• # Measuring excisable alcohol product volume and strength

In addition to the general obligations for all excise licence holders, if you manufacture excisable alcohol products you have additional obligations to:

• measure product volume
• test the alcoholic strength of the product.

This is so you can accurately work out how much excise duty you need to pay.

To work out how much excise duty you need to pay on an alcoholic excisable product, you need to work out the volume of alcohol contained in the product and then multiply it by the relevant excise duty rate.

The volume of alcohol in excisable products is the volume of alcohol when it's measured at 20 degrees Celsius. You may need to make adjustments to be able to state the volume of alcohol at 20 degrees Celsius.

You work out the volume of alcohol (known as litres of alcohol, or LALs) in a product by multiplying the volume of the product by its alcoholic strength. For beer, excise duty is worked out on the alcoholic content above 1.15%.

Make sure you keep adequate records that enable you to:

• demonstrate you have met these additional obligations
• show how you worked out the amount of excise duty you had to pay.

## Product volume measurement

The first step in working out the volume of alcohol, or LALs, in a product is to make sure you have accurate measurements of the volume of the final excisable alcohol product, at the point of packaging for sale.

You need to:

• accurately measure the volume of your product to calculate the amount of excise you need to pay
• measure the volume at 20 degrees Celsius (if you don't, you need to take a temperature reading so that it can be converted to 20 degrees Celsius).

In addition to needing to measure the volume of the final excisable alcohol product for the purposes of working out the volume of alcohol, you also need to account for the volume of your products during the manufacturing process. You need to:

• keep records of the volume of your product during manufacture
• be able to show us your records if we ask to see them.

In this information, a container means any article able to hold liquid. A bulk container means a container able to hold more than two litres of liquid.

### Measuring and equipment

The instruments and processes that you use to measure the volume of alcoholic excisable products must:

• conform to legal requirements for measurement
• consistently produce an accurate result.

Examples include:

• volumetric glassware
• a tank that uses a dip-stick, tape or sight glass
• weight and density
• flow meter calibrated by an appropriate authority, or
• any other method that consistently produces a similar result.

We recommend that you correct the temperature to 20 degrees Celsius when you measure volume in these situations:

• when you receive spirit from another premises
• when you deliver spirit to another premises
• in the header tank or bottling vat, immediately before you start packaging.

If you don't correct it to 20 degrees Celsius, you will need to record the actual temperature when your measurements are done.

### Sampling and analysis

You must take enough samples from each production or packaging run to ensure the average fill volume of the samples taken accurately reflects the average fill volume of all the containers. One sample is not enough. You can judge what is enough by considering things like the:

• circumstances and size of the run
• consistency of the product.

### Permitted variations for alcoholic volume

Small variations are permitted for the purposes of working out the excise duty payable on alcoholic excisable goods.

Dutiable volume means the volume of the product that you will need to pay excise duty on.

For alcoholic excisable goods packaged in a bulk container:

• if the volume of the contents is not nominated, the dutiable volume is the actual volume of the contents
• if the volume of the contents is nominated and
• the actual volume of the contents does not exceed 101% of the nominated volume, the dutiable volume is the nominated volume
• the actual volume of the contents exceeds 101% of the nominated volume, the dutiable volume is the actual volume.

For alcoholic excisable goods not packaged in a bulk container:

• if the volume of the contents is not indicated on the container, the dutiable volume is the actual volume of the contents
• if the volume of the contents is indicated on the container and
• the actual volume of the contents does not exceed 101.5% of the indicated volume, the dutiable volume is the indicated volume
• the actual volume of the contents exceeds 101.5% of the indicated volume, the dutiable volume is the actual volume.

Food Standards Australia New Zealand also provide information about the requirements imposed by the Australia New Zealand Food Standards Code.

## Alcohol strength testing

The second step in working out the volume of alcohol, or LALs, in a product is to make sure you complete accurate testing of the alcoholic strength of the final excisable alcohol product, at the point of packaging for sale.

Alcoholic strength refers to the percentage of alcohol that exists, by volume, in an alcoholic beverage when that beverage is at 20 degrees Celsius. When you measure the strength, you need to measure at 20 degrees Celsius (if you don't, you need to take a temperature reading so that it can be converted to 20 degrees Celsius).

In addition to needing to measure the alcoholic strength of the final product for the purposes of working out the volume of alcohol, you also need to account for the alcoholic strength of your products during the manufacturing process. You need to:

• keep records of the alcoholic strength of your product during manufacture
• be able to show us your records if we ask to see them.

### Sampling and analysis

To measure the alcoholic strength of an alcoholic product, you need to analyse samples of the product after it has reached its final alcoholic strength.

### Packaged excisable alcohol products

To analyse samples of packaged excisable alcohol products, you can either sample them:

• in the header vessel immediately before packaging
• directly from the packaging line.

### Bulk excisable alcohol products

You can sample bulk excisable alcohol products at any point after they reach final alcoholic strength.

For non-commercial beer produced at brew on premises shops (BOPS), you can use the strength you worked out from the test brews of each recipe. You don't need to sample each batch you produce. However, if you change the recipe you will need to remeasure the strength.

### How to ensure accurate strength measurements

You are required to ensure the accuracy of your strength measurements.

You must take enough samples from each production or packaging run to enable you to establish an accurate actual strength. One sample is not enough. You can judge what is enough by considering things like the:

• circumstances and size of the run
• consistency of the product.

For example, if beer in a single run was drawn from different final storage or packaging tanks, you should take samples from each tank so that you consider any difference in strength between the tanks. By doing this, the final average strength will be more accurate.

We recommend you correct the temperature to 20 degrees Celsius when you measure strength in these situations:

• when you receive spirit from another premises
• when you deliver spirit to another premises
• in the header tank or bottling vat, immediately before you start packaging.

If you don't correct it to 20 degrees Celsius, you will need to record the actual temperature when your measurements are done.

The alcoholic strength of a particular alcoholic excisable product:

• is the average of the strength of all the sample measurements for that product
• is expressed as a percentage, by volume, of the alcohol that exists in the alcoholic beverage if the alcoholic strength were measured at a temperature of 20 degrees Celsius

When you calculate volume by reference to the specific gravity of alcohol, you need to calculate on the basis that the specific gravity of alcohol in relation to water is 0.79067 (based on a temperature of 20 degrees Celsius and in a vacuum).

If you want to check the accuracy of your measurements, you can have your products analysed by an independent laboratory. If we have concerns about your measurements, we may verify your strength analysis methods when we draw samples.

### Measuring equipment and methods

The instruments that you use to measure alcoholic strength, including hydrometers, thermometers and weighing instruments, must conform to legal requirements for measurement.

You can use any of the following methods to measure alcoholic strength:

• gas chromatography
• near infra-red spectrometry
• distillation, followed by the gravimetric measurement of the distillate or by measurement in a density meter
• any other method capable of measuring the alcoholic strength to an accuracy of plus or minus 0.2 percentage points of the actual strength.

If you produce less than 100,000 litres of fermented beverages (including beer) in a financial year, you may use a hydrometer and a formula to determine the alcoholic strength of each fermented beverage. You must keep documentation that shows the formula produces accurate results.

### Permitted variations for alcoholic strength

Small variations are permitted. For the purposes of working out the excise duty payable on alcoholic excisable goods (excluding beer subject to secondary fermentation):

• if the actual strength does not exceed the labelled (or otherwise indicated) strength by more than 0.2 percentage points, the strength is the labelled (or otherwise indicated) strength and the tariff classification applicable to that strength applies.
• if the actual strength exceeds the labelled (or otherwise indicated) strength by more than 0.2 percentage points, the strength is the actual strength and the tariff classification applicable to that strength applies.

For the purposes of working out the excise duty payable on beer subject to secondary fermentation:

• if the actual strength does not exceed the labelled (or otherwise indicated) strength by more than 0.3 percentage points, the strength is the labelled (or otherwise indicated) strength and the tariff classification applicable to that strength applies.
• if the actual strength exceeds the labelled (or otherwise indicated) strength by more than 0.3 percentage points, the strength is the actual strength and the tariff classification applicable to that strength applies.

Example 1

Bottler Brandies takes samples during their bottling run and test the strength. Their alcoholic strength testing shows the strength of the brandy to be 37.3%, at a temperature of 20 degrees Celsius.

The alcoholic strength of the brandy stated on the bottle label is 37.2%, meaning that the difference between the labelled strength and the actual strength is 0.1%.

As the actual strength of the brandy does not exceed the permitted variation (tolerance) for this product, 0.2%, the strength of the bottles of brandy is accepted as being the labelled strength of 37.2% (not the actual strength).

End of example

Example 2

Bevy Brewing completes a racking run of 10 kegs of beer. The beer is not subject to secondary fermentation.

Their strength testing shows the strength of the beer is 5.3%, at a temperature of 20 degrees Celsius.

In their records, they have nominated that their kegs will be filled with beer with a strength of 5.0%, which means that the difference between the nominated strength and the actual strength is 0.3%.

As the actual strength of the beer exceeds the permitted variation (tolerance) for this product, 0.2%, the strength of the beer is accepted as being the actual strength of 5.3% (not the nominated strength).

End of example