Coronavirus chemicals update, 15th December 2020

Dear Friend,

It’s Day 267 of Lockdown/ Semi-lockdown, and it turned out that the people planting sphagnum moss plugs yesterday were only here for the day. The rain kept off most of the time, and they also avoided having their sandwiches snaffled by Islay, who was terribly interested in their back-packs!

Important – Brexit Arrangements Update from BEIS

Heather Thomas writes:

A few updates:

1. EU negotiations – I’m sure you’re all following the news and latest Tweets on the status of the negotiations and will have seen Sunday’s joint statement from Boris Johnson and European Commission President Ursula von der Leyen. “Our negotiating teams have been working day and night over recent days. And despite the exhaustion after almost a year of negotiations, despite the fact that deadlines have been missed over and over we think it is responsible at this point to go the extra mile. We have accordingly mandated our negotiators to continue the talks and to see whether an agreement can even at this late stage be reached.” –

2. BPDG webinars – with apologies for the very late notice but I just learned that BPDG will be running further webinars this week. The first webinar will take place on Tuesday 15 December between 09:00 – 13:00 with a focus on border readiness via the Short Straits and UK Landbridge. They will talk through case studies of goods travelling on the landbridge and provide information on customs procedures, transit and the GVMS. (Also apologies I saw details of last week’s webinar too late to share, but we’re trying to get hold of the slides to share.) Registration is here –

3. The second webinar will take place on Wednesday 16 December between 09:00 – 13:00 and will cover border readiness via direct maritime routes. Again, there will be a focus on customs procedures, GVMS and Transit, and they will also present case studies of goods going through maritime routes. Registration details can be found by accessing the links below.

4. Northern Ireland Protocol – I hope you will have seen that Michael Gove, Chancellor of the Duchy of Lancaster (CDL) updated the House of Commons last week on the implementation of the Northern Ireland Protocol as part of the Withdrawal Agreement with the European Union. Details of the agreement have been set out in the command paper published 10/12, link here. And sector specific guidance on moving goods into, out of, or through Northern Ireland from January 1 was published on, link here.

5. HMRC issued another letter to VAT registered businesses last week. The letter included information on customs declarations, the Trader Support Service and a trader checklist of the steps businesses need to take to trade with the EU from 2021. All HMRC letters can be found here 

6. HMRC’s webinar programme continues – a new topic on trader responsibilities, when using an intermediary, will be available this week – no link yet but I’ll share as soon as I receive it.

7. HMRC has launched a new online chat service which traders can use to speak to an advisor about import and export queries. More info here. 

8. HMRC webinars on Completing Customs Import Declarations’ continue. Slots have been filling fast, so new timeslots being added regularly (dates on the website now are 15, 16, 17 Dec). More info here.

9. HMRC guidance on RoW FTAs – Rules of Origin (RoO) – HMRC published further guidance on RoO last week. This covers rest of world Free Trade Agreements (FTAs) and more info can be found at the following:





10. HMRC is also reminding about their Get Ready for Brexit video – these have been published for a while but may still be useful to some as they provide an overview of everything UK businesses involved in the movement of goods between the EU and the UK need to know to keep goods moving after the UK leaves the EU –

11. DFT guidance on helping hauliers prepare for Brexit is here. And DFT has set up information pop-up stands across the UK and Europe to help hauliers and businesses prepare for Brexit, so that goods can continue to flow smoothly through ports. The pop-ups are located at ports, service stations and on ferries to provide easily accessible advice, helping hauliers understand the documentation they need for themselves, their vehicles and their goods after Brexit. All stands will be staffed by multilingual advisors. Details of haulier advice site locations is here –

12. BEIS SoS weekly letters continue to be sent to businesses who are Companies House subscribers. This week’s theme is: Take action now to ensure personal data flows freely from the EU/EEA to the UK.

13. UK Tariff information – DIT have provided updated UK Tariff information, including confirmation that the existing commodity code system will continue to apply from Jan 1, as will ten digit commodity codes. To note, this applies to GB and NI trade movements. More information here. HMRC have confirmed that a CHIEF tariff file will be produced. This will be for a Jan 1 version and will allow existing users of the file to update their tariff systems with all available data. This should be available shortly.

14. A reminder that the first of the HSE and Defra online events covering all chemical regimes (biocides, CLP, PIC, PPP & REACH) is taking place this week – on Weds 16 December – opening 10am for a 10:15am start, finishing by 1pm. The virtual events will cover actions businesses need to take when the UK Transition ends and how the new GB regulatory regime for chemicals may impact businesses, including an interactive Q&A function. The signup page has more details, The focus of these will be more on the ‘how’ to comply with the regulations, and on the more practical, operational side of the changes, as a complement to the information that has been cascaded on ‘what’ actions businesses need to take.

15. And finally, HSE is continuing to publish podcasts to help businesses prepare for the end of the transition period – PPP last week and BPR this week. You can sign-up here to get notifications –

Attached are the last couple of BEIS Business Readiness Bulletins which will have more info just in case anyone’s not receiving them. Business Readiness Bulletin – The UK Transition – 7 December 2020.pdf and Business Readiness Bulletin – The UK Transition – 11 December 2020.pdf

I have thanked Heather again for her tireless efforts in keeping us all up to date with the complexities of Brexit.

Poison Centres glitch around pH Justification corrected

Mark Pfister of Opesus AG writes on LinkedIn:

Submitting dossiers without pH Justification is possible again since today (14th of December 2020):
ECHA has changed the BR621 temporarily to quality rule QLT621: “If you have indicated the ‘pH’ is not relevant, then provide the justification in the adjacent field.”

This means the error (BR621) has been changed to a warning (QLT621) which means that the ECHA submission portal accepts dossier without a pH justification!
The warning gives the APs the option to request additional information from the submitter.

The rule will be changed back to failure with ECHA’s next April 2021 release where QLT621 will become a BR621 again.

Many thanks to Mark for highlighting this problem and how it has been resolved.

Reasons to be cheerful

Today’s Gavin and Stacey clip is a Smithy and Gavin singalong


And there’s an incredibly sad yet happy and ultimately uplifting story of a separated couple who got back together during Lockdown, (also included in a Channel 4 programme at 10pm tonight, along with other couples’ stories).

Many thanks to everyone who has contributed to the newsletter today. As usual, if you have anything you’d like to share, please email me and I’ll do my best to include it in the next newsletter.

I hope your week is going well, and you’re staying on top of all of the Brexit changes.

​Kind regards,


Janet Greenwood

TT Environmental Ltd