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

[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!   

[Rick]

Ah yes, good old EU protectionist political bureaucracy; the gift that keeps on giving...

Seriously - what on earth was the point of negotiating a free trade deal if they're just going to keep doing things like this?

Or am I just being overly cynical in linking this current EU regulatory mess with a new, more pro-EU, UK government?

[carlos marighela]

The answer to that is Yes.

The answer to that if you live in Southend, Thurrock or Great Yarmouth is more than likely 'bendy bananas' or 'real British sausages'. Unless you own a small business or you are a fisherman, in which case you've had sufficient time to realise your own idiocy and will probably just quitely mutter something incomprehensible and utterly inane about 'taking back control'.

[jon_1066]

It sounds like the trickiest thing is to translate your safety warning sheet into 24 different official languages.

[carlos marighela]

I see much Google translating in the near future, resulting in safety instructions that read like the instructions to a 1980s Korean VCR. Tantalisingly close but still gibberish.

[Daeothar]

Definitely not a fan of these new rules, but it's obvious they were originally aimed at the huge amounts of sub-par, cheap goods coming in from China. Hitting small UK businesses is just a byproduct of this ill-advised legislation and certainly not a deliberate attempt to hurt UK commerce (We'd all rather have seen you never leave in the first place ). But of course Chinese importers have already taken measures and are (probably) virtually not impacted by the whole deal...

It sounds like the trickiest thing is to translate your safety warning sheet into 24 different official languages.

I'm not familiar with the details of the regulations, but because it's safety related, requirements here might be in line with ADR regulations (of which I know a heck of a lot more), and that states that descriptions need to be in the language of the country of origin and if this language is not English, French or German, also in one of these three languages. So going with ADR as an example, simply English might actually suffice.

Then again, what do I know; there might be a completely different requirement in place...

[Andrew Rae]

I found this page which is hopefully accurate (fingers crossed) if existing requirements are extended to GPSR products: https://www.productip.com/kb/productipedia/compliance-resources/languages-in-user-instructions

I think for direct to consumer sales you'd only need the language(s) required by the destination country, but sales to EU importers or distributors could require more - if those importers and distributors sold to all EU states, all the languages would be required.

Edit: The multi-language safety info also needs to be in the product listing, with translations for every EU country to which you have a shipping option. Luckily my regular shop is only affected for sales to Northern Ireland and Norway, so English is fine and I'm relying on Etsy's auto translate for the listings there. Otherwise it would be totally unmanageable with Etsy's terrible listing UI! Not that anyone is every likely to check these things, but still...