GPSR Compliance

[bojangled]

This is as clear as mud to me. Been to the gov. advice website and various others.
How does a 1972 poster fit in to this process?

It's not an exempt category. 

Advise buyers this item is for viewing only ? 

My initial reaction, sadly, to to switch EU and NI off. 
Jo

[fatbobfan]

I'm not an economist but I cant imagine this is good for an economy

I've read the bit of the reasoning for the legislation, its protection and its not stated as economical, and in theory it shoud perhaps benefit EU's internal markets but this cant be good reducing so many imported goods, not healthy for so many reasons and so many I probably dont even know or consider

So many goods, the list to me is incomprehensible in the real big picture of things, not just general day to day general consumer goods, but everything, world wide, wow.

[camerapartsuk]

For NI, as some of my items have no retail packaging, could I simply put them in a bag and print/write their address on an envelope and send it without an eBay receipt?

So it wouldn't be like it's a sale?

If I had a relative or friend in NI and was sending them a spare part not from a business sale, would I still have to comply to the regulations?

[goodfella66]

That may be okay for posting but it doesn't get round the obstacle that Ebay are insisting on having details/documentation on the listings.

My European sales have all but disappeared after the Brexit bodge and for the odd few NI sales it isn't worth all the extra work. Unless something sensible happens between now and December, it's goodbye Northern ireland. It's been nice knowing you.

[camerapartsuk]

Ah, yes I didn't think of that, maybe I can put in my listing to contact me if you are from NI and I'll do an out of eBay PayPal transaction lol.

[4_bathrooms]

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@Anonymous wrote:

We may be able to do something similar stating not to be distributed to the EU, only NI.

I am a member of the UK internal market scheme and that does similar, guaranteeing no onward movement of goods into the EU / Republic of Ireland. Saying that, it's not much use if my GB suppliers no longer want to supply me in December.

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Here's the killer caveat found in the Internal Market Act 2020:

"Goods moved from Great Britain into Northern Ireland
Mutual recognition does not apply to goods sold in Northern Ireland where those goods need to comply with relevant EU rules under the Northern Ireland Protocol."

Most people who shop in UK supermarkets have probably seen the bulk point-of-sale fresh produce packaging now emblazoned with "NOT FOR EU". This is because things like fresh produce, meat, medicines etc. produced in the UK can be waved through the (rather exclusive) green lane system provided it clearly states "NOT FOR EU" on the outer distribution packaging. That exemption does not apply to the majority of consumer goods which are required to comply with the GPSRs.  

[4_bathrooms]

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@fatbobfan wrote:

I'm not an economist but I cant imagine this is good for an economy

I've read the bit of the reasoning for the legislation, its protection and its not stated as economical, and in theory it shoud perhaps benefit EU's internal markets but this cant be good reducing so many imported goods, not healthy for so many reasons and so many I probably dont even know or consider

So many goods, the list to me is incomprehensible in the real big picture of things, not just general day to day general consumer goods, but everything, world wide, wow.

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It is market protectionism dressed up as consumer protection. Most - if not all - of the specific exclusions from the GPSRs are intended to protect domestic EU markets (food, aircraft, pharmaceuticals etc). Even the exclusion for antiques is quite specific:

"Antiques, such as works of art or collectors’ items are specific categories of products which cannot be expected to meet the safety requirements laid down by this Regulation, and should therefore be excluded from its scope. However, in order to prevent other products from being mistakenly considered as belonging to those categories, it is necessary to take into account that works of art are products created solely for artistic purposes, that collectors’ items are of sufficient rarity and historical or scientific interest to justify their collection and preservation, and that antiques, if they are not already works of art or collectors’ items or both, are of an extraordinary age."

In short, it is only an antique if it's valuable and is likely to appreciate in value. It doesn't matter that money left the EEA when the item was purchased as it will be even more valuable when it is sold in the future or will attract tax when it is bequeathed. An antique is basically an asset by that definition.

Sellers of new items that require CE marking manufactured by big brands can simply provide the information that comes with the product. However, in most cases an EU consumer would be able to purchase such an item cheaper from a domestic EU seller anyway. The real losers it seems are the sort of non-EU established businesses like yourself who sell to the EU/NI via online marketplaces or their own websites:

• Sellers of second-hand or refurbished items missing their original compliance documents or that never required any when manufactured
• Sellers of new items or replacement parts that do not require CE marking
• Sellers of antiques that don't fall into the GSPRs definition of antiques
• Sellers of collectible items that are not "of historical significance"

If you want to sell into the EEA and/or NI it appears you will need to appoint an EU established "economic operator". Of course, this will increase your costs making you less competitive against a similar EU-established business whilst all the time ensuring even more money ends up in the EU's coffers.

[stampsnallsorts]

Below is a copy of a letter I have just sent to Dept for Trade and Industry on this subject.

How can a business continue to trade into Europe after Dec 13th 2024 under GPSR as collectibles are now to be included in this regulation. In my field of trade most of my products are less than 100 years. It would be impossible to provide the required information for my products as in most cases manufacturers are either not known or no longer trading.
IE -
1. - Kiloware stamps sold by weight as collected by charities. The stamps contained could come from any country in the world of any age used or unused.
2. A collection of items stamps, coin or postcards etc. Same applies.

This not only will effect my business but thousands of businesses across the UK if we have to adhere to this regulation as it stands. The way I see it after the 13th Dec I will have no option but to cease all trade with the EU.

I am an eBay concierge member and as yet eBay have no answer to this problem.

What the heck are UK businesses in our field supposed to do?

HELP PLEASE.

[555njp]

Thank you, my father in law is in exactly the same boat as he sells stamps, postcards and all the associated items to stamp collectors all around the world.

I cannot for the life of me understand why stamps, albums, postcards etc. would be included if the directive is primarily intended for safety reasons? Makes absolutely no sense.

[montgomerycollectables]

Good morning..

Would you mind if I included some of that content as you have written it.. into my email to my MP .  

I will add a few comments of my own.

with thanks

Adrian

[ett1954]

"It is market protectionism dressed up as consumer protection." - You hit the nail on the head there.

In my previous occupation I dealt with EU rulings on a constant basis over more than 35 years.  Protectionism is the name of the game with the EU - initially, in the early eighties dressed up as food safety (admittedly some was necessary) to protect the inefficient markets of certain countries; and more recently under product safety, environmental, and 'worker exploitation / protection' guises.  An army of bureaucrats work unceasingly in introducing new rules.  The EU, as a result, is uncompetitive with external markets and has to constantly introduce further new rules to obstruct imports.

One thing that did become apparent was that the rules are rigorously applied to food and goods imported into the EU however those same rules are not always applied (for one reason or another) with trading between EU members.

Certain countries, and industries (fashion and automotive spring to mind), have a very loose interpretation of the EU rules and standards if it in their national interest, and scramble to achieve preferential treatment with countries whose record on civil and workers' rights come nowhere near those the EU profess to hold.

One day the citizens of the EU will wake up and realise the cost to them (this started with the recent EU elections and French Parliamentary elections, where the extremes of both sides of the political spectrum gained a hold).  Unfortunately not soon enough to prevent this GPSR rule being introduced.  Like others, I will not be trying to figure what documentation I need to present to prove that a book or magazine (most between 60 and 100 years old) does not present a safety hazard.  Goodbye to sales to the EU and NI.

[moonspender]

Its worth reading the EU document, i think broken items for spares or repairs maybe excluded - see below. Untimately its about getting the right CN code on the customs decleration though -

The requirements laid down in this Regulation should apply to second-hand products or products that are repaired, reconditioned or recycled, that re-enter the supply chain in the course of a commercial activity, except for those products for which the consumer cannot reasonably expect that they fulfil state-of-the art safety standards, such as products which are explicitly presented as to be repaired or to be reconditioned, or which are made available on the market as collectible items of historical significance.

Its worth reading the document, it can be downloaded in English

https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0988

[comrie-antique-books]

In other news, I just recieved an email today from Reclay, the company I use for Lucid licencing. Apparently Spain is also rolling out the Lucid scheme from 2025. I make very little sales to Europe, so far this tax year I've had 3, but none to Germany, the previous year it was about 12. Last year I only sold 2 items to Germany, with the profits totalling £18.68, minus the cost of a Lucid number I made £11.90. This year Reclay hiked up the price from £6.78 to £10.63. By the time I add spain in 2025 this is bound to go up to £15.00+ and will liable be rolled out to more countries by 2026. 

I suppose this will get it's own thread in due time, but I just needed to vent my frustration in the meantime. 

For low volume sellers if the GPSR Compliance doesn't kill of EU sales than eventually the LUCID licence will. 

[bojangled]

Interesting continuing discussion on here.

I have already started editing business policies. What I don't want is to be caught up in this towards the end of the year, when hopefully the seasonal rush hits. 
Also had two European orders go awol in a week. Had to shut the door to EU from here. 

[technthread]

I hope eBay can create a database of manufacturers so sellers can auto fill the contact information in the item disclosures of a listing. Obviously it can never be an exhaustive list but if they can cover the most common manufacturers it will make the process a bit easier. 

The way it looks at the moment, it seems like too much hassle to create a listing and it won't end there. If a manufacturer changes contact information such as head office or even their phone number, the eBay seller will have to edit their eBay listings or risk the eBay bots removing them. 

[stampsnallsorts]

Following further investigation and reading off eBay on Govt website even after 13th Dec we are not only going to have to gather more data for each listing adding more time to create a listing, we are also going to have to find CN codes for each different product on top of Tariff Codes we already have to use. Therefore I have decided in begining of December I will block all sales to NI and Europe in my postal policies. That will do away with all the crazy waste of time.

[planet78]

All this carry on is madness for the few NI sales we get, so we'll be stopped sales there from the end of November.

[stampsnallsorts]

2 years ago I joined eBays Global Shipping Program. This cut my international losses from 5% of my sales to zero (peaked in 1 year at £1,500). The good thing is the seller delivers to the shipping company in Lichfield. Once it arrives there eBay become responsible for any claims for loss or damage from then onward. 

There are pros and cons using this system. Shipping costs to customers can be high but I have found a way to reduce costs when they buy more than 1 lot. I create a Client Special order with all their lots in 1 lot, after this lot is paid I cancel there other purchases using option buyer requested to cancel. In general that reduces the shipping most of the time. A pro is all goods shipped out of Lichfield go via a courier company with full on line tracking. Companies like DHL, FedEx etc.

See attached title picture I use for these lots. You are welcome to use the picture I created

[stampsnallsorts]

Just got a very useful answer from eBay Customer Services this morning July 24th. NOTE The para refering to goods supplied to EU BEFORE 13 December 2024.

Hello David,

Thank you for contacting eBay Customer Service in regards to the General Product Safety Regulation (GPSR) . My name is Fiona, and I do hope this message finds you well.

Firstly, I would like to thank you for your patience in regards to me finding out more information into your queries about this legislation applying to your stamps that you sell on the platform.

eBay has categories dedicated to vintage and antique items. In many categories, you can also provide a Year of Manufacture or Year of Publication item specific.

Model, product, serial, or batch numbers along with EAN or UPC can be used to identify specific products or product runs along with brand or manufacturer details. You should find the appropriate product identifiers for your listing category in the item specifics area.

The law does not provide any exceptions for products that were made by a person/entity that no longer exists.

The GPSR will come into force on December 13th, 2024. Products that were first supplied for distribution, consumption, or use on the EU market (in the course of a commercial activity) prior to Dec. 13, 2024, are exempted from GPSR, as long as they conform with Directive 2001/95/EC.

Providing any information that you have can also help your buyers make an informed decision.

As mentioned, I have also shared your feedback with the designated team about your concerns as your feedback is very important to us.

I trust that this is sufficient and I resolved your query today.

Thank you for contacting eBay Customer Service, and for your continued business. I hope you have a great day.

Kind regards,
Fiona
eBay Concierge

[bzmotman]

I may well be wrong but the CN codes shown in the EU Directive matched the HSS code so I perhaps stupidly assumed CN was just an EU version of HSS eg 9705 00 00 is both the CN & HSS for Collectors pieces of historical interest, 9704 00 00 is both CN & HSS for stamps/fdc/postmarks unused if not current issue.

I currently use 4911 99 00 for tickets [Printed matter] but will switch to 9705 00 00

The other issue is that the CN22/23 currently doesn't have a space for both CN & HSS - at least not on the Click & Drop system.

[moonspender]

I agree, they are the same as far as i can see