Wednesday, 29 July 2009

HMRC - Result... its legal after all...

I've just had a reply from HMRC, following my latest email. They have finally stopped beating about the bush, and given me the answer to the question, instead of lots of bizare reasons why I can't or shouldn't run the Landrover on waste engine oil. I'm so pleased, I'm thinking of putting a framed copy up on the wall.

Dear Mr Eastwood

Thank you for your emailed enquiry dated 24th July 2009 requesting further information on the HMRC requirements when processing waste oil with a view to using it as road fuel.

In the light of the information provided in your email you will be regarded by HMRC as a recoverer of waste oil and you will be required to ‘make entry’ of your premises by formally notifying us on Form EX103 (or EX103A if you are an incorporated company) which is available on our website. The completed form should be submitted to the Mineral Oils Relief Centre, HMRC, Building 4, BP4002, Benton Park View, Longbenton, Newcastle upon Tyne, NE98 1ZZ, and marked for the attention of Barry Nicholls.

Having entered your premises you will be required to pay excise duty on the recovered oil at the full diesel rate which is currently £0.5419 per litre. Form W50 will need to be submitted, with immediate payment, to the National Warrant Processing Unit before any oil is used for road fuel. Unfortunately that Unit is currently located in temporary accommodation so you will be advised of the correct address and payment procedure on completion of the EX103 submission.

The only HMRC publication that covers the scenario you propose is Revenue & Customs Brief 45/08. Certain elements of that document have been overtaken by subsequent changes – very noticeably the addresses of the sections involved - but most of the general principles outlined in the Brief still apply.

I hope this is of assistance.

I must emphasise that the advice given is based on the information you supplied. It only relates to HMRC procedures and pays no regard to any requirements imposed by other organisations. Moreover if the nature of the transaction changes in technical detail, or the relevant details provided were incomplete or incorrect, we will not be bound by this advice.

Yours sincerely,

Steve Preston

Looks like the waste oil powered 200 will be up and running shortly... the mpg of a diesel, at fuel the price of lpg... result.

Monday, 27 July 2009

Tonight I have mostly been

...reading up greek legends. No, that doesn't sound pausable somehow.

Ok then, I spent the evening drinking coco and watching Corrie on the box. No, don't belive me...

Right, I may have to own up then. Tonight I spent lying on my back underneath Bitsa, doing a simple job. Changing one engine mount.

If I was in the workshop I'd have just parked under the block and tackle, wipped the nose of the engine up, swapped the mounts and stuck a new one in. However tonight I changed one in the boatyard carpark with a 15mm spanner and a crowbar. Basically, the sport consisted of levering the engine about with the crowbar while reaching into the vicinity of the mount and trying to do the chinese puzzle which is tickling the engine mounts into place. This is not a sport for the sqeamish, but hopefully the fingers I trapped will have recovered sufficently by sunday for my to still manage to play the organ at Church. (Yes, I am an occasional church organist, even if that sounds less pausable than the claim that I watch Corrie(I don't))
Now, I thought with diesel engine mounts, here was somthing that even Britpart couldn't mess up. How wrong I was. Just guess what eats Britpart diesel engine mount rubbers, and turns them into a sticky jelly. Not washing up liquid. Not nitric acid, or at least, it may do, but I've not tried. Not rain, even acid rain. No, somthing more common on a diesel engine than any of the above... yep, you've guessed it - diesel. You would think it would be possible to make a rubber compound that can withstand diesel... fuel filters seem to have some sort of rubber seals that don't fail.

Talking of fuel filters, and leaked diesel, I think I've finally sorted the largest single cause of Bitsa's leaks - the fuel filter housing. Having traced the path of some of the significant quanties of oil that were running down the engine and onto the floor, it appeared that there was a small, but stead drip comming from the tank bleed back union on the filter. This had had the thread partially striped and that was probably the start of most of my problems. Anyway, I've now fitted a new fuel filter housing, that I found hiding in the back of the workshop the otherday, and she only seems to have the usual oil leaks now.

I also have a top tip for those changing fuel filters, particularly if they have iffy fuel lift pumps. Get a decent sized syringe, and you can fill the new filter in a few moments, with no mess. Incidentally, a syringe is a very handy addition to any toolkit for lots of jobs like this - apparently they are very good for filling steering relays(there is a saga here, involving a knackered relay that doesn't wish to depart Bitsa's front crossmember, but don't even ask just at the moment, I'll publish the full story as and when I've managed to get it out), and also for testing dizzy vac advances.

While I was fooling underneath the old shed, I figured it was about time I did somthing about the fact that one of the major mounting points for the exahust was the top of the rear axle. Those with memories of the 07 Series 2 Club Northern Gathering may recall that my truck caught fire about 4 times in the course of that weekend. The root cause was a faulty wiper switch which was occasionally earthing its live feed throught to the dash pannel face. The resuling current and consiquent heat burnt the insulation off the main pannel feed, which I wrapped in insulation tape as a "get me home, and the be ignored for the next year or so" sort of bodge. Anyway, in the recent rebuild, this delightful bodge was finally replaced, and the big bit of burnt looking heavy duty wire ended up with 1001 other bits of junk floating about in the toolbox. Not being a man to waste anything, this has now been recycled into a handy exahust mount, that holds the rear pipe a good 3" clear of the back axle. At some point I will replace this bodge with a propper rubber mount, but probably only in about 2020, or when the big of burnt looking wire breaks, whichever happens first.

I'm now nearly ready for EOD, which is a good job, as its only four days away now. The engine mount change I had deemed essential before I taking her laning/ragging her round Hartington quarry(one of the rubbers had been in the habbit of jumping out if I was just a tad agressive over speedbumps, never mind went laning), and I was getting sick of the fuel bill the leaking filter was responsable for. The main jobs I need to do now are put the transmition tunnel back in(not quite simple, as I need to scrounge a hole saw to make it fit over the overdrive lever), fit the truckcab propperly, adjust the handbrake so its not right on the limit of travel, and clear at least some of the junk out of the back...

Friday, 24 July 2009

HMRC must love me...

Having finally found the time to go looking for some legislation, I've written HMRC another email asking how to pay duty on waste lub oil used as fuel. Hopefully this time they will come back with a price, rather than some bogus info to put me off.

Dear Mr Preston,

Thank you for your email dated 9th June 2009. I have done some further
research regarding the use of waste lubricant oil in a diesel engined
road vehicle, and I would value some further advice.

>Any oil used as motor fuel must, under EU and UK law, bear excise duty and the
>specific duty rate charged would depend on the exact type of fuel (and the type of
>motor it is intended for) These factors would also determine the type of HMRC >approval/registration required by you.

>However you do need to be aware that you might be in breach of environmental
>legislation if you collected and transported quantities of such waste oil from
>various sources, and also if you then applied any type of process to this waste oil.
Thank you for your advice on this point. Most of the issues regarding
this are resolved by the fact that I intend on using oil that I
personally remove from engines, processed on the same site, and
immediately transferred to the fuel tank of the road vehicle. I
understand that there are licensing requirements imposed by
legislation, but I will be in correspondence with the relevant
authorities with regard to this.

>The finished product then used in a motor vehicle would possibly fail to meet EU
>and UK specifications on the exact content of sulphur and toxic heavy metals or
>other substances in it. I would strongly advise you to research and deal with these
>issues first before embarking on this project. I say this because such waste oil is
>normally considered only fit for burning as furnace fuel due to the heavy metal
>contamination and it is normally not cost-effective to reprocess it into motor fuel of
>an acceptable standard, even with the sophisticated methods available in oil
> refineries and the consequent economies of high volume.
Having reviewed all the legislation I can find on this point, it is
irrelevant, as I am neither buying waste oil to use as a motor fuel,
nor selling any oil as a motor fuel. None of the legislation I have
found prohibits actual use, only the buying and selling of
"unsuitable" oils with intent to use as motor fuel. You may also be
interested to know that in the UK a high percentage of most cheep
lubricant oil is recycled used oil which has had the impurities
removed and then been re-blended. In the USA, where due to the absence
of fuel duty, rules are more straightforward, at least one firm
markets equipment aimed at vehicle workshops, which is intended to
filter and process waste oil into a road fuel for diesel lorries.

>Additionally, from an HMRC perspective the Hydrocarbon Oil (Marking) Regulations
>2002 prohibit the sale of ‘dark oil’ as fuel for a heavy oil vehicle and lubricating oil
>might well fall within the dark oil specification (at Section 2(1) of the Regulations)
Again, this point isn't relevant provided no financial transaction
takes place to obtain the oil. If the oil in question is drained from
machinery I own then by subsequent use of the oil afterwards as motor
fuel isn't an issue provided it is confined to my personal use in my
own vehicles.

>Therefore before I advise as to the appropriate mechanism for paying any duty due
>I believe that the above questions need to be resolved.
Having confirmed the answers to the above questions, I would now be
interested in knowing the appropriate rate of duty, and mechanism for
Yours sincerely
John Eastwood.

On 6/1/09, John Eastwood wrote:
> Dear Sir,
> I was asked to email you after phoning HMRC's advice line, as they
> were unable to answer my query.
> I am looking to run a road vehicle on processed waste lubricant oil.
> The oil will be processed mainly by various forms of filtration, and
> blended with normal "pump" diesel before being used in the vehicle.
> The vehicle's engine and fuel system would be suitably adapted for
> burning the blended fuel, chiefly by increased filtration, and the
> addition of a heat exchanger to warm the oil to decrease its viscosity
> prior to its supply to the engine. The vehicle would have twin fuel
> tanks, with a changeover system, as the engine would still need to be
> started on normal diesel.
> The fuel used does not meet HMRC's normal heavy oil specifications -
> if used in an un-adapted vehicle, it would lead to poor performance,
> and probable engine failure.
> The fuel does not meet HMRC's definition of an alternative fuel
> either, as the oil waste used is predominantly hydrocarbon.
> I anticipate the production and use of the oil to be on a fairly small
> scale - probably no more than HMRC's limit for unregistered vegetable
> oil processors of 2500L a year.
> I realise I am probably required to pay the duty on the waste oil
> which is used. What I have been unable to find, despite searching your
> website, is what I am required to do to register, in order to pay the
> duty. I would be grateful if you could let me know:
> 1) If I need to pay duty, and at what rate
> 2) How to register, and what records and information I need to keep
> I am aware that there may be other requirements imposed by
> environmental legislation, and that I will need to make various
> applications for the handling of waste materials, but those
> requirements I will be querying with the relevant other government
> bodies.
> Yours sincerely
> John Eastwood

Tuesday, 21 July 2009

I've done so many jobs the last week or so, I'm losing count.

I have:

Changed a set of rear springs, and reconditioned the set I fitted.
Painted the bonnet to match the rest of the truck. (Its way too shiney, but time will change that)
Unloaded the pile of junk that was in the back
Fixed the 4wd selection in the gearbox so it now isn't stuck in 4x4.
Fitted a servo brake MC
Adjusted all the brakes
Made the brake lights work again.
Fit a new cluch slave cylinder

I'm sure there are other things I've done, and the "todo" list is still miles long and growing.

Currently it includes:
Get a refund for the dud springs
Replace the Birtpart switch for the wipers that lasted all of a week
Change the steering relay
Drill a transmiton tunnel for my overdrive, and fit, and bolt the floor in propperly.
Paint the inside of the cab, and doors
Change the drivers doortop, as its shot.
Bolt the truckcab down propperly so it doesn't let in quite so much liquid sunshine.
Change the bottom bushes on the rear shocks. (I've a nasty feeling this will become fit new rear shocks, the've not been undone in a while, and its very hard to get them undone)
Fit a new flasher unit for the indicators
Fit a new fuel filter housing that doesn't have a diesel weep
Repair the bottom of the front panel.
Modify the clutch release so that its not right on the limit of the adjustment, and hence leaking clutch fluid. (Cable conversion? I'm sick of LR clutch hydralics, they always go wrong)
Replace the passenger side engine mount, and do them all up propperly.

Once I've done that little lot, I may actually be able to make a start on the work to get NOG re-tested.

Saturday, 18 July 2009


Just a quick update, cos I've not posted in ages...

I've rebuilt a set of std rear springs and fitted them, and she now ride about 5" higher at the back.

Next major mission is to change the steering relay, I'm not looking forward to that much.

Tuesday, 7 July 2009

I've been doing lots of stuff...

...but not much blogging. So here be a quick update.

Bitsa and I attended Leafers at t'pit show last weekend. The weather was good, the BBQ better, and I seemed to come back with both more junk than I took, and more cash as well (That last makes a change). I also got a free nail, which is currently causing one of the rear tyres to decend every couple of days. I'm tossing up if it has enough tread to be worth paying someone to put a new tube in it.

I've also bought a new front prop - I had started changing the UJ's in the old one, but it was rather mangled, as someone had previously changed the UJ's with a very big hammer, and deformed one of the yokes quite badly. I had given up, until I could think of a solution, but I found one in the autojumble for all of £5, which suited me nicely.

I didn't take any piccys at leafers, but there are loads on OLLR, if anyone is interested.

In other news, the spare wheel now lives on the bonnet, this is to do with taking the junk home after leafers, and so to stop the screen blowing up when running roofless, a tactical cable tie is proving handy. I really need a bungy strap, that lives inside the spare wheel, but I've not found one by the roadside for a few weeks, and I'm reluctant to actually pay for one. Also in other news, the bright red drivers door top is clearly about to meet its maker, and sways merrily in every passing breeze. I suppose this means I'm due for a trip into Landranger for a new one. While I'm there, I'll have to ask how they are doing with refunding the dud rear springs - which are now bending backwards... all has gone quiet on that front of late, and I could do with a decent set really. I've been given a worn out set which would do for the short term, but I still need some decent ones for the longer term...