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Unlike the first visit by officers from the Customs & Excise Officers, the second visit was not a surprise out of the blue event.  The local officer (from Chester) phoned me well in advance to make an appointment to visit and to look through our records and inspect any equipment. She made it clear that there would be opportunity to discuss other issues as well, and they would be very interested in the workings of our process. I must admit that even though we do keep very simple records of all our fuel produced, and invoices of all fuel sold, I was none-the-less quite apprehensive of what could happen. I have received may messages or letters from other fuel makers of the stringent and practically un-fullfillable requirements made upon small fuel producers. I attempted to have everything ready for them a printed out copies of the records, and also our basic business plant to show what we were trying to achieve in the longer term. I also got out all the stages of the process to demonstrate how the fuel is made. Just before they arrived, one of our pumps blew a seal, and I was just able to get the system running as they walked in to our garden gate.

In the circumstances, any apprehension on my part was totally unjustified. The two officers were the most pleasant and friendly people, and they were first to admit that this whole issue of bio-fuel making was a 'new baby' for them, and they welcomed any explanation. It was very useful that I had printed out our business plan which contained a clear description of the technical processes involved and a comparison with the manufacture of bio-diesel (RME).

If the officers from Chester are typical of those operating throughout the UK then I can assure everyone that they will be helpful, polite, fair and rational in their demands. They have a job to do which is to ensure that any tax is paid when due, and in some ways they have a difficult problem with any fuel made from recycled materials because it is so difficult to prove an audit trail for the input of waste or used materials. However, they can only enforce on the basis of procedures that are set out in statute, and it would seem that the custody of the industry relies very much upon self regulation. It is very clear that the whole problem could be overcome if Britain took the same position on bio-fuels as Germany, Poland and Italy but cutting all Excise Duty from organic or non-fossil fuels. This is of course a political issue, and not one that they can decide or probably even make a comment upon.

To complement the report we published of our first surprise visit from the enforcement side of HMC&E, I wish to emphasise that the second visit from the local officers was a very different affair, and left me feeling that the overall development of bio-fuels is something they wish to encourage and facilitate, but within an agreed regulatory framework. In the absence of any agreement on many issues they have a difficult job. At this stage they wish to be sure that we are open about the technicalities of our fuel processing, and they wish to encourage consultation through all stages of further development. They would like to see a clear audit trail maintained in any continuous commercial scale production process, to ensure that all stock converted for use as a fuel is fully accounted for.

I welcome any similar reports from people who have had inspections from officers of HMC&E. It is important to our business that there is a consistent approach to regulation, to ensure a level playing field. I am aware that some people have been asked to provide information that would be difficult to produce, however we need to look at each specific case within the context of a broad-based assessment.

A similar report from Simon Wass....

Hello John,

I had my first visit by Customs last Friday, and they went away with a mountain of questions!

They told me that I was the first person that has registered with them in this area, which as they came from Derby, I would say the whole of the East Midlands. One of the first things they told me was that I would have to prove my biodiesels quality as I mentioned in a previous e.mail. I told them that all the other people that I have heard of do not have to do this. They are going to get back to me, they say if others don't have to prove anything, then its not fair that I have to. I showed them the standard recipe's on the web, and also in the From the Fryer book, they were most amused by the book!

I told them about WVO being able to comply with the biodiesel tax, and they're going to get back to me on this one as well!

One good thing, was that he did say that he would do everything possible to help me, he did say they are trying to be 'cooperative and understanding' and he congratulated me (us, the whole vegi troop) on what we are trying to achieve.

The set aside bit was confusing as the biodiesel 'fat' is taxable as they said, basically when I put it in the car, but the WVO is taxable when it is filtered, so I'm just going to pay tax (if they let me) on the filtered WVO as it is easier that way for me.

As for the measuring quantities, he thought that if I record what goes into the WVO tank and what goes out, then he'd be happy with regular calibrated stick dipping to confirm amounts, which is reasonable. Over time, it should average out.

regards,
Simon Wass
7 October 2002

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