Practical guidance for blending operations
For an ethanol/gasoline blending operation, the two assessments should therefore be performed separately.
Customs assessment:
Determine the composition of the product after blending and apply the relevant CN classification rules. Where the mixture meets the conditions of Additional Note 12 to Chapter 22, gasoline may constitute the denaturant for classification under CN 2207 20.
Excise assessment:
Separately determine whether the alcohol has undergone a denaturing procedure recognised under the excise legislation and whether the conditions for the excise exemption are met.
Consequently, the fact that a mixture is considered denatured ethanol for customs purposes does not, by itself, establish that it is completely denatured alcohol for excise purposes. Conversely, compliance with an excise denaturing procedure should not be used as the sole basis for determining the customs classification.
| Blend | Customs treatment |
|---|---|
| 100% ethanol | Ethanol; potentially 2207 10/20 depending on denaturation |
| 70% ethanol + 30% gasoline | 2207 20 00 – denatured ethyl alcohol |
| 50% ethanol + 50% gasoline | Still within 2207 20 00 |
| 40% ethanol + 60% gasoline | No longer covered by the specific 2207 mixture rule |
| E10: ~10% ethanol + 90% gasoline | Normally a 2710 motor-spirit/gasoline product, not an ethanol product |
| E5: ~5% ethanol + 95% gasoline | 2710 motor-spirit/gasoline product |
The relevant legal sources are:
- Commission Implementing Regulation (EU) No 626/2014 – customs classification and Additional Note 12 to Chapter 22.
- Commission Implementing Regulation (EU) 2017/2157 – classification of 70% ethanol/30% gasoline under CN 2207 20 00.
- Council Directive 92/83/EEC, Article 27 – excise exemption for completely denatured alcohol.
- Commission Regulation (EC) No 3199/93 – recognised procedures for complete denaturing of alcohol for excise purposes.