Procedure for the issue of Duty Free Spirits V2

Contains public sector information licensed under the Open Government Licence v1.0.

 

January 2023

 

Preliminaries

HMRC places strict controls over the use of Duty Free Spirits (DFS), guidance for which can be found in HMRC Notice 47:

Paragraph 7.2 “you may use duty-free spirits only for the purposes, and under the conditions, specified in your letter of authority”.

 The purposes authorised to Medical School QMC are as follows:

·       Teaching and Research purposes  

·       Specialised staining in microscopy    

·        Storage of pathological specimens   

·        Recrystallisation of chemicals and organic products  

·        Extraction and separation of organic products   

·        Making of reagent solutions     

·        Internal mechanical preparations         

·        Sterilisation of incubators, flowhoods, stages and microscopes   

Paragraph 3.4 ” Duty free spirits cannot be used for general cleaning or other purposes”

Though the Notice also states:

Paragraph 1.6 “However, duty free spirits can be used for specialised cleaning purposes if you can prove that denatured alcohol would be detrimental to the process or the presence of a denaturant would affect an end product. You must provide proof of the detrimental effects which using denatured alcohol would cause. Each case will be looked at individually and on its merits. Where necessary, consultation with the HMRC appointed analyst will be undertaken.”

 

Duty may become payable on any spirits used for unauthorised purposes.   

The Notice also places restrictions on the quantity issued:

Paragraph 7.2 “You may withdraw duty-free spirits from stock only in the quantities you need for immediate use for an approved purpose”.

 

 

 

 

Process (see appendix 1 for flow chart representation)

 

1.       A standard Stores requisition, authorised by a nominated signatory (DFS approver), is submitted to Stores accompanied by a DFS declaration of use form (form MSSDFS1), the bottle that you are replacing, and its completed record of usage sheet (form MSSDFS2). If there is residual spirit in the previously issued bottle you should decant the spirit shortly before you collect the replacement bottle. The empty bottle will be returned to the supplier for recycling, so the surface of all bottles should be decontaminated with a suitable disinfectant (e.g. Chemgene) and returned to Stores accompanied by a certificate of decontamination (form MSSDFS3). If you feel that the bottle cannot be fully decontaminated then please dispose of the bottle using your established disposal routes and notify the Stores that you have done so. Please record this fact on the requisition for any replacement bottle.

 

2.       Stores will release ethanol in 2.5L containers individually labeled to apply a unique identifier:

          MSS/DFS        13001

 

 

 

This number will be recorded on the Stores requisition and accompanying MSSDFS1 declaration of use form.

 

A numbered record of usage sheet (MSSDFS2) will be issued to the user to allow details of usage to be recorded in order to “establish that the spirits have been put to the authorised use” (paragraph 9.1). Stores will record details of the bottle issue and return in the DFS spreadsheet.

 

User responsibility (see appendix 2 for flow chart representation)

 

Once the DFS has been issued the user shall assume responsibility for some of the University’s obligations to HMRC:

 

Under paragraph 9.1, the University is required to keep a stock account of usage. Accordingly, users are expected to make an entry (in ink) in the MSSDFS2 record of usage log sheet each time they use DFS.

All spirit should be accounted for when the bottle is empty.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         

Paragraph 7.6: What should I do if some spirits are lost?

You must record:

  • losses in storage
  • accidental losses in processes, for example due to operational faults
  • investigations into the losses, including any management decisions take [sic], and
  • report more serious losses or deficiencies in line with arrangements agreed with your local office.

You should record any losses immediately in your business records [users should use the ‘record of usage’ sheet]. You should date, time and sign this record.

You will have to pay an amount equivalent to Excise duty (and VAT, if applicable) on any spirits which you cannot account for satisfactorily. See www.hmrc.gov.uk/rates/alcohol-duty.htm

Stores must be notified of instances of lost spirit.

IMPORTANT.  Paragraph 7.2 “You must not remove duty-free spirits from your authorised premises”.

“Unless, we have given you special permission, you may not use duty-free spirits in a room in which duty paid spirits, methylated spirits or other industrial alcohols are used.”

The authorised premises is the Medical School, Queens Medical Centre. You must notify Medical School Stores if your laboratory is expected to relocate outside of the Medical School at QMC.

Furthermore:

Paragraph 5.1. You must “ensure that duty-free spirits on your premises are kept securely”.

Guidance on how duty free spirits should be stored is provided:

Paragraph 7.1

You must keep your stocks:

  • in a place approved by us [HMRC]
  • under lock, and controlled by you or a responsible employee, and
  • kept apart from any duty-paid spirits, methylated spirits or any other industrial alcohols you may have on your premises.

It is the University’s responsibility to stock take DFS “on hand at intervals not exceeding 12 months”. This may mean that users will have to verify DFS holdings at the financial year-end. Any DFS approvers who are changing roles and will no longer be responsible for the spirit should report this to Medical School Stores before leaving the role, identifying a colleague with clear responsibility for the particular area of work who is willing to take responsibility for the spirit.

A failure to uphold these requirements may result in your removal from the list of approvers.

Appendix 1

DFS request process

 

 

Appendix 2

DFS user responsibilities

 

                                                                   

 

 

 

 

 

 

Appendix 3

Stores responsibilities