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About BAMA

The British Aerosol Manufacturers' Association (BAMA) represents the aerosol supply chain, from suppliers of components and ingredients, to fillers and brand owners. The association offers a range of business support and advice services to members and represents the views of the industry to legislators and regulators.

UKCA / CE marking

Following our recent event on Product Labelling: UKCA/CE Marking, we wanted to provide you the following update.

The UK Government has announced that new import controls for goods coming into Great Britain due to commence on 1 January will, temporarily, exclude movements from the island of Ireland. Controls will be introduced for goods coming from all other EU countries and there is no change to the timetable for the introduction of full import customs obligations and the pre-lodgement in the Goods Vehicle Movement Service. The easement for the island of Ireland is provided while the UK and EU continue to discuss the implementation of the Northern Ireland protocol. The UK Government will continue to keep these temporary arrangements under review and will continue to work with the Devolved Administrations and interested stakeholders. The Border Operating Model will be updated to reflect this and full guidance will be provided on shortly.

The full government announcement can be found on the UK Parliament website ( Written statements )

UK Net Zero Strategy – zero emission by 2050

Net Zero Strategy sets out how the UK will deliver on its commitment to reach net zero emissions by 2050
outlines measures to transition to a green and sustainable future, helping businesses and consumers to move to clean power, supporting hundreds of thousands of well-paid jobs and leveraging up to £90 billion of private investment by 2030
reducing Britain’s reliance on imported fossil fuels will protect consumers from global price spikes by boosting clean energy
it comes as the UK prepares to host the UN COP26 summit next week, where the Prime Minister will call on other world economies to set out their own domestic plans for cutting emissions
A landmark Net Zero Strategy setting out how the UK will secure 440,000 well-paid jobs and unlock £90 billion in investment in 2030 on its path to ending its contribution to climate change by 2050 has been unveiled by the UK government today (19 October).

Building on the Prime Minister’s 10 Point Plan, today’s UK Net Zero Strategy sets out a comprehensive economy-wide plan for how British businesses and consumers will be supported in making the transition to clean energy and green technology – lowering the Britain’s reliance on fossil fuels by investing in sustainable clean energy in the UK, reducing the risk of high and volatile prices in the future, and strengthening our energy security.

The commitments made will unlock up to £90 billion of private investment by 2030, and support 440,000 well-paid jobs in green industries in 2030. This will provide certainty to businesses to support the UK in gaining a competitive edge in the latest low carbon technologies – from heat pumps to electric vehicles – and in developing thriving green industries in our industrial heartlands – from carbon capture to hydrogen, backed by new funding.

As part of the strategy, new investment announced today includes:

an extra £350 million of our up to £1 billion commitment to support the electrification of UK vehicles and their supply chains and another £620 million for targeted electric vehicle grants and infrastructure, particularly local on-street residential charge points, with plans to put thousands more zero emission cars and vans onto UK roads through a zero emission vehicle mandate
we are also working to kick-start the commercialisation of sustainable aviation fuel (SAF) made from sustainable materials such as everyday household waste, flue gases from industry, carbon captured from the atmosphere and excess electricity, which produce over 70% fewer carbon emissions than traditional jet fuel on a lifecycle basis. Our ambition is to enable the delivery of 10% SAF by 2030 and we will be supporting UK industry with £180 million in funding to support the development of UK SAF plants
£140 million Industrial and Hydrogen Revenue Support scheme to accelerate industrial carbon capture and hydrogen, bridging the gap between industrial energy costs from gas and hydrogen and helping green hydrogen projects get off the ground. Two carbon capture clusters – Hynet Cluster in North West England and North Wales and the East Coast Cluster in Teesside and the Humber – will put our industrial heartlands at the forefront of this technology in the 2020s and revitalise industries in the North Sea – backed by the government’s £1 billion in support
an extra £500 million towards innovation projects to develop the green technologies of the future, bringing the total funding for net zero research and innovation to at least £1.5 billion. This will support the most pioneering ideas and technologies to decarbonise our homes, industries, land and power
£3.9 billion of new funding for decarbonising heat and buildings, including the new £450 million 3-year Boiler Upgrade Scheme, so homes and buildings are warmer, cheaper to heat and cleaner to run
£124 million boost to our Nature for Climate Fund helping us towards meeting our commitments to restore approximately 280,000 hectares of peat in England by 2050 and treble woodland creation in England to meet our commitments to create at least 30,000 hectares of woodland per year across the UK by the end of this parliament
£120 million towards the development of nuclear projects through the Future Nuclear Enabling Fund. There remain a number of optimal sites, including the Wylfa site in Anglesey. Funding like this could support our path to decarbonising the UK’s electricity system fifteen years earlier from 2050 to 2035
The policies and spending brought forward in the Net Zero Strategy mean that since the Ten Point Plan, we have mobilised £26 billion of government capital investment for the green industrial revolution. More than £5.8 billion of foreign investment in green projects has also been secured since the launch of the Ten Point Plan, along with at least 56,000 jobs in the UK’s clean industries – and another 18 deals have been set out at the Global Investment Summit to support growth in vital sectors such as wind and hydrogen energy, sustainable homes and carbon capture and storage.

Through energy efficiency measures, falling costs of renewables and more, the measures in the strategy also mean people’s energy bills will be lower by 2024 than if no action was taken particularly as gas prices rise.

As the first major economy to commit in law to net zero by 2050 and hosts of the historic UN COP26 climate summit, the UK is leading international efforts and setting the bar for countries around the world to follow. The UK has hit every carbon budget to date – today’s Net Zero Strategy sets out clear policies and proposals for meeting our fourth and fifth carbon budgets, and keeps us on track for carbon budget 6, our ambitious Nationally Determined Contribution (NDC), while setting out a vision for a decarbonised economy in 2050.

SAFE HANDLING of Aerosol PROPELLANTS training – 15th July 2021

This course aims to provide delegates with knowledge of the issues surrounding handling of flammable propellants and provide practical examples of how this applies to an aerosol filling line (from the point at which the propellant enters the factory from the tank farm). It then focuses on the safe operation and maintenance of the propellant storage and delivery pipes, and the aerosol filling lines (it does not cover the design, construction and modification of the plant).

The Course Content:

Properties of common flammable aerosol propellants
Common causes of fire, and how to eliminate them in an aerosol factory
Classification of hazardous zones in an aerosol factory, the propellant tank farm and propellant delivery, storage and transfer
The gassing room and gas detection and safety
Propellant change-over
Machine settings, danger of leaking cans and static electricity, and hot water bath testing
Preventative measures – “Prevention is Better than Cure” – how your behaviour can affect your safety
The course will conclude with a test of your knowledge.

Who should attend?

The course is designed for operations and maintenance staff from aerosol filling plants, their line managers, or anyone who needs to have a practical knowledge of the safe handling of aerosol propellants in the plant.

To reserve your place, email

Changes from April 2021: the burden of tax liability moves from the contractor to the end clients and the recruitment agencies.

From 6 April 2021 the rules for engaging individuals through personal service companies or other intermediaries are changing.
The responsibility for determining if the ‘off-payroll working rules’ (IR35) apply will be with the organisation receiving an individual’s services.

Ensure you understand:

– the impact of the changes on your organisation
– the actions you might need to take before the changes come into effect

The workplace should have been a level playing field, where you couldn’t have two individuals working side-by-side doing the same job, with one being taxed as an employee and one being treated as an independent contractor. This hasn’t always happened.

HMRC had estimated that only 10 percent of the contractor population was treating engagements as “inside IR35” and if that wasn’t properly addressed this would cost the Treasury up to £1.3bn per year by 2023-24. Their target is to increase the 10 percent to a third of all engagements being deemed inside IR35.

HMRC believed that the changes would affect approximately 60,000 medium and large-sized end-client engagers and potentially 20,000 agencies.
In terms of contractors, the changes were being presented as 170,000 contractors having less of an administrative burden – possibly because a lot of them would be closing down their PSCs (Personal Service Company).

(Payroll, HR and recruiting managers will need to understand the changes)

Steps you need to take:

1. Look at your current workforce.
This includes those engaged through employment agencies.

Identify individuals who are supplying their services through their own limited company (sometimes known as a personal service company), or other intermediaries.

Put in place processes to identify future individuals who work in this way.

2. Talk to individuals and agencies you engage with.
You may need information from them on some engagements.

Share the contractor factsheet to help your contractors understand how the changes may affect them.

3. Determine if the off-payroll working arrangements apply.
Check if the rules apply for any contracts that will extend beyond, or start after 6 April 2021.

Decide who in your organisation should be responsible for the determination of employment.

You can use HMRC’s Check Employment Status for Tax (CEST) service to find out if a worker should be considered employed or self-employed for tax purposes:

Look at escalations for difficult cases.

Make a determination ahead of April 2021 – as long as the information remains correct.

4. After you’ve determined if the rules apply.
You’ll need to tell the contractor (and any agency you engage with) the outcome.

Use a Status Determination Statement (SDS) to tell them.

5. Who will operate PAYE.
Consider if your organisation or an agency will have to operate PAYE.

If you’ll need to operate PAYE, put in place processes to make sure the correct Income Tax and National Insurance contributions (NICs) are deducted for engagements inside the rules from 6 April 2021.

6. Dealing with disagreements.
You’ll need to set up a process to deal with any disagreements about the employment status determination. This is a legal requirement.

7. Keep records.
You’ll need to make sure you maintain a robust audit trail. It is a legal requirement to keep records.

8. Test your processes.
You’ll need to test your processes, systems and controls to make sure you’re ready.

9. Changing working practices and contracts.
You should follow the processes you’ve set up to revisit status decisions and make new ones if you:

– change working practices
– change contractual arrangements
– renew contracts
– create new contracts

You can find more information about the April 2021 changes for off-payroll working and who it affects, here:

£40 million government funding to help businesses clean up

Some of the UK’s high-carbon-emission industries will benefit from £40 million funding to help them cut their carbon emissions (Published 7 February 2021)

• £40 million government investment to help polluting industries including steel, pharmaceuticals and food & drink to find new ways to reduce their carbon emissions
• solutions including using heat recovery technology to generate electricity and replacing gas with hydrogen fuel will help businesses cut energy costs, protect jobs, and improve air quality across the UK
• funding supports the government’s mission to build back greener and eliminate the UK’s contribution to carbon emissions by 2050

Some of the UK’s industries will benefit from £40 million funding to help them cut their carbon emissions, while reducing their energy bills, the government announced today (Sunday 7 February).
Businesses in energy-intensive sectors, including pharmaceuticals, steel, paper, and food and drink, will be able to apply for grants worth up to £14 million through the government’s Industrial Energy Transformation Fund – totaling £289 million in funding up until 2024.

In this second competition window, the minimum grant has been lowered to £100,000 for deployment projects, offering more flexibility for small businesses to receive funding so they can speed up getting their ideas to market.
With potential projects taking place across the East and West Midlands, North East, North West, and Yorkshire and the Humber as well as Wales and Northern Ireland, the government grants will enable businesses to use new technology to improve the efficiency of industrial processes and reduce energy demand.
They will drive them towards a cleaner, more sustainable future as part of our green industrial revolution by 2030 and mission to eliminate our contribution to climate change by 2050.
This includes factories installing electric motors and heat pumps to replace their natural gas-fired boilers and steam turbines, manufacturers using heat recovery technology to recycle waste heat and generate renewable electricity, and industries such as the food and drink sector carrying out studies to replace natural gas with hydrogen as their primary fuel.
Doing so will create and support thousands of British jobs, cut carbon emissions and lead to cleaner air for the people of the UK.
Energy Minister Anne-Marie Trevelyan said
We can only achieve our ambitious plans to tackle climate change if everyone plays their part, including businesses large and small.
That’s why our £40 million investment will not only help some of the highest polluting industries like steel, paper and pharmaceuticals build back greener by finding innovative ways to reduce their carbon emissions but will also create more opportunities for growth and jobs by leveling up and making industry fit for the future.
The fund supports the UK government’s mission to build back greener and level up the country’s industrial heartlands by allowing them to lay the path for economic growth.

The government’s Industrial Energy Transformation Fund is worth £289 million with funding available across England, Wales and Northern Ireland up until 2024. The fund supports heavy industry as the UK transitions to a low-carbon economy.
Today’s announcement follows an initial launch in June 2020 which saw 39 applications approved for funding in the first window, totaling £31 million.
It is calculated that as a result of these projects carbon emissions will be reduced by 2.6 million tonnes over their lifespan, which is equivalent to taking 38,000 fossil-fuelled cars off the road over a 30 year period.

The Industrial Energy Transformation Fund (IETF) window opens for applications on Monday 8 March and closes on Wednesday 14 July:

• find out more about applying for funding for the IETF Phase 1: Spring 2021

• the Scottish Government is administering £34 million (£26 million from the IETF) for investment in Scotland and launched the Scottish IETF in December 2020

Buying goods from EU means extra costs, for consumers and businesses alike

The Trade and Cooperation Agreement between the UK and EU might have scrapped the tariffs on goods moving across the two parties (subject to RoO), but VAT and Import taxes are still in place.

As the BBC reports (21 Jan 2021):
Under the new rules, anyone in the UK receiving a gift from the EU worth more than £39 may now face a bill for import VAT – with many items charged at 20%.

For goods costing more than £135, customs duties may also apply, which can range from 0% to 25% of the product you’re buying if they have not been paid by the sender already.

The extra charges are usually collected by the courier on behalf of the government, with customers asked to pay before they can pick up their package.

Some specialist European retailers, such as bicycle part firm Dutch Bike Bits and Belgium-based Beer On Web, recently said that they would stop all deliveries to the UK because of the VAT changes, which came into force on 1 January.

Some firms have started charging additional “handling fees” to shoppers to cover costs associated with extra customs checks and paperwork that must be filled out.

Royal Mail, for example, is charging an £8 fee it says “reflects the cost of clearing items through customs and presenting them to Border Force”.

Meanwhile, delivery firm DHL says it is charging UK customers 2.5% of the amount paid to clear customs, with a minimum charge of £11.

Mail and freight company TNT is also adding £4.31 on all shipments from the UK to the EU and vice versa. It has said this reflects the increased investment it has had to make in adjusting its systems to cope with Brexit.

A spokeswoman for Logistics UK told the BBC that the handling fees were “a commercial decision by individual businesses”.

But Michelle Dale, senior manager at accountants UHY Hacker Young, said that new charges could present a major problem for firms in the coming weeks.

“I think what we’ll find is that a lot of trade with the EU from a business-to-customer perspective will come to a stop until some of these rules are eased,” she said.

A government spokesperson said: “The new VAT model ensures goods from EU and non-EU countries are treated in the same way and that UK businesses are not disadvantaged by competition from VAT-free imports.

“The new system also addresses the problem of overseas sellers failing to pay the right amount of VAT when they sell goods in the UK. We anticipate this will bring in £300m in tax every year, to fund essential UK public services.”

VAT and Import Duties are due imports from outside the UK into GB, and from outside the EU into Northern Ireland.

You can find all the VAT relevant information on this webpage:

Are there any EXEMPTIONS or any way in which the cost can be reduced?
The answer is yes, through Duty Relief Schemes.
There are a variety of such schemes that you might benefit from, depending on a number of criteria: the country of origin of the goods, the typology of goods and the reason for which the goods are being imported.

The main duty relief scheme is the GSP scheme. “The GSP (Generalised System of Preferences) scheme is an EU directive that allows for products being purchased from suppliers in certain countries to be lower-rated or even free from duty. This scheme is in place to allow businesses in developing countries to trade on a wider scale internationally.”

GSP Duty Relief schemes are also known as “trade preferences”; this means you’re allowed to claim duty relief because there is a Free Trade Agreement with the origin country.

To find out if you can benefit from one, the easiest way is to check your product’s commodity code in the UK trade tariff. Under each product’s details, you should be able to see whether it’s eligible for any duty relief schemes and the terms of each scheme.

In addition to duty relief schemes listed under the trade tariff, there are also schemes based on what you’re using the goods for and on how long they’ll remain in the UK.

Below are some of the main of the duty relief schemes available:

Temporary admission; when you bring goods into the UK for designated, short-term use. (For example, an exhibition.) Inward processing; when you’re importing goods from outside of the EU to process then export (either to outside the EU or within the EU) you can claim duty relief. Outward processing; this allows you to export your goods to another (non-EU) country for repair or processing and then bring them back into the UK with full or partial duty relief.

Customs warehousing; customs warehouses allow you to store goods duty and VAT free until they leave the warehouse.

Community system of duty relief; if you’re importing products “for educational, scientific or cultural purposes; to encourage trade (for example, goods for test and commercial samples); for other purposes, for example: awards and decorations, when inherited, received as private gifts” (source: HMRC) you can claim duty and VAT back.

Duty suspensions and tariff quotas for raw materials, parts and unfinished products; if you’re importing goods to finish or use as materials in the UK (goods/materials that are unable to be bought or bought in sufficient quantities from within the EU) you can claim duty relief. The criteria that determine the eligibility for these duty relief schemes and the level of savings associated with them are:

– the type of goods
– the country the goods are being exported to
– the country the goods come from (as set by the ‘rules of origin’!)

To claim a trade preference you need to:br – insert the correct commodity code for your goods
– ensure your goods comply with the rules of origin
– be able to provide evidence of where your goods came from
– ensure you comply with transport rules

It is worth doing a bit of research to verify whether your goods are eligible for a Duty Relief scheme, and applying for it, as the financial savings for your business would be considerable.

Changes to labelling and marking of aerosol dispensers in GB

Changes to labelling and marking for aerosol products (GB)

OPSS has made the preparations necessary for the effective functioning of the product safety and metrology system at the end of the Transition Period.
To help ensure business understand what is expected of them, including on issues such as the use of the UKCA marking, OPSS have produced a range of guidance and advice, all of which is available at:

This now includes a ‘What’s Changed?’ summary guide to key changes regarding the specific product safety and metrology legislation amended by The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019.

This guidance provides a clear indication of what rules and regulations you will be required to comply with now that the Transition Period has come to an end.
To be notified when new material is published on the OPSS pages of GOV.UK, you can sign up for OPSS email alerts via the following link: – half way down, under ‘Latest from OPSS’, there is a ‘get email alerts’ button to click on.

As ever, if you have any queries or if there is anything you wish to raise, please do get in touch with the BAMA staff or directly with the OPSS.

Trade event: Indian supplies of Specialty Chemicals

India Virtual Chemicals Event – UK Participants Needed

Dear BAMA Member

The Department for International Trade, together with the Federation of Indian Chambers of Commerce, is organising a Virtual Trade Event and is looking for British Chemical Companies to participate, both chemical manufacturers and end users. If this is of interest to you please let me know or contact directly.

They are looking for users of a wide variety of different chemicals to take part, many of which I know our industry uses extensively. A draft programme is available, please don’t hesitate to contact us if you would like a copy.

Extract: Michael Gove’s staged implementation of border controls

From Michael Gove’s Statement to the House, on EU Exit preparations

The new technology that we’re introducing will allow us to monitor with far greater precision exactly who, and what, is coming in and out of our country.

The Border Operating Model that we published today (13 July) provides clarity about the end-to-end journeys of goods on the move between Great Britain and the EU, including information about controlled goods and the new government systems that will support future trade.

It is important to note that the Border Operating Model does not cover matters relating specifically to the Northern Ireland Protocol.

In the light of coronavirus, and in order to give business and industry more time to adjust – we announced last month that border controls would be introduced in THREE STAGES up to 1 July 2021.

– In the FIRST PHASE, from January 2021, traders importing standard goods will need to prepare for basic customs requirements. Full Customs Declarations will be needed for controlled and excise goods such as alcohol and tobacco products. But people importing standard goods will have up to six months to make their declaration and to pay tariffs. Traders moving goods using the Common Transit Convention will need to follow all of the transit procedures.

– In the SECOND PHASE, from April 2021, we’ll require all products of animal origin, regulated plants and plant products to have pre-notification and the relevant health documentation. Any physical checks will continue to be conducted at the point of destination.

– And in the THIRD and final PHASE, from July 2021, traders moving all goods will have to make full customs declarations at the point of importation and of course pay relevant tariffs. Checks for animals, plants and their products will take place at Border Control Posts in Great Britain.

UK trade tariffs from January 2021

The UK Government announced the UK’s new MFN tariff regime, the UK Global Tariff (UKGT). This will replace the EU’s Common External Tariff on 1 January 2021 at the end of the Transition Period.

The new tariff is tailored to the needs of the UK economy. It will support the economy by making it easier and cheaper for businesses to import goods from overseas. It is a simpler, easier to use and lower tariff regime than the EU’s Common External Tariff (EU CET) and will be in pounds (£), not euros.

The Government is taking a common-sense approach to the new tariff schedule by streamlining and simplifying nearly 6,000 tariff lines, and lowering costs for businesses by reducing administrative burdens. The changes include scrapping unnecessary tariff variations, rounding tariffs down to standardised percentages, and getting rid of all “nuisance tariffs” (those below 2%).

The UKGT also expands tariff free trade by eliminating tariffs on a wide range of products. The UKGT ensures that 60% of trade will come into the UK tariff free on WTO terms or through existing preferential access from January 2021, and successful Free Trade Area negotiations will increase this.

This will lower costs for businesses, ensuring they can compete on fair terms with the rest of the world, as well as keeping prices down and increasing choice for consumers.
The Government is maintaining tariffs on a number of products backing UK industries such as agriculture, automotive and fishing. This will help to support businesses in every region and nation of the UK to thrive. Some tariffs are also being maintained to support imports from the world’s poorest countries that benefit from preferential access to the UK market.

The UKGT was designed following widespread engagement with businesses across the UK. As it will come into force on 1 January 2021, it’s important that businesses can familiarise themselves with the new tariff regime ahead of this date.

Please, access to check:

– what the tariffs apply to
– how to check the relevant tariff
– what goods are covered by tariff-rate quota