HCOTEG41000 - Authorisation and approval: What do traders have to get our authorisation or approval for?

This is a list of the things that a trader or person is required by law to get HMRC Authorisation or Approval for:

Common storage

  • Approval is required for the use of common storage, specifically to approve duty-suspended oil tanks as part of an Oil Warehouse approval, in accordance with the Customs and Excise Management Act (CEMA) 1979 section 92 and Excise Notice 179 section 3.9.

Customs & Excise Warehouse (Import)

  • Approval is required for operating a Customs or Excise Warehouse, authorising the applicant as a warehouse keeper and approving the premises under CEMA section 92, with guidance in EN 179 and EN 197.

Duty Deferment

  • Approval is required for any revenue trader wishing to use duty deferment arrangements, applied for on forms C1200–C1202 under CEMA section 127A and the Excise Duties (Deferred Payment) Regulations 1992, as detailed in EN 179 sections 10–11.

Entry of Premises – Registration

  • Registration of premises is required before production may begin, applied for on form EX103 under CEMA section 108 and the Hydrocarbon Oil Regulations 1973 reg. 3, with relevant guidance in EN 179 and EN 179e.

Furnace Operator

  • Approval is required for a furnace operator to receive rebate on light oil used as furnace fuel, obtained in writing to MORC under the Hydrocarbon Oil (Industrial Reliefs) Regulations 2002, as set out in EN 184B section 2.2.

Gas for Road Fuel

  • Approval is required for a revenue trader to supply or use duty paid gas as a road fuel, applied for on form C\&E 930B under the Gas (Road Fuel) Regulations 1972 and related legislation, in accordance with EN 76.

Marking in Warehouse

  • Approval is required for the marking of oil in a duty suspended warehouse, with applications made to the local officer under the Hydrocarbon Oil (Marking) Regulations 2002, as referenced in EN 179 section 8.8.

Mixing (duty paid)

  • Approval is required for mixing duty paid oil in a pipeline to produce a new oil, applied for in writing to the local officer under the Hydrocarbon Oil (Mixing of Oils) Regulations 1985 and the Hydrocarbon Oil Duties Act (HODA) section 20A, as detailed in EN 179 sections 9.3, 9.4 and 9.8.

Mixing – Licence

Approval is required for mixing rebated or partially rebated oils with unrebated oil, applied for in writing to the local officer under the Hydrocarbon Oil Regulations 1973, the Mixing of Oils Regulations 1985 and HODA section 20A, as referenced in EN 179.

Netting

  • Approval is required for revenue traders to use netting arrangements, applied for in writing to the local officer for the Central Accounting Point Office (CAPO) under the Excise Duties (Deferred Payment) Regulations 1992, as stated in EN 179 section 12.3.

Occasional Importers

  • Approval is required for occasional importers of excise goods, applied for on form C\&E 1165 under the Excise Goods (Holding, Movement and Duty Point) Regulations 2010, as set out in EN 204a.

Use of Rebated Oil 

  • Approval is required for the repayment of rebate and for the use of rebated heavy oil as road fuel or in excepted machines under HODA and associated rebate regulations. Control of dealers in controlled oils is governed by HODA section 24AA and the Hydrocarbon Oil (Registered Dealers and Controlled Oil) Regulations 2002, with practical user and dealers' obligations set out in EN 75 and EN 192.

Oil Producers – Premises

  • Approval requirements for oil producers’ premises follow the rules for entry of premises and oils warehouse approvals under the Hydrocarbon Oil Regulations 1973 section 3, with guidance in EN 179 and EN 179e.

Oil Warehouse - keepers

  • Approval is required for warehouse keepers as legal entities, applied for on form EX61/61A under CEMA section 100G, in accordance with EN 179 sections 3.3 and 3.7. 

Oils Warehouse (Excise/Tax Warehouse)

  • Approval is required to authorise a warehouse keeper and approve warehouse premises, applied for on form EX70/EX71 under CEMA section 92, in accordance with EN 179 section 3.4 and EN 197.

Operations in an Approved Warehouse

  • Approval is required for operations carried out in an excise or tax warehouse under the Excise Warehousing Regulations 1988, with relevant guidance in EN 179 section 6 and EN 197.

Pipeline Mixing (Approved)

Approval is required for pipeline operators and shippers before mixing oils of different duty categories, and this must be applied for in writing under HODA section 20A and the Mixing of Oils Regulations 1985, as set out in EN 179.

Pipeline – Moving Goods

Approval is required for pipelines used to import or export uncleared goods or move goods from warehouse duty unpaid, applied for in writing to the local officer under CEMA section 24, as set out in EN 179 section 9.

Plant – Approval

Approval is required for plant and structural alterations in a warehouse, applied for on forms EX70/EX71 under the Hydrocarbon Oil Regulations 1973 section 9, in accordance with EN 179 section 3.

Port – Boundary Definition

Approval is required to define the boundary of a port, applied for through the National Approval Unit under CEMA section 19.

RDCO – Registered Dealers in Controlled Oil

Approval is required for individuals or legal entities dealing in controlled oil, applied for on form HO4 under HODA section 24AA and the Hydrocarbon Oil (Registered Dealers and Controlled Oil) Regulations 2002, as detailed in EN 192 section 4.1.

Records – Keeping of

Approval is required for revenue traders to meet record keeping obligations under the Hydrocarbon Oil Regulations 1973 and the Revenue Traders (Accounts and Records) Regulations 1992, as referenced in EN 206.

Registered Consignees (NI) and GB Arrangements

  • Northern Ireland: Traders must be approved as Registered Consignees to receive duty suspended excise goods under the Excise Goods (Holding, Movement and Duty Point) Regulations 2010, with operational guidance set out in Excise Notice 203A.
  • Great Britain: The REDS approval no longer applies; traders must follow the excise duty point and movement rules set out in the Excise Goods (Holding, Movement and Duty Point) Regulations 2010.

Registered Owners

Approval is required for registered owners of excise goods (except hydrocarbon oils) to carry out due diligence in accordance with the Excise Duties (Miscellaneous Amendments and Revocations) Regulations 2024, with detailed requirements set out in EN 196.

Registered Remote Markers

Approval is required for individuals or entities acting as remote markers, applied for through MORC under CEMA section 100G and the Hydrocarbon Oil (Registered Remote Markers) Regulations 2005, as outlined in EN 179 section 8.8.

Repayment User

Approval is required for repayment users, applied for on form HO27 under the Industrial Reliefs Regulations 2002, in accordance with EN 179 and EN 207.

Tied Oil Trader

Approval is required for tied oil traders distributing or using tied oils in industrial processes, applied for on form HO27/HO27b under the Industrial Reliefs Regulations 2002, as set out in EN 184A section 6.