UK companies and GPSR - stopping sales to the EU.

[Fighting15s]

Sally 4th is continuing to sell to EU & NI.

We've had a look at GPSR and I don't think it as difficult to comply as we first thought.

Most of us will have a maximum of four products that we manufacture (metal castings, resin castings, mdf products & books & printed materials.

No. It's each and every product you offer, identifiable by product code.

"Manufacturers shall ensure that their products bear a type, batch or serial number or other element enabling the identification of the product and which is easily visible and legible for consumers, or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product. "

[Chris Abbey]

I think metal castings come under the "or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product. "

That's my interpretation, but if you want to do a different risk assessment for a 'Grenadier Firing' and a 'Grenadier advancing' because they have a different product code, that's up to you.

GPRS also has to be balanced against environmental waste and excess packaging directives!

[Fighting15s]

I think metal castings come under the "or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product. "

That's my interpretation, but if you want to do a different risk assessment for a 'Grenadier Firing' and a 'Grenadier advancing' because they have a different product code, that's up to you.

GPRS also has to be balanced against environmental waste and excess packaging directives!

Actually, how I'd do it is have a product safety sheet for a range of product codes, referencing a materials safety sheet from the supplier. Some codes, however, will, be pointier and stabbier than others. :-) I already send out products with a label, safety warning about white metal, and hand written code. Paper invoices repeat the safety warning about white metal.

Metal formulations change. The Pewter 92 I now use is different from 20 years ago because the supplier changes the composition to improve its characteristics, mainly flow. Technically, if I cast from different batches, that needs to be advised. It's not really practical.

There's a lot that needs clarifying. The government's current information on GPSR and Northern Ireland, for example, implies that if a product is already available on the NI market then it is OK under the new regulation (and conversely new products are not). But as that also assumes that anyone supplying NI already has mechanisms in place to supply there, it isn't really looking at how small, boutique or craft businesses work.

[Daeothar]

Seeing as it appears issues aren't as severe as they were first interpreted to be, might I in the meantime suggest that for future threads on similar subjects, a little restraint is applied when drafting up the subject title?

Meaning that (in hindsight, I admit) it might be more appropriate to use a less definitive wording. For instance: 'suspending' instead of 'stopping', or maybe adding the word 'temporarily'. Because, to me at least, the current iteration is rather too clickbaity and alarmist, and has quite a few people all ruffled up about something altogether not as impactful as implied by the title...

[Andrew Rae]

Seeing as it appears issues aren't as severe as they were first interpreted to be, might I in the meantime suggest that for future threads on similar subjects, a little restraint is applied when drafting up the subject title?

Meaning that (in hindsight, I admit) it might be more appropriate to use a less definitive wording. For instance: 'suspending' instead of 'stopping', or maybe adding the word 'temporarily'. Because, to me at least, the current iteration is rather too clickbaity and alarmist, and has quite a few people all ruffled up about something altogether not as impactful as implied by the title...

It's still impactful. It's onerous for EU manufacturers and adds the requirement for an authorised rep for non-EU manufacturers on top. As well as the technical docs, you need to consider labelling, safety information and product instructions and how you package those with the products. Then there's updating your product listings online to include the manufacture's address and contact info, along with the rep's details if you're non-EU. Any safety information included with the product must also be in the product listing. Some manufacturer's will still just stop selling to the EU, even if most will only take a temporary pause. Thankfully, I'm all set, but it's been a fair bit of work at a very busy time.

[sp762au]

Hi there,

  as Chris has kindly pointed out above, I have now set up a company precisely to help small UK businesses in this space be compliant with the GPSR.  My email address is hfgservices29@gmail.com, and I think we're about to hit the magic ten signups - including a couple of people on this list.  (No names, no pack drill.)

I'm not going to engage in discussion here, sadly.  But I don't believe anything in the regulations is very tricky.

Thanks for reading

Mike Wilson

[boneio]

But I don't believe anything in the regulations is very tricky.

Agreed, and with the poster who referenced the fairly alarmist reactions - that's all I was trying to say while getting into debate over it!

Thanks Mike for offering a solution which should hopefully demonstrate that sensible compliance needn't be either expensive or risky.

I haven't kept up with the thread but I've seen a number of companies have also found friendly arrangements with an EU company to act as their appointed rep (for the correspondence which will never occur  )

[bluewillow]

Hi there,

  as Chris has kindly pointed out above, I have now set up a company precisely to help small UK businesses in this space be compliant with the GPSR.  My email address is hfgservices29@gmail.com, and I think we're about to hit the magic ten signups - including a couple of people on this list.  (No names, no pack drill.)

I'm not going to engage in discussion here, sadly.  But I don't believe anything in the regulations is very tricky.

Thanks for reading

Mike Wilson

Nice idea Mike

[Lovejoy]

We do now have some information on the penalties, supplied by the UK's Global Trade Department:

'Penalties can typically be fiscal and/or custodial
❑ Examples:
➢ Germany – up to €25,000
➢ Belgium – between €200 and €200,000
➢ Denmark – up to 10,000 KR
➢ Sweden – fine and/or up to 6 months custodial sentence
➢ Latvia – between €70 and €24,000
➢ Sweden – between SEK 5000 and SEK 5 million'


The big question will be what constitutes non-compliance, and the Global Trade Department are still a bit woolly on that, only saying that 'the situation is fluid', and each country is applying their own individual methods of interpreting the regs.

I'll be seeing how the next few months goes, and if we start getting a lot of delays or returns, I'll give serious consideration to dropping EU sales. But I'm hoping it'll either not be a big deal overall, or that at worst we'll only have to drop certain countries.

Interesting times!