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Under subsection 4.16(1) of the FTA, any person who contravenes subsections 4.13(1) or 4.13(2) is guilty of an offence. ... Subsection 4.19(3) of the FTA provides that every registered dyer that contravenes a condition or limitation on its certificate of registration is guilty of an offence and on conviction is liable to a fine. 30. ... " It also states that registered dyers are required under the FTA to colour fuel using only the dye provided by the Minister and to store, label and handle dye and coloured fuel in accordance with the Minister's requirements and it is an offence under the FTA to contravene these requirements. ...

The fact that the rewards voucher is not supply-specific makes it possible that the voucher may be used against the price of zero-rated supplies, which would directly contravene the requirements of the aforementioned provisions. ...