Coronavirus chemicals update, 1st March 2021

Dear {{ subscriber.first_name }},

Happy Monday! and Happy St David’s Day, especially to our Welsh readers!

It’s Day 343 of Lockdown, and we have another email about Brexit trade issues from Heather Thomas at BEIS (including news of a Rules of Origin Q&A session next week, which I know may be useful for some readers).

There’s also room today for an update on the Titanium Dioxide issue, a few improvements to last Friday’s fish pie recipe, and of course we have a new set of Reasons to be Cheerful for the week too.

Brexit trade information

Heather Thomas of BEIS writes:

  1. ACTION – very many thanks for all the feedback and intel you have been feeding in. This week’s some more areas where we would be very grateful for any feedback wherever possible:

· A request for feedback on specific costs associated with meeting new trading requirements;

· A request for information on remanufactured goods which may not meet RoO requirements and so face tariffs upon export;

· A request for information on any issues sourcing heat-treated pallets for export.

  1. Rules of Origin Q&A session – Q&A sessions on rules of origin in the UK-EU will be taking place on Tuesday 9 March @ 1600-1700 and Friday 12 March @ 1200-1300 . We are running two sessions but the ground we will cover will be very similar, there are two sessions only to ensure that there is a choice of time, rather than to cover different issues. The aim of the sessions is to ensure that businesses trading between the UK and EU are able to make full use of the Agreement by understanding how to apply the rules and make declarations. Officials from BEIS will briefly run through some frequently asked questions and case studies, provide advice on where to go for further information and then invite further questions from attendees. Any questions that are not answered within the sessions and are relevant to businesses across the sector will be added to our chemicals Q&A pack (the current version has been shared before and is reattached here 20210125 Chemicals RoO webinar QA v.1.pdf) and circulated to attendees and trade bodies after the meetings. We regret that we will not be able to provide definitive judgements on whether a particular company’s products qualify as originating or not – only the company involved can do that – but the aim is rather for us to help people navigate the relevant rules so they can come to their own conclusions. Attendees will be invited to share their feedback and experiences as well as questions, where they think this could help others. If you haven’t seen these already, prior to the Q&A sessions you should review the attached:

· presentation that may help as an introduction; 20210118 – Chemicals Rules of Origin presentation.pdf

· definitions document; 20210125 Chemical Rules of Origin definitions FINAL.pdf and

· guidance document from HMRC that outlines some of the basic principles of rules of origin as well as going into further detail on declarations and on alternative customs procedures for businesses who may not be able to meet the rules. Rules of origin and special procedures FOR PUBLN VER3.pdf

· full GOV.UK guidance – .


  1. UK Global Tariff – if you / your members wish to raise an issue related to the UKGT please complete the Tariff Implementation Monitoring (TIM) form (attached: Tariff_Implementation_Monitoring__TIM__Exercise.pdf ) and submit it to DIT at , ideally copying me in. The form can also be found at . The TIM form is designed to collect evidence on specific products or tariff lines, as well as for evidence and information on the UKGT more widely. As part of the TIM exercise, the UK Government will assess evidence received to monitor the impact of the UKGT. All evidence provided by respondents in this form will be considered alongside wider UK Government analysis to inform assessment of the impact of the UKGT. The Government will then consider what action, if any, should be taken. It’s worth flagging however, that the bar for making changes through this process will be very high.
  2. Duty suspensions – another route to address tariff issues is through duty suspensions (i.e. temporary removal of tariffs rather than a ‘permanent’ change of the underlying rate). DIT is currently seeking views on the process for how businesses can make an application for tariff duty suspensions. These suspensions will apply to goods imported into the UK. The consultation closes on 12 March.
  3. Turkey FTA – the Turkish authorities have told the UK Government that all businesses, including SMEs, exporting products from the UK to Turkey should provide a letter of guarantee from their banks to cover their potential tariff liability according to Turkey’s tariff schedule. The UK agreed a in December, which means that originating goods that UK businesses send to Turkey should cross the border tariff-free. However, this agreement is yet to be ratified and so this measure has been taken by Turkey for this short interim period. We understand that some UK businesses are being asked to make ‘guarantee payments’ equivalent to Turkey’s tariff schedule, at the point that the UK originating good enters Turkey, with the promise of a refund after ratification of the treaty. This is not a requirement in our agreement and UK ministers have asked the Turkish Government to prevent officials and intermediaries from asking for this. If you are encountering difficulties, please contact the .


  1. The latest BPDG stakeholder bulletin is attached with lots of information, including webinar details and Q&A (and links to Q&A from webinars) 2021-02-26 BPDG Weekly Stakeholder Bulletin (1).pdf. You may be interested in ‘Industry Day’ webinar on the Short Straits which BPDG will be hosting on Monday 8 March (I can’t see any time as yet). This will focus on how cross-Channel trade has fared since 1 January, with a specific focus on what companies can do to keep their operations smooth in light of new controls. British and French officials will be available to answer your questions. To register for this event, click .
  2. BPDG have launched a survey for the (Businesses that trade over £250,000 of goods with the EU each year are eligible for a range of support; this includes: invitations to specialist events; 1-to-1 query resolution; more access to business case studies; sector-specific guidance from policy experts). The survey seeks your views about the guidance you need – you’re invited to .


  1. HMRC has put in place a range of support for customs and international trade customers. In response to feedback that customers are experiencing difficulties with transit for imports/exports, HMRC has introduced 24/7 support. More detail, including helpline numbers and contact email addresses for support,
  2. On Guarantee Reference Amounts, HMRC has now updated NCTS meaning that declarations require a value to be entered in the guarantee reference amount field. As a temporary solution, for those traders who are unable to enter a figure in the guarantee reference amount field, HMRC is now entering a value of £1 for each movement to enable the movement to be started.
  3. The Goods Vehicle Movement Service: [UPDATED] the GVMS is for traders, hauliers and carriers who use a UK Port. This service brings together multiple declaration reference numbers into a single goods movement reference. This is to speed up the clearance of goods through customs. The updates clarify what hauliers need to do to take advantage of this service.

· Guidance for hauliers has been updated .

· Guidance on registering for the Goods Vehicle Movement Service has been updated with new information about who should register for the service. For more information, click .

· Get a goods movement reference: Information about what you need to do to get a goods movement reference has been updated. For more information, click .

· Check if a goods movement reference is valid: Information about hauliers moving goods from the EU to GB has been updated. For more information, click .

  1. European Conference of Ministers of Transport (ECMT) international road haulage permits: [UPDATED] Guidance on permits to travel to or through ECMT member countries has been updated. Information about applying for short-term permits has been updated, you can now apply for there for the rest of 2021. For more information, click .
  2. HMRC newsletter to help traders avoid some problems they may encounter when moving goods under transit: [UPDATED] has been updated with information on ‘French ports with the ‘smart border’ system’. For more information, and to view recent editions of the newsletter, click .
  3. List of customs agents and fast parcel operators: [UPDATED] The list of agents and operators who can help submit customs declarations has been updated. For more information, click .
  4. Using CHIEF, the Customs Handling of Import and Export Freight for declaring goods into or out of Northern Ireland: [UPDATED] Guidance has been updated with information about the use of CHIEF before making declarations. For more information, click .
  5. Exporting: What you need to do to keep your goods moving: [NEW] A new YouTube video from HMRC is now available to watch on-demand. To view this, click .


  1. The UK REACH Agency approach to gathering and using independent scientific knowledge and advice (ISA) has been published in a draft statement – and feedback is sought. More information can be found in this .


  1. Data adequacy – the European Commission has provided its which recognises the UK’s high data protections standards and set out that the UK’s standards are ‘adequate’; the decision now goes forward for member state approval. Positive data adequacy decisions under both the EU General Data Protection Regulation (GDPR) and the Law Enforcement Directive (LED) would allow for personal data to continue to flow freely from the European Union (EU) and wider European Economic Area (EEA) to the UK. The ‘bridging mechanism’ will remain in place until June 30 or until the adequacy decisions come into effect, whichever is sooner. The EC’s statement is and HMG’s statement is .


  1. The new Taskforce on Innovation, Growth and Regulatory Reform (TIGRR) will identify and develop proposals across a range of areas that will drive innovation and competitiveness, reduce barriers to start-ups and scale-ups, create opportunities for innovation to make the most of cutting-edge technologies, and support growth and dynamism right across the UK economy. The Prime Minister has asked the Rt Hon Sir Iain Duncan Smith MP, the Rt Hon Theresa Villiers MP, and George Freeman MP to form the Taskforce. The Taskforce can be contacted at and welcomes submissions on opportunities to drive growth and innovation through regulatory reform.

Many thanks as usual to Heather, who is still working shifts with her colleagues to try to keep everyone up to date and the flow of goods into and out of the UK running as smoothly as possible.

As usual with information from the regulators, I have set this newsletter to “open access” on this website so you can share this page with anyone who may find it useful.

Titanium dioxide revisited

Following on from my email on Friday about the developments in the Titanium Dioxide case being heard in the EU, Alison Hill of Billions Europe writes:

Maybe worth pointing out the court case was brought forward by some of the individual companies under the TDMA.

I think this highlights those in support acting as interveners in the case, including CEFIC and CEPE

This case and the other cases brought forward unfortunately will not reach a conclusion before the classification is implemented

And an eagle-eyed reader spotted this very interesting first comment, from the UK, on the original TiO2 proposal:

As the CLH report and decades of human health experience (CLH report p8 Carcinogenicity) Human data do not suggest an association between occupational exposure to TiO2 and risk for cancer. This type of scaremongering brings the work of the ECHA into disrepute and actually leads to detrimental effects on support for EHS awareness in the general public when products of extremely safe wide exposure (in almost every home there is a painted of plastic article containing titanium dioxide). Consequently, when the general public and workers see this sort of classification it is generally ignored with the risk that really dangerous substances are then also ignored.

You may also be interested in James O’Shea’s article for Speciality Chemicals Magazine back in 2019, which can be viewed here: .

More fish pie recommendations

And another follow up, this time from my Fish Pie recipe on Friday, Dr John Smith of Aztec Oils remembers his Granny used to add broken up ready salted crisps to the topping to make it crunchy; and Alan Ritchie of WSP suggests three improvements:

  • add a couple of chopped up hard boiled eggs
  • for a richer sauce, use half cream/ half milk rather than all milk (if you’re using all cream, you probably don’t need to make the bechamel)
  • and don’t pre cook the salmon, the other fish is fine, but salmon is best cooked in the pie itself (if you don’t have fresh salmon, defrost your frozen salmon completely before using it)

Reasons to be cheerful

Our funny clips this week are Father Ted. For our younger readers, Father Ted was a sitcom set in a very remote Irish parish about 3 priests and their housekeeper.

Today’s clip is The Dancing Priest:


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 you are refreshed after a good weekend off, and are looking forward to an excellent week.

​Kind regards,


Janet Greenwood

TT Environmental Ltd