What’s it oil about?

What with all those nasty chaps [PDF] doing whatever it is they do to diesel, thereby cheating the citizenry and polluting the countryside, it seems that the Revenue Commissioners, whom god bless and preserve, came up with a new scheme last year that might be made to look like a solution. (The real solution, of course, is to abolish green diesel, charge everyone full whack, and — if you really must, although personally I think they get too much subsidy as it is — give farmers back some money to shut them up … for a while.)

The new scheme is outlined here. As far as I can make out (but IANAL), anyone selling marked fuel oil (which I guess would include marinas selling it for private pleasure navigation, the category I’m interested in) has to pay €250 to get a Marked Fuel Trader’s Licence.

Actually, I may be simplifying it unduly: first they have to apply to be allowed to apply.

If this Application is approved the National Excise Licence Office will issue you with an Application Notice to apply for the Licence.

If the marina counts as a “forecourt retailer”, it also has to make a monthly electronic return of “oil movements”.

These requirements came into effect on 1 October 2012 and the Revenue website provides a 147-page PDF list of licence-holders as at 31 December 2012. I’ve had a quick look for a few Shannon marinas; I found none of them, although I confess I haven’t read the whole thing.

I haven’t been to any of the seminars (although I’ve looked at some of the PDFs available on that page) and I haven’t contacted the official sources of information (although I have emailed the Revenue press office). I have read the FAQ, though. There is no reference to boats or marinas or private pleasure navigation, so I assume that the scheme does apply to marinas. As far as I can see (again, IANAL), all traders in marked fuel must have licences, even if they sell only small quantities. However, for those selling under 2000 litres per customer per month, there is a simpler monthly return:

However, if you supply less than 2,000 litres per month per customer, you only need to notify Revenue of the number of customers you supplied during the month as well as the aggregate quantity of fuel supplied.

That would cover most marinas, I imagine, although the ROM1 procedure still has to be used.

The first return, in respect of oil movements during January 2013, must be submitted by 25 February 2013.

So does this apply to marinas? I’ve asked Revenue but I don’t expect to hear for a few days. If it does apply, what will the effect be? Is the increased cost (time to compile the application and meet any Revenue demands; €250; whatever the ROM1 system costs) likely to be significant? How are the marinas (and other waterways fuel retailers) responding?