Category Archives: Brexit

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:
https://www.gov.uk/guidance/uk-product-safety-and-metrology-from-1-january-2021.

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: https://www.gov.uk/government/organisations/office-for-product-safety-and-standards – 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.

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 https://www.gov.uk/guidance/uk-tariffs-from-1-january-2021 to check:

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

!!! Regulation Update!!!

Luckily or not we are still within the EU, and the checks of goods crossing our national borders haven’t yet tighten as most people expected them to. Depending on what the situation will be in November, things might well change and give us few more loops to jump through.
While the political elite gets through its umpteenth scuffle, business has to continue, trade must go on, and we all have to comply with the requirements of an ever changing regulation.
That, at least, is something BAMA can help you with.
On the subject of transport (by road, sea, train or air), we already know that aerosols are classed as ‘dangerous goods’and the transport regulations require that any shipment, including samples, must be properly declared and adequately packaged by staff that are ‘appropriately trained’ to the current legal requirements.
Said requirements have recently changed, to a limited extent but enough for BAMA to have to amend its 2017 Guide to the Transport of Aerosols, to make sure it still delivers you the most up-do-date requirements.
The 13th edition of the BAMA Guide to Transport is 100 pages (and you thought it was a marginal topic) of knowledge, distilled in an easy to follow format, with graphs and tables to facilitate understanding and to simplify reference searches at any stage.
It explains how to consign aerosols for transport, according to the mode you have chosen (rail, road, sea or air). It covers the classification, packaging, testing, marking and labelling requirements in each case and it explains what documentation is required.
The Guide includes the UN model regulations; it also tells you what sort of training is considered ‘appropriate’.
It is free to download for BAMA members, so you really have no excuses I’m afraid (we can liven things up with face-to-face training, though – just ask).

BAMA, ADF and European post-Brexit prospects

As we all know, and we are probably sick of hearing, on 29th March 2019 it is planned that the UK will leave the European Union, but three years on from the referendum it is still not known what settlement will be agreed between the EU and the UK.
Chief executive of BAMA, Patrick Heskins, talked about this decidedly hazy landscape in his presentation at the ADF/PCD Paris exhibition.
The ADF/PCD Paris exhibition is Europe’s premier expert innovation event for aerosol and cosmetic packaging. On 30th and 31st January, leading suppliers from a variety of sectors gathered to present their innovations to the industry, and the event was extremely well attended.
In his presentation entitled: ‘Brexit – where are we?’, Patrick explained what the new trading arrangements might look like, what Brexit could mean for EU countries exporting to the UK, and what the regulations could be when trading across this ‘new’ European border.
He also discussed the options still open to the British government and worst-case scenarios in terms of trade tariffs and regulations.
This insecurity surrounding Brexit has also prompted BAMA to reassess the way it addresses international trade shows such as FLADA in Brasil, ADF New York and the Ningbo exhibition in China.
Patrick delivered his presentation on the second day of the conference, ensuring BAMA maintained its visibility with the audience, as well as securing coverage on the show’s website in advance of the event.
In addition, a BAMA/CFA joint workshop was organised to take place in Paris following the close of the ADF event in order to capitalise on the number of industry representatives already in the area.
While the outcome of the ongoing Brexit negotiation is still uncertain, BAMA remains committed to representing the interests of its members both at home and abroad and will maintain a cautious approach to investments at least until the post-Brexit situation becomes clearer.