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# Measuring excisable alcohol volume and strength

How to measure product volume and test alcoholic strength to work out how much excise duty to pay.

Last updated 14 May 2023

## Your obligations as a manufacturer

As well as the general obligations for all excise licence holders, if you manufacture excisable alcohol products you must correctly:

• 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 report and pay.

To work out your excise liability on an alcoholic excisable product, you need to:

• determine the volume of alcohol contained in the product
• multiply it by the relevant excise duty rate.

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.

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

Make sure you keep adequate records that enable you to:

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

For the calculations, see Calculating the excise duty payable on excisable alcohol.

## How to measure volume of excisable product

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

To do this, you need to:

• ensure you have an accurate measurement of the volume of the final excisable alcohol product at the point of packaging for sale
• measure the volume at 20˚C (if you don't, you need to take a temperature reading so that it can be converted to 20˚C).

You also need to account for the volume of your products during the manufacturing process, and:

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

## Measuring and equipment

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

• conform with legal requirements pertaining to measurements as administered by the National Measurement Institute (NMI)
• 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
• any other method that consistently produces a similar result.

We recommend that you correct the temperature to 20˚C when you measure volume in the following 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 the reading to 20˚C, you must record the actual temperature when taking your measurements.

## Sampling and analysis for alcohol volume

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 liability on alcoholic excisable goods.

Dutiable volume means the volume of the product on which the excise duty is calculated.

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.

## How to measure alcohol strength

The second step in working out the litres 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 excisable alcohol product. When you measure the strength, you need to measure at 20˚C (if you don't, you need to take a temperature reading so that it can be converted to 20˚C).

You also need to account for the alcoholic strength of your products during the manufacturing process and 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.

For more information, see EXC 2019/1 Excise (Alcoholic strength of excisable goods) Determination 2019.

### Sampling and analysis for alcohol strength

To measure the alcoholic strength of an excisable alcohol 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.

## Excisable alcohol in bulk containers

You can sample excisable alcohol product in bulk containers 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 also required to ensure the accuracy of your strength measurements.

You must take enough samples from each production or packaging run to allow 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.

You should correct the temperature to 20˚C when you measure strength in the following 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˚C, you must 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
• 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˚C.

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˚C and in a vacuum).

You can have your products analysed by an independent laboratory if you want to check the accuracy of your measurements. If we have concerns about your measurements, we may verify your strength analysis methods by taking samples and have them independently tested.

## Measuring equipment and methods

The instruments that you use to measure alcoholic strength must conform with legal requirements for measurement as administered by the National Measurement Institute (NMI). This includes hydrometers, thermometers and weighing instruments.

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. When 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. 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. The tariff classification applicable to that strength applies.

When 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. 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. The tariff classification applicable to that strength applies.
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Example: measuring alcohol strength of brandy

Bottler Brandies take samples during their bottling run to test the strength of their brandy product. Their alcoholic strength testing shows the strength of the brandy to be 37.3% at a temperature of 20˚C.

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 of 0.2 percentage points, the strength of the bottles of brandy is accepted as being the labelled strength of 37.2% (not the actual strength).

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Start of example

Example: measuring alcohol strength of beer

Bevy Brewing complete 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˚C.

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

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

End of example