Gasoil
Nearly the same molecule. Three different laws.
Heating, industrial and off-road gas oil — where the sulphur limit, the duty treatment and the marking requirement all depend on what the fuel will be used for rather than on what it is, and where getting that wrong is a customs matter rather than a quality one.
The desk
Gasoil is defined by its use, not by its chemistry.
Automotive diesel, heating oil and off-road gas oil come off the same part of the barrel and can look nearly identical on a certificate. What separates them is legal: which sulphur limit applies, whether duty is paid at the full rate or a reduced one, and whether the fuel must carry a fiscal marker.
That makes this the one product on our book where the end use has to be established before the specification can be written. A parcel that is entirely correct for a heating customer is unlawful in a road tank, and the difference is not detectable by eye. It is detectable by the marker, which is exactly why the marker exists.
So a gasoil enquiry starts with a question that sounds bureaucratic and is not: what is this fuel going to be burned in, and in which country? Everything else — sulphur tier, marking, duty, documentation — follows from the answer, and none of it can be inferred from a tonnage.
Regulation
Three sulphur regimes, and which one catches you.
EU law splits gas oil across separate instruments according to use, and the definitions are drafted to exclude each other. Reading only one of them is how a compliant-looking cargo turns out to be the wrong product.
| Use | Sulphur limit | Instrument |
|---|---|---|
| Heating and general industrial gas oil | 0.10 % by mass maximum — that is 1,000 mg/kg | Directive (EU) 2016/802, Article 4. Its definition of gas oil expressly excludes marine fuels, diesel as defined in the fuel-quality directive, and fuels for non-road mobile machinery and agricultural tractors. |
| Non-road mobile machinery, agricultural and forestry tractors, inland waterway vessels | 10 mg/kg maximum | The fuel-quality regime, Directive 98/70/EC as amended. Same low limit as road diesel, despite being off-road and often marked and duty-reduced. |
| Automotive diesel | 10 mg/kg maximum | EN 590 and the fuel-quality directive. Full duty, no marker — see Diesel. |
| Marine | Separate regime entirely | MARPOL Annex VI and the ECA rules — see Marine Fuels. |
| Non-EU destinations | National standards, frequently 50, 500, 2,000 or 5,000 mg/kg | Quoted to the destination's own standard by name. We do not describe a higher-sulphur export grade as "EN 590 equivalent". |
Fiscal marking
The Euromarker changed. A lot of offers have not noticed.
Gas oil and kerosene that receive a duty exemption or reduced rate must carry a common EU fiscal marker so that enforcement can tell subsidised fuel from full-duty fuel. The marker in force is not the one most reference material still names.
| Item | Position |
|---|---|
| Current marker | ACCUTRACE™ PLUS, whose active component is butoxybenzene, CAS 1126-79-0. |
| Instrument | Commission Implementing Decision (EU) 2022/197, which repealed Implementing Decision (EU) 2017/74. |
| What it replaced | Solvent Yellow 124, the previous Euromarker. It was replaced because research found it insufficiently resistant to common illegal removal methods — that is, it could be laundered out. |
| Dates | Applicable from February 2022, with a 24-month transition during which either marker was acceptable. Since 18 January 2024 ACCUTRACE PLUS is the marker. |
| Marking level | Member states set a level of at least 12.5 mg/l and not more than 18.75 mg/l of the marker, corresponding to between 9.5 and 14.25 mg/l of butoxybenzene. |
| National colouring | Separate from the Euromarker. Member states additionally apply their own dyes — the familiar red or green — and those requirements are national, not harmonised. A cargo can carry the correct Euromarker and still be the wrong colour for the market. |
Supply
What we supply.
Heating gas oil
Domestic and commercial heating, to 0.10 % sulphur or tighter where a national specification requires it, marked and coloured to the destination's rules.
Industrial gas oil
Burners, kilns, dryers and static plant. Specified on calorific value, sulphur and cold flow according to the installation rather than to a road standard.
Off-road and NRMM gas oil
Construction and agricultural machinery, inland waterway vessels. 10 mg/kg sulphur, marked and duty-reduced where the destination allows.
Genset and power gas oil
Standby and prime-power generation, where cold flow and cleanliness matter more than anything on a road specification, and where storage may run for years.
Export tiers
50, 500, 2,000 and 5,000 mg/kg grades to the destination's own named standard, where its national rules permit them.
Parcels and basis
Clean-product tankers into a buyer's terminal, coastal parcels, and delivered where the trade supports it. FOB, CFR, CIF or delivered.
The parameters
What to hold when there is no EN 590 to point at.
Heating and industrial gas oil is not governed by one European specification the way automotive diesel is, which means the contract has to do more work. These are the parameters that actually matter to a burner or a static installation.
| Parameter | Why it matters here |
|---|---|
| Sulphur | The regulatory line, and for a burner also a flue-gas and corrosion question. Which tier applies follows the use, per the table above. |
| Density and calorific value | What a heating customer is actually buying. Energy per litre, not litres. |
| Cold flow — CFPP and cloud point | The parameter that causes winter failures in outdoor and unheated tankage. Domestic heating tanks sit outside; specify for the site's ambient, not the market's average. |
| Viscosity | Burner nozzle atomisation. A burner tuned for one viscosity does not run cleanly on another. |
| Flash point | Storage safety and insurance compliance, and a marker of light-end contamination. |
| Water, sediment and total contamination | Filter blocking, tank-bottom corrosion and microbial growth. Worse in slow-turning tankage, which describes most heating and standby storage. |
| Oxidation stability | The parameter nobody specifies and everyone needs. Standby generator fuel may sit for years; heating oil sits over a summer. Long-storage service deserves a stability limit and, where warranted, a FAME-free product. |
| FAME content | Often zero or capped for heating and standby duty, precisely because of the storage and microbial behaviour set out on the diesel page. If you need B0, say so. |
| Colour and marker | A compliance parameter, tested and certified rather than assumed. Both the Euromarker and the national dye. |
Risk
The duty differential is the fraud, and we treat it that way.
Duty-reduced gas oil is worth materially less than road diesel, and the two are chemically near-identical. That gap is a standing invitation, and fuel laundering — removing the marker and selling rebated fuel as road fuel — is one of the more organised frauds in this industry.
It is also the reason the Euromarker changed: Solvent Yellow 124 was replaced specifically because it proved insufficiently resistant to illegal removal. The replacement is harder to launder, and the fact that the EU went to the trouble of changing it says how much of this is going on.
For a legitimate buyer this matters in two directions. Downstream, a marked cargo has to stay in its lawful use or the liability travels. Upstream, a gas oil parcel offered at a price that only makes sense if the duty position is not what it appears to be is not a bargain.
What we do. We establish the end use and the duty position before quoting; we certify the marker and the colour rather than asserting them; and we decline business where the intended use and the duty treatment do not line up. We will also say plainly when an offer we have seen elsewhere does not add up, because on this product an unexplained discount usually has an explanation.
Counterparty and origin screening runs per consignment as it does across the book — see Compliance.
Scope
Where our obligation ends.
- What we supply
- Gas oil as cargo parcels and coastal lots into terminals and shore tankage, with independent inspection and full documentation.
- What we do not do
- We are not a distributor. We do not deliver into domestic tanks, farms or construction sites, and we do not operate a marking or dyeing terminal.
- Marking and colouring
- Performed at the loading terminal or refinery to the destination's requirement, and certified. Where a buyer wants unmarked full-duty product, that is a different order and we will not treat the two as interchangeable.
- End use and duty
- The buyer's, and declared. We will not supply rebated or marked product for a use it is not entitled to, and we will ask the question directly rather than leaving it implied.
How to specify
Six lines, and the first one is not optional.
On gasoil the end use is the specification. Everything else is downstream of it.
End use and country
Heating, industrial burner, off-road machinery, inland waterway, standby generation — and where. This sets the sulphur tier, the marking and the duty.
Sulphur tier
0.10 % or 10 mg/kg for EU uses, or the destination's national tier by name for export.
Marking and colour
Whether the fuel must carry the Euromarker, and which national dye. Both certified, not assumed.
Cold flow for the site
CFPP and, for outdoor or unheated tankage, cloud point. Specify for the coldest place it will sit, not the market average.
Storage turn and FAME
How long it will sit, and whether you need B0. Long-storage service should carry an oxidation stability limit.
Quantity, basis and terminal
Tonnes or cubic metres, FOB / CFR / CIF / delivered, receiving tankage and berth restrictions.
Quality
Including the two parameters that are legal rather than technical.
Independent inspection by an agency appointed for the cargo — SGS, Bureau Veritas or Intertek — instructed jointly, sampling under supervision, sealed retains at both ends, determination points named in the contract.
On gasoil the certificate carries two items that are not quality parameters in the ordinary sense: the fiscal marker and the national colour. Both are tested and reported, because both are the difference between a lawful cargo and a customs problem, and neither is something to take on trust.
- Core test set
- Density at 15 °C; sulphur; distillation; viscosity at 40 °C; flash point; CFPP and cloud point; water and sediment; total contamination; ash; carbon residue; copper corrosion; colour and appearance; calorific value where the buyer prices on energy.
- Compliance items
- Euromarker presence and concentration, and the national dye. Certified per parcel.
- Long-storage service
- Oxidation stability and FAME content, plus acid number where the parcel will sit for an extended period.
- Documentation per parcel
- Certificate of Quality, Certificate of Quantity, Certificate of Origin, marking certificate, safety data sheet in the destination language, bill of lading, three-cargo tank history, the independent inspection report, and the duty and end-use documentation the destination requires.
Straight answer
What we will tell you before you ask.
- That off-road does not mean high-sulphur
- EU non-road machinery gas oil is 10 mg/kg, the same as road diesel, even though it is marked and rebated. The 0.10 % regime is for heating and industrial burning. This is the most common misunderstanding on this product.
- That the marker is ACCUTRACE PLUS, not Solvent Yellow 124
- Since January 2024. If you are being offered the old marker, the offer is out of date in a place where being out of date is a customs exposure.
- That we will ask what the fuel is for
- Not as a formality. Duty-reduced product supplied into a use it is not entitled to is a liability that travels with the cargo, and we would rather ask an awkward question than inherit it.
- That an unexplained discount usually has an explanation
- The duty differential on this product is large enough to fund a great deal of creativity. If a level only works on an assumption about duty, we will say so.
- That storage life belongs in the contract
- Heating oil sits over a summer and standby fuel can sit for years. Oxidation stability and FAME content are the parameters for that, and nobody specifies them until the filters block.
- Where an origin cannot be cleared
- Screened per consignment; declined where it cannot be documented, and not referred onward — see Compliance.
Enquiries
Every enquiry is answered by the desk that handles it.
Send the product, quantity, delivery basis, destination and timing. We revert with availability, an indication and the documentation that accompanies it. Specifications are released once we know who we are speaking with.