Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence.
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June 30, 2004
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Dear XXXXX,
This is in response to your letter XXXXX in which you requested approval to use non-duty-paid alcohol to manufacture homeopathic remedies in a XXXXX oz / XXXXX ml bottle in order to supply customer demand.
Section 143 of the Excise Act, 2001 allows the Minister to impose any conditions or restrictions that the Minister considers necessary in respect of the making, importation, packaging, use or sale of, or other dealing with, an approved formulation.
As you are aware, homeopathic products are highly potable. That is why all homeopathic products manufactured by licensed users under an approved formulation are approved with the condition that the container cannot be of a capacity greater than 60 ml in order to minimize the risk of diversion.
The Canada Revenue Agency's policy under the Excise Act, 2001 to impose the 60 ml condition on homeopathic products is a continuation of the same policy that was imposed under the Excise Act prior to July 1, 2003.
Since the coming into force of the Excise Act, 2001 in July 1, 2003, this condition, amongst others, has been under review. We regret to inform you that our position remains the same and your request will therefore not be permitted.
Even though the price of homeopathic products is currently considerably higher than beverage alcohol, it is conceivable that industry would continually push for the packaged size to be increased to a point where the cost argument would become irrelevant.
Should you wish to manufacture homeopathic products in containers of a capacity greater than 60 ml, you must use duty paid packaged spirits or pay duty on bulk alcohol as per section 126 of the Excise Act, 2001. The duty must be reported on your monthly return, Form B263, Excise Duty Return - Licensed user, in the appropriate box.
If you have questions or require additional information, please do not hesitate to contact me at (613) 954-4208 or Nathalie Robitaille at (613) 947-4138.
Ron Hagmann
A/Manager,
Excise Duty Operations - Alcohol
Excise duties and taxes Division
Excise and GST/HST Rulings Directorate
Policy and Planning Branch
Revenue Canada Agency
2004/06/29 — RITS 52760 — Cooking Wine
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