DNALC4055 - Approval of process and entry of premises (producers): How can a producer denature alcohol? - ‘In line’ denaturing

Another system of denaturing involves ‘in-line’ blending. Using this method, alcohol, markers and denaturants are released from separate holding tanks for mixing (denaturing) in the pipework of the plant before being received into a road tank wagon. This system enables the producer to produce denatured alcohol to order, thus eliminating the need to hold bulk stocks of various denatured alcohol formulations. This system has obvious advantages for the producer, but you should fully consider and address the risks to the revenue inherent in the trader’s proposed system before giving approval.

In particular, you must be satisfied that the denatured alcohols produced will meet the standards set out in Notice 473. The producer should be required to provide an adequate level of assurance by either sampling every batch of denatured alcohol produced or have in place a satisfactory verification system (e.g. a pre-mixed and tested marker and denaturant concentrate which can provide assurance of denaturing adequacy by monitoring the denaturant content of the final product).

The producer must be made aware that under-denatured alcohol remains liable to duty at the rate appropriate to the type of alcohol used and that it is therefore in the producer’s own interests to ensure that the correct standards are maintained.

If you need assistance when considering applications for ‘in-line’ denaturing operations, contact the Alcohol Team Policy Team who will be pleased to offer further advice.