ERODG6100 | Administering the reimbursement scheme: can repayment be set-off against debts on file
From HM Revenue & Customs · Excise Repayment of Overpaid Duty
A repayment paid to a revenue trader’s duty account for the purposes of the scheme cannot be used to offset any debt on file.
This is because the money repaid is the consumers and not the revenue trader’s.