Supplying ethanol is not as straight-forward as most other products, requiring careful control and compliance. When ethanol is stored or transported under duty suspension, it is subject to strict HMRC regulation, with clear requirements covering every stage of the process.
In response to this, Kimia has developed a thorough due diligence process. While it may feel detailed at the outset, by guiding you through every step Kimia can ensure all parties operate safely, legally and with confidence.
Let’s look at this in more detail…
Duty Suspension: A Controlled Environment
Under duty suspension, excise duty is not paid until the product leaves a bonded environment. This system is tightly controlled, with HMRC requirements covering:
- The storage, handling and movement of alcohol
- The documentation required for each movement (e.g. EMCS, ARC, eAD)
- The responsibilities of producers, warehouse keepers, and traders
Given the level of duty involved, any mistakes in following the right process can create significant financial and operational risk, as liability for excise duty can fall to the wrong party.
Why We Request Detailed Information
Before we supply ethanol under bond, we need to confirm that each customer is authorised to receive it. This is a regulatory requirement and something we must get right from the start.
To make this easier, we’ll ask you for a few key documents, such as your Alcoholic Products Producer Approval (APPA), Authorised Warehouse Keeper registration (GBWK or XIWK), and, where relevant, Trade Facility Warehouse approval (GB00). We may also request AWRS details, EMCS access and supporting documentation like W7 or eAD information.
Our Due Diligence Form brings all of this together in one place. It helps us confirm that everything is set up correctly; that movements are compliant, goods are going to the right authorised location, responsibility is clearly defined and duty suspension requirements are maintained throughout.
We understand this can feel like a lot initially, but it’s there for a good reason. By putting these checks in place upfront, we help ensure everything runs smoothly, safely, and without risk — for you as well as for us.
Third‑Party Arrangements
If you need your product delivered into a third‑party bonded warehouse or contract manufacturing facility, we require written confirmation from the bond holder that you are authorised to operate under their approval.
This can be provided by email and must be received before we can process bonded supply on your behalf.
Why the Process Is Important
The consequences of getting things wrong under duty suspension can be significant. These can include duty liabilities and financial penalties, the seizure of goods, loss of licences or approvals, and, in some cases, regulatory investigation.
Even small errors in documentation or process can lead to issues, which is why it’s important to have everything set up and handled correctly from the outset.
Follow our due diligence process and you can be confident that these risks are minimised. It helps ensure your supply remains secure, compliant and straightforward to manage.
Once You’re Set Up
Once the initial set-up is complete, the ongoing process is simple. You place your order, we arrange the movement (including EMCS where required) and your goods are delivered in line with the agreed schedule. On receipt, the ARC is completed within the required timeframe and supply can continue reliably and predictably.
If you are ordering duty paid, the process is even easier. Many of the approvals and requirements outlined above aren’t needed, making it quicker and easier to get started.
Delivery Requirements
Our delivery requirements process is designed to make sure every delivery runs smoothly. From tail lifts to restricted access, booking requirements, delivery windows and vehicle suitability, completion of the form ensures our logistics partners arrive with the right equipment at the right time and fully prepared.
Planning these details in advance avoids common issues such as failed deliveries, additional costs or deliveries arriving outside your site’s opening times. It also ensures that everything runs as expected on the day with all the correct documentation to be fully compliant.
In Summary
Yes, our onboarding and due diligence process is detailed, and we ask you for a lot of information – but it’s all there for a reason.
Taking the time to get this right at the start means we can help protect you, protect your supply and ensure everything is fully compliant with HMRC requirements. It also allows us to build a reliable and consistent way of working with you from day one.
We understand that this can feel like a lot at first. Once everything is in place the day-to-day process becomes straightforward and you can order with confidence, knowing everything is correctly set up behind the scenes.
If you need any support – whether completing the documentation or understanding the difference between duty paid and duty suspended supply – we’re here to help.