UK/EU Sales post Brexit

[LilyJo]

So, finally there appears to be a little clarity on what happens when we leave the EU on the 29th March and some ideas of what happens if we get a deal and if we dont.

For any UK soap, bath product, cosmetic makers its worth making sure you understand the rules and act as quickly as you can. Not claiming to be an expert on this but I do have TS documents to refer to, however, its worth making sure you read everything you can and speak to your local TS office for further advice.

In essence, post 29th March you will not be able to access the EU CPNP (portal) and unless you can nominate a suitable EU responsible person (RP) before the 29th you will not be able to access the data and may be unable to legally trade (into the EU).

The UK is implementing its own version of the CPNP but this is still in the beta testing phase. Once that is available all cosmetics (soap, bath bombs, bath salts, make up etc) must be uploaded by 29th March. There is a 90 day grace period to allow for changes in packaging etc but products must be uploaded ithin that 90 day period. Labels must include both EU and UK CPNP RP details.

A RP must be nominated who is UK based. If you wish to sell in the EU you must have an EU RP and both details must appear on products.

The big one to note is that if we were to leave the EU without a deal and under WTO rules, products from the UK sold into the EU may be subject to tariffs. I understand that this is likely to apply at a rate of 6.5% for shaving products, deodorants/antiperspirants, bath salts/bath preparations. This may include bath bombs - this could have an impact on prices so its worth checking this out for anyone who sells into the EU.

As I said, not an expert but this has come to me in the last day or so and I thought its worth sharing given we have a few UK members.

 

[earlene]

I am so glad you posted this, LilyJo. I am not in the UK, obviously, but I have been wondering how this would be handled.

Do you have any idea how it will affect sales of these products from outside the UK? Will non-UK sellers be able to sell to the UK in the same way they do now (following EU standards) or will they also need to use the UK's portal? Or has that been addressed? I am thinking of sellers on eBay & Etsy, for example.

 

[LilyJo]

My understanding is that if you were to sell into the UK or the EU, you would need to basically follow the same rules - safety assessment etc but that the RP has to be from the EU and/or the UK. I think that for someone in, say, the US, you could need to register in both the UK as well as the EU so I am hoping that there is some alignment of the assessment criteria.

 

[Chris_S]

Have you got any idea on what will happen if you apply for the assessment after we leave the eu are the regulations going to be the exact same set of rules and regulations we had before in the UK or will they be changing them too? Thank you so much for posting this I have yet to get to the point of being ready to sell my soaps as I'm still testing and deciding on my fave recipe this is why i am trying to find out if the rules or process besides what you have mentioned will be changing at all.

 

[LilyJo]

My undersstanding is that the basic rules will stay the same (safety assessments etc) but that the process for registering the product and allocating an RP will be slightly different and, I think, if you wanted to sell in the UK and the EU you would need to register your products on two seperate portals with two separate RPs. Not a problem in itself but there may be an additional cost to nomintae a suitable RP in Europe unless you have a friend or family member who can cover that role.

 

[Deadgroovy]

Just registered with the eu portal, waiting for my safety assessment to be completed. Think I will only be selling in the UK, so is it worth going through the rigmorole of registering with the eu portal?

 

[Chris_S]

My undersstanding is that the basic rules will stay the same (safety assessments etc) but that the process for registering the product and allocating an RP will be slightly different and, I think, if you wanted to sell in the UK and the EU you would need to register your products on two seperate portals with two separate RPs. Not a problem in itself but there may be an additional cost to nomintae a suitable RP in Europe unless you have a friend or family member who can cover that role.

Thank you that was kind of what i was thinking but always good to have someone with more knowledge in the matter say something along the same lines. Not really got any intention to sell outside the UK far beyond my ambition without selling a single soap in the uk yet lol. Furthest my soaps might go is to friends in America as gifts but thats an entirely different matter and issue for another day.