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HMRC internal manual

Oils Technical Manual

HCOTEG121520 - Marking: background: what markers are used?

Fiscal markers

The markers that show that oil has attracted a rebated rate of duty and is not to be used as a road fuel or for heating are known as ‘fiscal markers.'

UK prescribed markers and colouring substances

In the UK we use both markers and colouring substances to identify oils which have been supplied at a rebated rate of duty other than for use as motor or heating fuel.

The use of markers is stipulated in Regulation 3 of the Hydrocarbon Oil (Marking) Regulations 2002 (HOMR), as amended by the Hydrocarbon Oil (Marking and Designated Markers) (Amendment) Regulations 2023.

3(2) The markers are -

the general marker (Solvent Yellow 124) added in the proportion of not less than 3 kilograms per 1,000,000 litres of oil;

quinizarin added in the proportion of not less than 1.75 kilograms per 1,000,000 litres of oil;

coumarin added in the proportion of not less than 2 kilograms per 1,000,000 litres of oil;

the common UK fiscal marker (Accutrace S10) added in the proportion of not less than 2.5 kilograms per 1,000,000 litres of oil;

n-butyl phenyl ether (Accutrace Plus) added in the proportion of not less than 9.5 kilograms and not more than 14.25 kilograms per 1,000,000 litres of oil.

3(3) the colouring substances are added in the proportion of not less than 4 kilograms of solvent red per 1,000,000 litres of oil and not less than 0.4 kilograms of solvent orange per 1,000,000 litres of oil;

(For further information on which oils must be marked, and their appropriate prescribed markers and colouring substances, see Notice 179, paragraph 8.3.)

Composite Markers

In practice, the required proportions of markers and colouring substances may be added to the oil to be marked in the form of a composite marker, which consists of a combination of prescribed markers, colouring substances and a carrying solution.

A small amount of this composite marker is then added in proportion to the volume of the oil that needs to be marked. These products are commercially available and are usually known as Gas Oil Marker Concentrate (GOMC) and Kerosene Marker Concentrate (KMC).

The standard ratio for the addition of GOMC to gas oil is 1:1,000 and for the addition of KMC to kerosene is 1:10,000. Markers should be used in accordance with the manufacturer's instructions to ensure compliance with the legal marking requirements.

Markers are obtained and supplied directly by commercial companies.

We require registered markers to store markers separately in labelled containers, to keep records of their use and carry out regular stocktakes.

(See Notice 179, paragraph 8.6.)

Commercially added markers

Commercial delivery firms are increasingly adding a marker (usually an anti-theft dye) to their fuel, in order to stop employees filling their own tanks, as well as the company vehicles.

Blue anthraquinone dyes can interfere with the detection of the prescribed fiscal markers and colouring substances.

Under the Hydrocarbon Oil (Marking) Regulations 2002, regulations 14(3) and 15(1), as amended by the Hydrocarbon Oil (Marking) (Amendment) Regulations 2007, gas oil and kerosene may not be marked with any marker or substance that interferes with HMRC's ability to detect the prescribed fiscal markers.

For further information see HCOTEG36500