EU GSPR and its impact on the (non-EU) hobby industry

[Citizen Sade]

It certainly fits the OOP lead and pewter than I sell from time to time. I’ll continue selling and offer an article 3 defence in the very unlikely event that I catch any flak.

Thanks, Fighting15s!

[carlos marighela]

Hmm. Have fun explaining that. I suspect that they are more likely to be viewed as toys.

By the by, the EU is on the cusp of introducing additional, stringent regulation, specifically on toys so it seems. The crack down is on harmful or toxic materials, so maybe dial down the argument about them being a lead-pewter mix. 

https://www.consilium.europa.eu/en/press/press-releases/2024/05/15/toy-safety-council-adopts-position-on-updated-rules/

Digital passport for your goods anyone?

[Andrew Rae]

There's additional text about antiques in the preamble, along with reference to another regulation:

Antiques, such as works of art or collectors’ items are specific categories of products which cannot be expected to meet the safety requirements laid down by this Regulation, and should therefore be excluded from its scope. However, in order to prevent other products from being mistakenly considered as belonging to those categories, it is necessary to take into account that works of art are products created solely for artistic purposes, that collectors’ items are of sufficient rarity and historical or scientific interest to justify their collection and preservation, and that antiques, if they are not already works of art or collectors’ items or both, are of an extraordinary age. When assessing whether a product is an antique, such as a work of art or a collector’s item, Annex IX to Council Directive 2006/112/EC could be taken into account.

PART A

Works of art

(1) Pictures, collages and similar decorative plaques, paintings and drawings, executed entirely by hand by the artist, other than plans and drawings for architectural, engineering, industrial, commercial, topographical or similar purposes, hand-decorated manufactured articles, theatrical scenery, studio back cloths or the like of painted canvas (CN code 9701);

(2) original engravings, prints and lithographs, being impressions produced in limited numbers directly in black and white or in colour of one or of several plates executed entirely by hand by the artist, irrespective of the process or of the material employed, but not including any mechanical or photomechanical process (CN code 9702 00 00);

(3) original sculptures and statuary, in any material, provided that they are executed entirely by the artist; sculpture casts the production of which is limited to eight copies and supervised by the artist or his successors in title (CN code 9703 00 00); on an exceptional basis, in cases determined by the Member States, the limit of eight copies may be exceeded for statuary casts produced before 1 January 1989;

(4) tapestries (CN code 5805 00 00) and wall textiles (CN code 6304 00 00) made by hand from original designs provided by artists, provided that there are not more than eight copies of each;

(5) individual pieces of ceramics executed entirely by the artist and signed by him;

(6) enamels on copper, executed entirely by hand, limited to eight numbered copies bearing the signature of the artist or the studio, excluding articles of jewellery and goldsmiths' and silversmiths' wares;

(7) photographs taken by the artist, printed by him or under his supervision, signed and numbered and limited to 30 copies, all sizes and mounts included.

PART B

Collectors' items

(1) Postage or revenue stamps, postmarks, first-day covers, pre-stamped stationery and the like, used, or if unused not current and not intended to be current (CN code 9704 00 00);

(2) collections and collectors' pieces of zoological, botanical, mineralogical, anatomical, historical, archaeological, palaeontological, ethnographic or numismatic interest (CN code 9705 00 00).

PART C

Antiques

Goods, other than works of art or collectors' items, which are more than 100 years old (CN code 9706 00 00).

However, the reselling of products purchased before Dec 13th is allowed (so either second-hand products or stock bought by retailers, but not stock held by manufacturers, I believe) assuming they are GPSD compliant, according to GPSR Article 51.

[Daeothar]

Since it was mentioned; wouldn't the (Northern) Ireland border be a backdoor into the EU?

[Ursus Maior]

Define antique.

Many of mine would be classic if they were cars.

"If the buyer guarantees that they will sit on his pile of shame for at least 6 months before painting, they can be considered 'antiques' ahead of purchase."

Would work for me.

[Andrew Rae]

Woop woop! You can take me off the list - got my rep signed up, just need to do the docs 

Since it was mentioned; wouldn't the (Northern) Ireland border be a backdoor into the EU?

No, GB businesses (or any other non-EU, non-NI business) affected by the GPSR need to follow the same rules selling to NI as they do selling to the EU.

[Ruire]

Since it was mentioned; wouldn't the (Northern) Ireland border be a backdoor into the EU?

Not intentionally, NI should be complying with GSPR. My pondering was how it'll be enforced if UK agencies are seemingly unable to advise.

[Mammoth miniatures]

Woop woop! You can take me off the list - got my rep signed up, just need to do the docs 

I've crossed you out! glad to see there is hope. Would you mind adding a bit of info about the whole process?

[Fighting15s]

It certainly fits the OOP lead and pewter than I sell from time to time. I’ll continue selling and offer an article 3 defence in the very unlikely event that I catch any flak.

Thanks, Fighting15s!

It wasn't actually intended to back up the idea they're collectables. The opposite, in fact, as new make miniatures could reasonably be expected to comply with modern safety requirements. Andrew fortunately elaborates on the definitions.

[zemjw]

Jon from GZG just posted this to the mailing list

FURTHER UPDATE ON GPSR SITUATION, 30th NOVEMBER:

I'm afraid that I've had to take the decision to suspend all EU/EEA/NI sales for the time being (as explained in my last update below), as I'm currently so busy that I simply haven't had enough time to sort out any alternative... the shipping option for these destinations will be turned off on the store either TONIGHT (30th Nov) or tomorrow morning (1st Dec). I'm hoping that this situation will be temporary and that I will be able to resume all sales sometime in the New Year, but for now I just can't run the risk of any parcels being turned back by Customs due to the newly-enforced regulations. All orders that have already been placed (and any last-minute ones that are made tonight before the options are disabled on the store) will of course be fulfilled, there should be plenty of time for them to be delivered before the deadline. Please keep an eye on further announcements here, as soon as the situation changes I will let you know.

Jon (GZG, Saturday 30th November 2024.

[Annie]

We're sorting the rep and documents at the mo and should be grand in the new year, but still stopping shipping to EU/NI/NO on the 6th December til we've got it sorted. Mostly because the we is just me, and I am absolutely flat out at the moment with a trillion tasks, I'm not going to push myself even more. But the good news is we're on it, phew. Finally it makes some sense.

[duc de limbourg]

I understand that Barry Hilton (League of Augsburg) also stopped deliveries to EU but on the shop site cannot find anything about it

[Fighting15s]

At last, wider coverage of the issue and its impact on all small businesses: https://inews.co.uk/inews-lifestyle/money/small-business/small-firms-stop-selling-eu-northern-ireland-brexit-rule-change-3413995

I reserve judgment on the accuracy of the reporting, given that journalists often report stories without having a full understanding of specialised information and that the detail may therefore not be 100% right (said as a former sub-editor).

The article is limited by a paywall, except that i usually gives a free article reading limit. I also note that the BBC did cover this on 26 November, but shunted it into its Northern Ireland section, with the result that no one will have seen it...

[duc de limbourg]

You can add Bachus to the list. They stopped december 3 with their deliveries to the EU

[Chris Abbey]

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.
A risk assessment and product recall plan is needed to cover these four products, and then a product safety label / leaflet. This needs to be supplied in the customers language. We are including one per order. Any company not based in the EU needs to appoint an EU authorised agent.

Mike Wilson is offering this service for hobby businesses in the miniatures and model railway hobbies for a very, very low rate. He lives in France, long time wargamers, modeller and model railway hobbyist with lots of work experience in project management/ analysis helping businesses comply with legislation. His email address is sp762au@gmail.com if anyone is interested.