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HMRC internal manual

Duty Free Spirits Guidance

From
HM Revenue & Customs
Updated
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Technical Guidance: Can Duty Free Spirits be used for damping nitrocellulose?

Yes. But it depends on the final use which the nitrocellulose is to be put.

Nitrocellulose can be used in the manufacture of many products, such as the manufacture of printing ink for food labelling. In this instance we allow the use of undenaturedethanol for the following reasons:

  • Nitrocellulose is a highly volatile product and requires to be kept moist to enhance its stability and shelf-life and allow safe transportation. In its dry state it is classed as an explosive.
  • Nitrocellulose can be damped with water but this reduces the quality of the product. The most effective material for keeping it moist is pure ethanol. This has been achieved in the past by IDA but when the denaturants in IDA were found to be toxic, in 1996, HMRC approved the use of trade specific denatured alcohol (TSDA). The TSDA, though, was made with cyclohexane and it has recently been discovered that cyclohexane contains benzene, which is a carcinogen.

If a trader wants to use undenatured ethanol to damp nitrocellulose, therefore, he must prove to you that the current formulations of denatured alcohol are unsuitable to their processes or to the final product. We must then make sure that the final use of DFS in the nitrocellulose does not contravene the Directive.

If you receive any queries about this subject, please contact ESM for advice.