HCOTEG122095 - Marking: Authorisation and Approval: Issue of marking waiver approvals

The issue of marking waiver approvals

Marking waiver approval needs to be carried out locally

The local officer should put a report to his team manager:

• assessing the risk the trader presents to the revenue
• the suitability of the storage available for gas oil and kerosene
• the effectiveness of the trader’s proposals for segregation of stocks of unmarked rebated gas oil or kerosene form all other stocks of heavy oil and
• whether the trader’s accounting arrangements will comply with the conditions laid out in the model letter for authority to receive and use unmarked kerosene or gas oil (at the end of this section)
• whether unmarked oils are essential to the trader’s process ( the trader’s own case for this should be sought in writing)

The team manager, if satisfied, can issue an authority on the lines of the letters at HCOTEG213500 or HCOTEG213750 taking into account:

• the terms in the model letter
• that the authority should be time-limited, by which it will be renewed or lapse.
• consideration to additional conditions that could be made to protect the revenue (but these must be proportionate to the risk)

Arrangements are to be made to:

• periodically review the grounds for giving the authority.
• draw up a program of periodic physical checks, to be made according to risk, should examine; receipts, stocks, amount of use of unmarked oil. The results should be crosschecked against the trader’s records.

There needs to be an audit trail for any variation to the terms of the marking waiver and accordingly requests and our replies should be in writing.