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Brexit process
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UndercoverElephant



Joined: 10 Mar 2008
Posts: 8864
Location: south east England

PostPosted: Mon Oct 15, 2018 4:36 pm    Post subject: Reply with quote

Little John wrote:
I've been reading here and there, over the last few days, that a Canada style free trade deal has always been on offer from the EU, but that May has consistently rejected that and gone for her chequers plan instead.

Is that actually True?. Does anyone know? Because, if it is true, then she is a f***ing traitor to this country.


It's true, but misleading. The EU has always been offering Canada, but with a border in the Irish Sea. Canada with a border within Ireland has never been on offer.
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Mark



Joined: 13 Dec 2007
Posts: 967
Location: NW England

PostPosted: Mon Oct 15, 2018 5:55 pm    Post subject: Reply with quote

More on the impact of 'No Deal' Brexit on the Chemical Industry.......

HSE to replace EU chemicals agency in a no-deal Brexit:
https://www.endsreport.com/article/61106/health-and-safety-executive-to-replace-eu-chemicals-agency-in-a-no-deal-brexit

The government would seek to maintain as much regulatory continuity for chemicals as possible in the event of a no-deal Brexit, according to guidance issued on Friday afternoon. All six papers state that a no-deal scenario “remains unlikely given the mutual interests of the UK and the EU in securing a negotiated outcome.” The papers came just ahead of news that a 21-month post-Brexit ‘backstop’ is becoming a more likely prospect, to avoid the creation of a hard border in Northern Ireland. Under this, the UK would effectively remain within the EU, though without any influence on its rules. None of the papers are longer than a few pages and offer limited detail, such as the extra costs involved. While largely playing down the consequences of Brexit, they also hint at some profound impacts on business and potentially the environment. Should a no-deal come to pass, the Health and Safety Executive (HSE) would step into roles currently occupied by the European Chemicals Agency, European Food Safety Authority and the European Commission, with little time to prepare. Nothing is said about the practicalities of recruiting sufficiently qualified staff and developing IT systems before April.

NGO CHEM Trust is “very concerned” about the focus on the HSE, given that “they don’t have adequate environmental expertise & commitment. They are also not involved in public health,” said executive director Michael Warhurst. The guidance for pesticides states: “In a no-deal scenario the UK would not be legally committed to medium or long-term regulatory alignment with the EU. Divergence from developing EU legislation would be possible in due course.” Given time, this could see the EU ban pesticides that will remain in place in the UK, or the HSE approving new pesticides and formulations that will not be permitted in the EU. At the same time, it adds: “The technical requirements of the regime would remain the same as they are in current EU legislation, maintaining existing standards of environmental and health protections.” Among such pesticides could be glyphosate. Although Brussels has given the world’s most commonly used weedkiller the thumps up after it was linked to cancer, some member states favoured a ban when its authorisation was discussed last year. In contrast, the agricultural and horticultural lobby opposed the move, with environment minister Thérèse Coffey describing glyphosate as “amazing” in August.

As things stand, the EU Plant Protection Regulation requires active substances to be approved at EU level. Products containing them are approved for sale and use by the HSE. This two-layer system would be stripped away under no-deal, the HSE regulating pesticides and their formulations directly. All approvals, authorisations and maximum residue levels in place on 29 March next year would continue to be recognised. From then on, all pesticides regulation would fall to the HSE, with businesses being warned that they should plan ahead for the change. Processes carried out by the European Food Safety Authority, such as public consultation would be retained “if they are relevant in a UK only context”, states the guidance. New arrangements for independent scientific assurance would also be put in place. A further change would make it easier to establish what maximum residue levels for food and active substances have been approved. A new statutory register, backed by a publicly accessible online database will be created, replacing separate volumes of tertiary EU legislation.

Regulation under the EU Biocidal Products Regulation works in a broadly similar way to pesticides. Under no-deal, the HSE would be responsible for authorising substances and approving products and will develop its own IT systems. Any applications under the EU regime would need to be re-submitted to the HSE. Classification, labelling and packaging (CLP) requirements would remain much the same, though manufacturers and importers to the UK would have to notify classification details to the HSE rather than ECHA. The CLP paper also states: “In future, the UK will be free to make its own decisions about chemical hazard classification, including whether or not to align with decisions made in the EU or other countries. The paper on prior informed consent, a process which implements the Rotterdam Convention on international trade in hazardous chemicals, would again pass the European Chemicals Agency’s role to the HSE. Unlike now, companies exporting chemicals within the single market would have to notify the regulator. The UK broadly expects to keep pace with the EU as it implements the decisions of the Stockholm Convention on persistent organic chemicals. Similarly, Brexit should have little impact on the UK’s management of mercury, which is governed by the international Minamata Convention and the EU Mercury Regulation, says the mercury paper. The regulation prohibits the export of mercury-bearing materials outside the EU, with certain derogations. Under no-deal, consignments to the EU would be permitted, while imports banned. As so little is imported, “this should have a limited impact on business” it says.

The Chemical Industries Association and its EU counterpart CEFIC published their own guidance note on Friday, on preparing for a future with the UK out of REACH. This will be the case from 30 March without a deal or perhaps 2021 if a transitional period is agreed.

The practical advice includes:
• Identifying chemicals affected by Brexit and companies’ roles in the supply chain
• If a substance is manufactured in the UK and EU by subsidiaries of the same company, the latter could act as the importer for the former. Doing so would mean that the EU firm’s registration dossier would need to be updated to accommodate the additional volume being placed on the market, which may cross a tonnage band and mean more testing requirements.
• To ease compliance, draw up a contract to appoint an only representative with a suspensive clause, to take effect when UK withdrawal is complete.
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Potemkin Villager



Joined: 14 Mar 2006
Posts: 1036
Location: Narnia

PostPosted: Mon Oct 15, 2018 7:36 pm    Post subject: Reply with quote

Flanders and Swan Brexit latest.


"The English the English the English are best
I wouldn't give tuppence for all of the rest

And crossing the channel one cannot say much
For the French or the Spanish, the Danish or Dutch
The Germans are German, the Russians are red
And the Greeks and Italians eat garlic in bed

The English are noble, the English are nice
And worth any other at double the price

And all the world over each nation's the same
They've simply no notion of playing the game
They argue with umpires, they cheer when they've won
And they practice before hand which spoils all the fun

The English the English the English are best
I wouldn't give tuppence for all of the rest

It's not that they're wicked or naturally bad
It's just that they're foreign that makes them so mad
The English are all that a nation should be
And the pride of the English are Chipper and me"


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"Test to destruction: engineers like to do that. Only with a test to destruction can you find the outer limits of a system's strength".Kim Stanley Robinson
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Little John



Joined: 08 Mar 2008
Posts: 6125
Location: UK

PostPosted: Mon Oct 15, 2018 7:39 pm    Post subject: Reply with quote

Yes... Yes... of course.

Anyone who believe in nation statehood must be a blithering, jingoistic fool at best or a knuckle dragging moron at worst...right?

you are pathetic
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Potemkin Villager



Joined: 14 Mar 2006
Posts: 1036
Location: Narnia

PostPosted: Mon Oct 15, 2018 7:43 pm    Post subject: Reply with quote

And maybe you should get a life and take yourself a little less seriously.
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stumuz1



Joined: 07 Jun 2016
Posts: 135
Location: Anglesey

PostPosted: Tue Oct 16, 2018 8:54 am    Post subject: Reply with quote

Mark wrote:
such as the extra costs involve.


Sorry no, there will no extra costs for the taxpayer. Any extra costs are going to be paid by EU companies. When they re-register with UK HSE.
UK companies are grandfathered over.

Mark wrote:


The practical advice includes:
• Identifying chemicals affected by Brexit and companies’ roles in the supply chain
• If a substance is manufactured in the UK and EU by subsidiaries of the same company, the latter could act as the importer for the former. Doing so would mean that the EU firm’s registration dossier would need to be updated to accommodate the additional volume being placed on the market, which may cross a tonnage band and mean more testing requirements.
• To ease compliance, draw up a contract to appoint an only representative with a suspensive clause, to take effect when UK withdrawal is complete.


This advice is about two years old. All UK chemical companies will have started doing this within an hour of the referendum result.

Remember, CEFIC, CIA, ENDSREPORT.

All private companies selling compliance services.
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Mark



Joined: 13 Dec 2007
Posts: 967
Location: NW England

PostPosted: Tue Oct 16, 2018 10:50 am    Post subject: Reply with quote

stumuz1 wrote:
Sorry no, there will no extra costs for the taxpayer.


Blimey, you're hard work..... Smile

Setting up a UK equivalent to ECHA - Free ?
Setting up a UK equivalent to IUCLID - Free ?
All the extra people required at HSE/DEFRA to assess all the Registrations/Dossiers - Free ?
I could go on....

Then there's cost of Raw Material imports from the EU and elsewhere - all these registration costs will for sure be passed on to UK industry.....,
Costs up = Competitiveness down
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Mark



Joined: 13 Dec 2007
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Location: NW England

PostPosted: Tue Oct 16, 2018 10:58 am    Post subject: Reply with quote

stumuz1 wrote:
This advice is about two years old. All UK chemical companies will have started doing this within an hour of the referendum result.


Really ?
The big ones with regulatory departments maybe, but certainly not SMEs....
My belief is that most are still watching/waiting, like other industry sectors....
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Potemkin Villager



Joined: 14 Mar 2006
Posts: 1036
Location: Narnia

PostPosted: Tue Oct 16, 2018 4:24 pm    Post subject: Reply with quote

This seems pretty comprehensive as to exactly what no deal entails.

https://www.docdroid.net/m3YvOS5/brexit-truth-revised.pdf

"Let’s look more closely at no-deal. By default, we will automatically enter a no-deal situation on Brexit Day, unless we agree and ratify a Withdrawal Agreement. Parliament has a say on any Brexit deal, but it has no say on no-deal. That’s because no-deal isn’t a deal at all, but simply a shorthand way of describing the absence of any deal. The promise made to Parliament of a “meaningful vote” only allows for a vote on an actual deal. MPs can’t vote on nothing, which is what no-deal is.

No-deal has never been a real choice at all, regardless of Theresa May’s sloganeering. It’s where we end up when negotiations break down and we run out of alternatives. If you fall off a building, you grab at anything to break your fall. No-deal is the strawberry jam splat as you hit the ground. There is literally nothing worse."

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stumuz1



Joined: 07 Jun 2016
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PostPosted: Tue Oct 16, 2018 4:45 pm    Post subject: Reply with quote

Mark wrote:
stumuz1 wrote:
Sorry no, there will no extra costs for the taxpayer.


Blimey, you're hard work..... Smile


I thank you !!!

Mark wrote:

Setting up a UK equivalent to ECHA - Free ?
Setting up a UK equivalent to IUCLID - Free ?
All the extra people required at HSE/DEFRA to assess all the Registrations/Dossiers - Free ?
I could go on....


These will be paid for by the chemical companies, concomitant with the polluter pays principle.

The HSE is purely paid for by fees and fees for intervention. No tax payer money needed.

Mark wrote:

Then there's cost of Raw Material imports from the EU and elsewhere - all these registration costs will for sure be passed on to UK industry.....,
Costs up = Competitiveness down


Most chemical feed stocks or raw materials are sourced outside the EU (mostly China) so again nothing going to change.

As for competitive, I am currently dealing with the export to Asia of 23 litres of a complex chemical product,
The price £103000. Yes nearly 5K litre!

They would not be buying it if they could make it themselves, or find it cheaper.
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stumuz1



Joined: 07 Jun 2016
Posts: 135
Location: Anglesey

PostPosted: Tue Oct 16, 2018 4:47 pm    Post subject: Reply with quote

Mark wrote:
stumuz1 wrote:
This advice is about two years old. All UK chemical companies will have started doing this within an hour of the referendum result.


Really ?
The big ones with regulatory departments maybe, but certainly not SMEs....
My belief is that most are still watching/waiting, like other industry sectors....


And the best thing about SME's? Highly nimble. They'll be fine.
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Mark



Joined: 13 Dec 2007
Posts: 967
Location: NW England

PostPosted: Tue Oct 16, 2018 4:54 pm    Post subject: Reply with quote

stumuz1 wrote:
These will be paid for by the chemical companies, concomitant with the polluter pays principle.

The HSE is purely paid for by fees and fees for intervention. No tax payer money needed.


Exporting chemicals to the UK will classified as a polluting activity ?
I've not seen that stated anywhere...., have you got a reference ??

Fees For Intervention are currently only paid to the HSE if a company does something wrong.
I've not seen anything to say that FFI is changing either - reference ?
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Mark



Joined: 13 Dec 2007
Posts: 967
Location: NW England

PostPosted: Tue Oct 16, 2018 5:16 pm    Post subject: Reply with quote

stumuz1 wrote:
Most chemical feed stocks or raw materials are sourced outside the EU (mostly China) so again nothing going to change.

As for competitive, I am currently dealing with the export to Asia of 23 litres of a complex chemical product,
The price £103000. Yes nearly 5K litre!

They would not be buying it if they could make it themselves, or find it cheaper.


I don't know the exact EU/non-EU split, but a massive chunk currently comes from Germany/France/Spain/Holland..., especially at the commodity end where transport costs are key...
Granted, China & India are a growing presence from a low base but are certainly not the majority as you state...., reference ??

I'd venture that your £5K a litre example is a rare exception, rather than the rule.... the vast majority of UK chemical producers face stiff competition.....
A more common example/trend would be R&D in the UK with manufacturing under Licence in India/China (lower costs and safety/environmental protection).
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Mark



Joined: 13 Dec 2007
Posts: 967
Location: NW England

PostPosted: Tue Oct 16, 2018 5:25 pm    Post subject: Reply with quote

stumuz1 wrote:
Mark wrote:
stumuz1 wrote:
This advice is about two years old. All UK chemical companies will have started doing this within an hour of the referendum result.


Really ?
The big ones with regulatory departments maybe, but certainly not SMEs....
My belief is that most are still watching/waiting, like other industry sectors....


And the best thing about SME's? Highly nimble. They'll be fine.


Either, all companies started preps 2 years ago and are ready and waiting....
Or, SMEs don't need detailed preps as they'll get by on the hoof.....
Make your mind up, you can't have it both ways.....

My vibe is that most UK companies are nervous and getting more so, regardless of the sector.
Very few have detailed plans in place, due to the ever moving political sands....
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stumuz1



Joined: 07 Jun 2016
Posts: 135
Location: Anglesey

PostPosted: Tue Oct 16, 2018 5:33 pm    Post subject: Reply with quote

Mark wrote:
stumuz1 wrote:
These will be paid for by the chemical companies, concomitant with the polluter pays principle.

The HSE is purely paid for by fees and fees for intervention. No tax payer money needed.


Exporting chemicals to the UK will classified as a polluting activity ?
I've not seen that stated anywhere...., have you got a reference ??

Fees For Intervention are currently only paid to the HSE if a company does something wrong.
I've not seen anything to say that FFI is changing either - reference ?


Doing a bit of legal reasoning there.

It goes like this, stay with me!

Lord young introduced fees for 'HSE services' at the beginning of the coalition govt'. His reasons was, why should taxpayers pay for the education of criminal H&S offences when the law abiding companies paid for the HSE through their taxes and did not commit the offences.

So Fees was introduced.

HSE have always been the competent authority for chemicals. Since the financial crash they are self funding.

Chemicals provide most of our pollution and ill health. Since the Rio earth summit the polluter pays principle has been adopted by countries to give the bill to the polluters.

So, if you want to put a novel chemical on the market. .. You pay.
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