News & Insights

Composite products: an unworkable minefield of regulation

By Jonathan Kittow on 19/03/21 18:30 |

First the Good News: Michael Gove on behalf of the UK Govt. have unilaterally declared a 6 month extension to UK Customs Import Procedures. Now the not so good news...
  1. The new regulations on export requirements for Composite products are an unworkable minefield of regulation for many manufacturers seeking to maintain supply of their products to RoI/NI and Europe, especially if retailers decide they require batch level health certification of goods they are consolidating in the UK.

Currently there appear to be two fundamental issues:

Firstly, a lack of clarity of interpretation of the regulations themselves, especially with regards processed dairy ingredients, as to whether a Private Attestation meets the regulation and
Secondly, what retailers (particularly those who consolidate in the UK) require from suppliers in response to the above.
Defra draft guidance is due next week, but with just over 3 weeks  to implementation, European retailers are as concerned as UK Manufacturers that shelves could be left empty of many lines including biscuits and chocolate.

  1. The rumour of a common sense review of the need for ISPM15 pallets appears to be overstated and there are no plans to change forthcoming, so the requirement for RoI and NI stock  to be re-palletised remains for the foreseeable future.

Through our collaboration initiative with the Post-Brexit Group suppliers, retailers and now Govt. departments we will continue to work hard to clarify the issues and gains a consensus approach to the implementation of regulation, where possible.

DOWNLOAD the Extension to UK Customs Import Procedures

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