Product destruction and credit process for draught beer and cider

When our pubs closed on 21st March 2020, we contacted you all to discuss what (draught) stock you currently had in your cellars and how major brewers had agreed to replace like for like once pubs were able to start trading again.

Since then the industry has been deliberating on the most appropriate process to complete this mammoth task. Due to the time and resources required, the uplifting of product by the distributor is simply not possible and so the most effective option available is to destroy the product on site, following the guidelines set by the HMRC and the Environmental Agency and detailed below.

We have already advised you that full credits will be provided for unopened (unbroached) containers. Since closure we have also been advised that in some cases duty may also be claimable on containers that have already been opened and are part full. However this cannot be guaranteed and is at the discretion of the brewer.

For credit on full containers to be claimed, the product must be out of date whereas if the product has been broached (opened) then the date is irrelevant.

ALL product must be destroyed through your dispense system and down a foul drain.

Please note the following procedure involves the use of Brulines. If you do not have Brulines installed on your premises then please discuss how the destruction of stock will be recorded with your BDM.

Preparing for the dispensing of product

1. The destruction of product on site will be measured through your dispense monitoring system (Brulines). If you have switched this off as part of the shutdown process then please ensure the system is switched back on a minimum of 24 hours before you start dispensing beer & cider for destruction.

2. Organise your cellar so the containers that are due to be destroyed (and that are out of date or opened) are clearly separated from those still in date. Cider, and some keg ale, are most likely to have significant date remaining and will be fine to serve on re-opening. Credit will not be provided for in date product, unless it has been broached, in which case the duty element may be claimed.

3. To ensure an accurate measurement of the product you are dispensing for destruction, and claiming credit, do not clean the lines or pour any product for a minimum of 24 hours before you start the dispense for the destruction process.

4. To ensure the product does not fob on dispense make sure the ‘Cellar Cooling’ is switched on a minimum of 48 hours prior to commencement of beer destruction. This will allow containers to come down to the correct temperature.

5. When the cellar is at the correct temperature switch the Air Compressor on (where you have one) and allow it to run and build pressure until it cuts off (circa 5 minutes). Turn gas bottles on then connect kegs and pull product through the line, at this stage just until beer starts to come through the dispense tap, and enough to fill the lines.

6. Switch on the ‘Remote Cooler’ and allow at least 6 hours for it to come down in temperature and form an ice bank. To avoid the possibility of product coils freezing do not switch ‘Remote Coolers’ on until lines are filled with beer.

7. When the ‘Remote Cooler’ has come down to temperature, product can be pulled through the lines to empty the containers.

8. Do not sit buckets on drip trays; the weight of full buckets will break the bracket. If required remove the drip trays.

9. If you encounter any Technical Service issues through this process, then please contact your BDM and or ‘Lead Brewer’.

Dispensing the product

1. Only dispense the product for destruction between the dates of Monday 1st June and Sunday 14th June 2020.

2. Dispense the product one brand at a time and it is critical the product is dispensed through the correct branded line.

3. Make sure that you dispense both the full and part (broached) containers for that brand, before moving onto the next.

4. Once you have completed the dispense of all the product you are destroying, and claiming credit for, then leave it a minimum of 48 hours before cleaning the lines ready to serve your fresh beer and cider.

5. Position your empty containers in the cellar clearly, and ready for collection as part of your initial couple of orders.

Destroying the product

Attached is a BBPA document entitled, ‘Protocol for Destruction of Beer in Cellars to Avoid Environmental Damage’. The process outlined in the document is designed to allow the destruction of product in a phased approach, reducing risk to the local sewerage infrastructure. If you do not comply with these guidelines, then you could risk receiving a significant financial penalty from the Environmental Agency. It is imperative you read the document thoroughly, but outlined below are the key points of guidance: –

• The process only applies where less than 3,000 litres (equivalent of 18x36g) is being destroyed. Trust Inns will contact you directly where we believe this is a risk based on the number of containers logged.
• Product can only be destroyed and emptied into a foul sewer (sink, toilet, or urinal), not a surface water sewer (outside drain).
• No more than one container (9g, 11g or 18g) should be disposed of in any period of 30 minutes.
• Water should be used to dilute the product during destruction and reduce foam formation.
• Disposal of product should only be undertaken between 7am and 12pm.

Logging and recording the destruction of product

Credits will be raised based on the volumes registered through the Brulines system only, but it is your responsibility to make an accurate record of the product that you have destroyed.

We have provided details below of what you need to record for each product that you destroy however for kegs of Guinness and/or Hop House 13 you must log all details on the Diageo website www.mydiageo.com Full details are available on the site which is available from 1st June 2020.

Please note that any time over the next 6 years either the HMRC, Environmental Agency or Supplier may request to view this information. Attached is a self-certification template that you should fill out for each individual container you destroy. If you decide not to use the self-certification template then your records must include the following information: –

• Name and address of pub
• Name and position of staff destroying beer
• Date of destruction
• Identification of product (name and beer style)
• ABV
• Batch number
• Total volume destroyed
• Containers type & size

However, you decide to log the destruction of each container, each logged destruction of a container must be accompanied by two pictures: –

Picture 1 – Label of destroyed container. Picture 2 – Product from destroyed container being dispensed into a measuring vessel/bucket.

It is anticipated that the HMRC and Suppliers will audit records to verify their accuracy. Please be aware that falsifying records is tantamount to fraud and may result in action being taken by HMRC and you will be liable to pay back any credits you have received in regards the destruction of beer and cider.

Products not covered through this process

• Products that you have purchased Free Of Tie and were not delivered through the Marston’s network. You should contact the supplier directly for guidance.
• Products purchased through the SIBA Beerflex scheme and not delivered through the Marston’s network; guidance will follow once SIBA have discussed with their member brewers.
• Details will follow with regards to draught BIB soft drinks, and the process and support for any product out of date.
• Packaged products do not qualify for any credit.

We understand that the above procedure may seem complex, but by following all the guidelines set you will ensure that you receive the maximum level of credit available to you, whilst also retaining appropriate records for the HMRC, Environment Agency or Supplier.

As always, if you have any queries then please contact your Business Development Manager for assistance

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