Section 13 — measurement of quantity
Source: gov.uk (2025-11-18)

Information on measuring the quantity of alcoholic product as an alcoholic product producer.

13.1 General

As long as due care, as set out below, is taken, the quantity of alcoholic product in any container is the volume included on:
- the label on the container
- any invoice issued in relation to the alcoholic product
- any delivery note issued in relation to the alcoholic product
- any document similar to an invoice or delivery note issued in relation to the alcoholic product
If the volumes of the alcoholic product in the above sources differs, the greatest of the different volumes must be used.

13.2 Due care

This section has force of law under regulation 2(5) of the Alcoholic Products (Excise Duty) Regulations 2023.

‘Due care’ is the term used for measures you have in place to monitor the filling process and actions you take to prevent and rectify any instances of excessive over-filling or under-filling.

You must take due care to make sure the quantity included on the label and documents above and therefore used to calculate the duty accurately reflects the actual volume of the product in the container.

You should monitor the filling process to make sure that the quantity put into the package does not regularly excessively exceed the amount declared on the container. You should record these checks and provide an adequate audit trail to satisfy our officer that care has been taken. Where there is evidence of consistent excessive overfilling, additional duty will be due.

If due care is not taken, the volume of alcoholic product in the container used to calculate the duty will be the actual volume of the alcoholic product.

13.3 Combining the results of monitoring the volume for 2 or more products

We will normally require you to assess the monitoring results separately for each product. However, if in exceptional circumstances, for example, where a small amount of a seasonal product is packaged and separate monitoring would produce an inequitable outcome, we will consider requests for combining and monitoring results for a number of products.

13.4 Small pack

Small pack refers to containers of 10 litres capacity of less. Alcoholic product producers are required to demonstrate due care, as set out above, when filling containers.

13.5 Large pack

Large pack refers to containers with a volume of more than 10 litres up to a maximum of 400 litres, such as kegs and casks. Containers with a capacity in excess of 400 litres are generally referred to as ‘bulk’. Alcoholic product producers are required to demonstrate due care, as set out above, when filling containers.

For large pack containers, alcoholic product producers must take steps to make sure they are operating within the set tolerance limits. Details on the tolerance limits are set out below.

If a large pack does not meet the tolerance requirements the volume of alcoholic product in the container used to calculate the duty will be the actual volume of alcoholic product.

Tolerance requirements for large packs filled with a metered or weighted volume of alcoholic product

In the case of filling alcoholic product controlled by meter or weighing, the volume of alcoholic product for each container must not exceed the volume on the label, invoice, delivery note or similar document by more than these tolerances:
- a large pack containing a volume exceeding 100 litres, 0.5% of that volume
- or in any other case, 0.5 litres.
If the volumes on the label, invoice, delivery note or similar document are different, then the one that is the greatest is used for tolerance purposes.

Tolerance requirements for large packs filled with alcoholic product that is not metered or weighted

In the case of filling alcoholic product not controlled by meter or weighing, the volume of alcoholic product for each container must not exceed the volume on the label, invoice, delivery note or similar document by more than the following tolerances:
- 3 litres for a pack containing more than 200 litres of volume
- 2 litres for a pack containing more than 100 litres but not exceeding 200 litres
- 1 litre for any other case
If the volumes on the label, invoice, delivery note or similar document are different, then the one that is the greatest is used for tolerance purposes.

13.6 Exceeding the overfill tolerances

If the volume of containers for a racking line exceeds the specified tolerances in any accounting period, there will be additional duty liability when that alcoholic product is sent to home use. The volume on which additional duty is then liable is the quantity of alcoholic product in excess.

13.7 When to pay the additional duty

Duty becomes payable at the end of the accounting period in which a container of alcoholic product is delivered to home-use. That is, when it passes the duty point.

Where you’re incurred an additional duty liability as a result of overfilling, the additional duty should be paid in the relevant accounting period when alcoholic product is supplied to home use from your approved premises, or from excise warehouses owned or operated by your company.

In the case of overfilled containers of alcoholic product supplied in duty suspension to third parties, you should record details of these deliveries separately in your records. The law requires that the person holding the goods at the time of their delivery to home-use is liable for the duty, including that on the volume in excess of the declared quantity. However, if we are satisfied that the third party was unaware that the container had been overfilled and that the third party is entirely independent of you, we will not normally seek to recover the additional duty due. In deciding whether or not to pursue the additional duty, we will take into account the:
- relationship between you and the third party
- contracts of supply, if appropriate
- the price paid for the goods
- any other information considered relevant
If you fail to either properly record or pay the additional duty due (or both) on excess volume that you’ve delivered to home-use, we will assess you for the additional duty due. If you cannot produce accurate records upon which the additional amount of duty can be readily established, including quantities delivered to home-use, we will use ‘best judgement’.

13.8 Imports of small and large pack

International obligations require that we cannot treat imports any less favourably than domestic products. As importers will not necessarily be aware of the actual contents of containers, we will apply the same principle set out in the above paragraph ‘When to pay the additional duty’.

13.9 Arrangements for cans with widgets

If the widget that you use retains alcoholic product, then that retained quantity need not be declared for duty purposes. You must carry out tests to confirm the average retention volume. This average retention must be agreed with HMRC. Once agreed, due care can be applied to the labelled quantity plus the retained amount.

13.10 Cask conditioned alcoholic products

The following text has force of law under Regulation 5(3) of The Alcoholic Products (Excise Duty) Regulations 2023.

Duty need not be charged on any undrinkable sediment in your cask-conditioned alcoholic product provided:
- your customer (for example, the publican) is made fully aware in writing, at or before the time of receipt, of the quantity of product on which duty has been charged — if for example, a barrel (163.7 litres) contains 2.3 litres of undrinkable sediment, the customer must be made aware, by a statement on the label, delivery note, or price list and so on, that duty has been charged on 161.4 litres (a copy of the notification to customers must be retained)
- you can, if required to do so, satisfy our officer that only undrinkable sediment has been excluded from the duty charge
Any sediment on which duty has not been charged, cannot be included in any subsequent claims for relief on spoilt alcoholic product.

13.10.1 Calculating the amount of undrinkable sediment

There is no prescribed method to calculate the amount of undrinkable sediment in your cask-conditioned product. You must, however, be able to satisfy us that the method you use gives equitable results.

Sediment levels for each quantity of alcoholic product and container size must be regularly monitored by alcoholic product producers and reviewed or amended (as necessary) at least annually and notified to us. Any changes to recipes or ingredients during the year, which would significantly affect sediment levels must be notified to us and the allowance adjusted accordingly. You must write to HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries).

13.10.2 Undrinkable sediment allowances for polypins, mini-pins and bottle conditioned products

There are no undrinkable sediment allowances for polypins, and mini-pins sold by producers to the public, or on bottle-conditioned alcoholic products.