Christeyns Food Hygiene’s Regulatory Affairs Manager talks BREXIT

Mike Taylor, Senior Chemist and Regulatory Affairs Manager for Christeyns Food Hygiene Limited. It’s the Regulatory Affairs bit which has been grabbing all the Technical Department’s attention since Christmas.

At the end of the Brexit Transition Period on 1^st January 2021 the UK had a deal – but although we have avoided tariff charges there is still a lot to do as a result. So as the motorway signs kept reminding us we have been working on our documentation for international trade and have designed and introduced a Commercial Invoice, complete with Country of Origin, EORI numbers, shipping terms, commodity codes, weights and the all important number of pallets. Then there’s a Packing List too.

As most of our goods are classified as dangerous for transport by road, sea and air they are still fully covered by international agreements such as ADR and IMDG but for the labelling for the actual end user – for supply – new rules for the UK have been drawn up to replace the EU ones : hence the UK now has its own Classification, Labelling and Packaging Regulations: GB CLP. We are hoping that these also stay in line with the Globally Harmonised System (GHS) adopted by the EU but theoretically in future they could diverge.  Chemical classification: The GB CLP Regulation (hse.gov.uk).

The system for controlling chemical substances available and in use in the EU i.e. REACH (Registration Evaluation Authorisation and restriction of CHemicals) has been replaced in the UK by….UK REACH. Similar but different as we in the UK are having our own Registrations. https://www.hse.gov.uk/reach/.

Potentially the most expensive of the new UK legislation are the controls for any product which claims to kill moulds or yeasts or bacteria or deactivate viruses: the Biocidal Products Regulations or GB BPR. Again, similar to existing EU legislation, which feels as if it has been evolving for ever. The UK is having its own system and is beginning again – well almost, with a flying start. There is already disquiet and muttering about the cost of registrations or re-registrations if your company had European operations. GB authorised biocidal products – Biocides – HSE

We’re all doing our best to learn and adhere to the new regulations, with plenty of paperwork – or online time – and more deadlines to be aware of and to hit. Still, in the words of the old Flanders and Swann song, “It all makes work for the working man to do”. Now that’s giving my age away…….