"Alternative Armies: GPSR (General Product Safety Regulation) EU Statement" Topic

Lots of companies are making this announcement. It doesn't sound good for either the EU, or the manufacturers as they end up being forced to lose a customer base.

I suppose this affects American companies selling into the affected areas also.

This is what happens when a micro-managing bureaucracy takes hold.

"For instance, the name, address, and electronic address of the economic operator should be listed on the product or its packaging or labelling."
That banking commercial from a few years back comes to mind:
"There's a FEE/TAX for that"

Is the "responsible person" intended to be a super-strong version of establishing jurisdiction over a foreign company, so that the EU can more easily pursue that company for fraud, dangerous products, etc.? Or does this new requirement serve some other purpose, or even serve the purpose of eliminating foreign direct sellers, and effectively requiring foreign companies to use EU-based middlemen and vendors?

when ever did the beaurocratic overburdening clowns in the EU parliment do anything other for them selves and screw the people, we should slap the same on the EU from every country in the world

Are there other UK companies reacting this way? This is the only one I have seen so far.

@marmont1814

"when ever did the beaurocratic overburdening clowns in the EU parliment do anything other for them selves and screw the people, we should slap the same on the EU from every country in the world"

A pretty important thing those 'clowns' did was protect consumers from extra costs being forced on them by retailers and manufacturers.

Under EU regs all goods must be fit for purpose out of the box. Battery operated goods must ship with batteries included. Electrical goods must have plugs attached to power cables. Power tools ship with blades, cutters or drill bits.

Some in the UK wanted Brexit and to "Take back control", well they got their wish so let them suffer the consequences.

Bureaucrats create rules to increase and support more bureaucracy. Film at 11.

It's time for a change in Europe (and honestly, everywhere else).

Why the *&*$ would anyone need such absurd regulations? Lots of things in the US these days come with batteries simply because they sell better— the market decided.
And what petty things you list that the EU has "saved" the people from. Needing to buy drill bits and blades and batteries? Oh, those poor, poor souls with their First World problems. Thank GOD the EU has saved them from that misery. [/sarcasm, for those who can't read it, like bureaucrats.]

And yes, it is absurdly affecting the rest of the world: Apple had the Lightning proprietary connector for its iPhones and iPads. It's got greater throughput than USB-C, is orientation neutral, and the biggest hang up was you couldn't plug an old 1/8-inch micro headphone set into it. But you could use Bluetooth headphones/earbuds with it, and dispense with the cable entirely, or buy an adapter. But noooooo… the EU had to insist that the iPhone be entirely retooled to be fitted with the inferior USB-C connectors because it was "too hard" for Europeans to figure out the advantages of wireless headphones, or that an adapter was a small concession. So now the rest of the world has to use USB-C, regardless of its drawbacks, because it's too costly for Apple— yes, Apple— to try producing both EU and the Rest of the World iPhone models.

WHY THE FRICK DID WE NEED THAT?!?

What the HECK are y'all thinking you're being "protected" from?

(Oh, you know why batteries weren't included with many products? It's called shelf-life and the risk of battery seal failure, causing corrosive acid to leach out of the battery and damage the device!!! Heck, the things are labeled "Batteries NOT included." What moron can't determine what that means, or didn't know that's part of the deal? Plus, the people who manufacture battery operated devices are NOT, surprise, surprise, manufacturers of batteries. So they have to pay to include batteries AND increase the cost of the device as a result— and the cost of the device to the consumer with batteries is going to be higher than the cost of the device and the batteries separately… unless low quality batteries are used.)

TANSTAAFL

Hey Parzizal,

How do you really feel about this? :)

kodiakblair, toy soldier don't come with batteries or need them or have sell by dates, and needing a EU person as a useless rep for a certification you are what?, doing exactly the same as we did before these crazy Brusels idiots did. We now need the world to do the same on EU products and l;et the block feel the pain of being a small part of a big world

I imagine that regulations such as this will ultimately lead to more nations seriously considering exit from the EU. I think that the EU had to happen just to confirm that individual nation states are better at regulating their own people.

@Wargamorium. Yes. There's a thread on Lead Adventure Forum about it.

link

@citizen sade – many thanks for that. The debate is most interesting. I am living inside the EU and rely on mail order from the UK for nearly all of my wargame supplies. Brexit was a terrible blow for gamers like me but this will finish it off completely if it becomes a major issue.

Yes, is has been bad for many UK gamers and gaming companies too. A real shame that an amicable arrangement could not have been reached.

Now we're outside the EU we get treated the same as everyone else, and that's what we asked for.

This regulation could be seen as an opportunity for current EU manufacturers and for start ups to increase production within the EU at the expense of the rest of the world.

Isn't that what @Parzival argued was the benefit of US tariffs? Sauce for the goose….

If tariff negotiations open up domestic production of goods, then the profitability of domestic goods increases— and this means that domestic laborers earn more money, as demand for labor to produce those domestic goods goes up. More money allows people to make luxury goods choices they previously could not make— such as buying toy soldiers.

A real shame that an amicable arrangement could not have been reached.

Since we turn down every olive branch the EU proffers it's not surprising…we don't seem to have learnt the lesson of the last 8 years. Yet.

Since we turn down every olive branch the EU proffers it's not surprising…we don't seem to have learnt the lesson of the last 8 years.

Really? Details please. The EU did all they could to make Brexit as difficult and damaging as possible.

DBDD

3d printing here they come.

Regards
Russ Dunaway

It's a scam to benefit the "brokers".
Like all entrenched bureaucracies throughout history, there are favorites "outside the system" to smooth the waters.
It should only add another week for an order to get from Britain to …. Frankfurt. And what's the added cost?

Hey, Americans. Don't get too smug. Incoming POTUS has a thing about tariffs. 🙄 Yes. On everything, those evil foreigners!

I just received an order from Britain that arrived within 5 days after being shipped. That was 2 days ahead of predicted.
Don't worry. Tariffs will bring shipping times, and costs into line.
It'll be my own darn fault for ordering from FOREIGN PEOPLE!

Here's one – EU offered limited Freedom to travel for under 30s

UK said no

Name one thing that the EU did that was unreasonable. Johnson had a deal (an oven ready one) and he got that perfect deal signed. So UK got everything it asked for.

So, I'm going to ask a simple question as a US customer of say Perry Miniature's, 1st Corps or others will this impact me in anyway?

I'm fine paying a bit more but I'm unsure how this will affect my purchases in the future, as I'm now retired…

the EU is an evil corrupt place, its alright to potificate if you never lived under its influence, the best think the UK did was leave. Do you know shock horror we can still travel to europe nobody moved it, and shock horror we can get buses and trams everything freely, thats called freedom of movement. Nothing has changed except the EU and us pay import, everyone in the world pays that no shock, the big issue that we gave away NI and it shouldnt have happened, the border moves to inc all Ireland or the EU grow up over borders like it has with other non euy countries. The UK keeps pandering to this jumped up collective even other countries, the UK said no yet the EU cant except it and tries to punish

Here's how Knuckleduster Miniatures, a fine American company if you like Cowboys and Indians handles it.
"EU and UK customers please order through Caliver Books to avoid high shipping costs, VAT, and import duties. Email your list to stuff@caliverbooks.com."

I buy any Perry or Foundry etc figures from American distributors.

@Andy—right now, none of this affects us US consumers buying from the UK or even the EU. And … the whispers are that the new administration is more likely to sign a favorable trade deal with the UK than apply any new tariffs, etc., like the administration intends to implement against certain other countries. So I am optimistic about the UK miniatures market in the future for us American customers.

What this boils down to, for me as an American anyway, is that it's usually preferable to buy from Foreign Johnnies at an in country distributor.
It seems like the EU is compelling that.
If it's too much for a small company to even try, that's a sign that….

I am fairly in the dark as to why this is suddenly (?) happening or why, but I *do* note that I have seen a lot of news posts and alerts from British minis companies about how they are not going to be able to feasibly sell to EU customers soon. This may not directly or immediately affect we US customers, but it is NOT good for our hobby if many of our most valued UK companies take a big financial hit from losing access to EU markets.

"Hey, Americans. Don't get too smug. Incoming POTUS has a thing about tariffs. 🙄 Yes. On everything, those evil foreigners!"

*NJH: John, Part of the problem is that too many folks in the USA think the exporting country pays the tariff. What can I say, we're getting dumber by the year. Breaks my heart.

It is NOT good for our hobby if many of our most valued UK companies take a big financial hit from losing access to EU markets

It's sad, boo hoo!, but the impact of losing 20 EU orders a year isn't really going to make a difference to some of us. The EU stopped being a major marketplace after it removed the 22euro threshold for charging VAT on imports, particularly in countries that charge a premium for collecting VAT on imported goods (I'm looking at you, Belgium). But at least, unlike the UK, the EU continued to allow the existing system of collecting VAT on import parcels through the mail service, rather than requiring anyone who sold into the country to register for VAT without exception for orders under £135.00 GBP

All this over an obsession with catching tax on £3.00 GBP items from Chinese companies on eBay and Amazon. Currently, the US and Australia do it far better by only worrying about import tax on sizeable orders.

For me, US customers have certainly stepped up their game when it comes to making up for the loss of the EU business. Only a universal 20% tariff could scupper that…

3d printing here they come.

At least one 3D printing company from Canada , has said they will no longer be shipping into the EU .

Only a universal 20% tariff could scupper that…

That will put an end to 3rd party sales of UK produced minis in the USA .

Don't forget there's already companies who won't ship to the EU or UK because of the VAT rules .

I am pretty sure John is referring to people printing 3d figures within the EU, not ordering printed figures from outside the EU.

I can see a flourishing "registered agent" industry coming into existence (does it already exist?) of dudes sitting alone in shabby offices in an EU country being the "responsible person" for dozens of exporters, taking a percentage of sales for acting as a figure head.

Don't forget there's already companies who won't ship to the EU or UK because of the VAT rules .

I believe I mentioned that VAT rule. :-)

I can see a flourishing "registered agent" industry coming into existence (does it already exist?) of dudes sitting alone in shabby offices in an EU country being the "responsible person" for dozens of exporters, taking a percentage of sales for acting as a figure head.

I'm thinking of using my daughter, who lives in the EU and is a Swedish citizen. Basically all she'll have to do is field any safety enquiries about sheets of paper printed with toner. I wouldn't burden her with issues about figures made from tin, antimony, cadmium, and silver, which is what is typically in a Pewter 92 formulation nowadays (92% tin, 8% stuff to make it flow). She can scam me all she wants. :-)

Thanks to John and Yogi for the explanations!!

Nice one Ian 😀

Now, before you needlessly scuttle your EU business, please read the documentation…

The draft document is here: link

The language of the draft states:

--

‘authorised representative' means any natural or legal person established within the
Union who has received a written mandate from a manufacturer to act on his or her
behalf in relation to specified tasks.

Article 9
Obligations of authorised representatives
1. A manufacturer may, by a written mandate, appoint an authorised representative.
2. An authorised representative shall perform the tasks specified in the mandate
received from the manufacturer. The mandate shall allow the authorised
representative to perform at least the following tasks:
(a) provide a market surveillance authority, upon its reasoned request, with all
information and documentation necessary to demonstrate the safety of the
product in an official language which can be understood by that authority;
(b) where they have a reason to believe that a product in question presents a risk,
inform the manufacturer;
(c) cooperate with the competent national authorities, at their request, on any
action taken to eliminate the risks posed by products covered by their mandate.

---

Notice the language:

"the manufacturer MAY (emphasis mine), by a written mandate, appoint an authorised representative…"

I don't see a REQUIREMENT to do so. Do you?

Presumably, the tasks which the authorized representative MAY perform can also be performed by the manufacturer himself.

Unless you can point to a specific sentence actually REQUIRING you to appoint a representative in the EU, please don't panic yet.

It means a written mandate is an allowable means of appointing a representative. Your emphasis relies on the interpretation of "may" as a vaguely permissive word to suggest a manufacturer has the option to appoint a safety representative. It doesn't.

There is an awful lot of reading to do with the Regulation, but the short fact sheet produced by the EU is quite clear: "Protecting consumers from dangerous products coming from outside the EU by requiring a responsible person in the EU with additional product safety related tasks, who will also act as a contact point for consumers and market surveillance authorities."

The related 2021 regulations for trading with Northern Ireland require the manufacturer or its appointed representative (importer, agent or individual) to have a physical address in the EU or NI, for example.

I like all these folks on LAF saying "there is very little risk."

Right up to the point where the legal fees, fines bankrupt you and they put in jail for a few years.

There is nothing to worry about.

"They are really after Temu and China."

Then why don't the rules say "Items imported from China?"

I think Trump is planning on targeted tariffs, say against countries that spy on us, steal our intellectual property, use the money we sent them to threaten our friends, allies, and build aircraft carriers, rather than nations like Japan or the UK who have been good allies and more reasonable trade partners.

Mike

I have no knowledge about this stuff, but, in my experience, EU consumer protections are generally there for good reasons. For example, our domestic airlines treat us like dirt (that's the polite way of putting it), but the EU protections apply to flights to and from the EU and it makes a big difference. They don't just cancel flights because they can and, when cancellations or delays are unavoidable, they have to look after you.

AussieAndy 27 Nov 2024 9:33 p.m. PST
I have no knowledge about this stuff, but, in my experience, EU consumer protections are generally there for good reasons. For example, our domestic airlines treat us like dirt (that's the polite way of putting it), but the EU protections apply to flights to and from the EU and it makes a big difference. They don't just cancel flights because they can and, when cancellations or delays are unavoidable, they have to look after you.

The Regulation is there for the very admirable reason that the EU wants every product available in the EU to be safe. How that is achieved is causing issues.

As for EU airline regulations, Ryanair is repeatedly criticised by customers for failing to pay compensation when it is due. And my own family's experience with British Airways is that two years after bumping my daughter off a flight to the next day, they still haven't paid the appropriate compensation. But I wouldn't take that as an indication that a small business could safely ignore EU law. 🙂

Fighting 15s, I've never flown Ryanair and one flight across the Atlantic on BA was enough for me.

AussieAndy 28 Nov 2024 1:56 a.m. PST
Fighting 15s, I've never flown Ryanair and one flight across the Atlantic on BA was enough for me.

I can only speak from the experience of flights to Gothenburg, but they once upon a time on a typically heavy landing, broadcast a message preceded by a fanfare along the lines of "Another successful landing with Ryanair." Such comforting words! 🤣 They are a super-budget airline, notorious for charging for extras (a plane, a seat, use of a toilet, air…) and for avoiding paying any fines levied on them. None the less we use them because they're cheap…

BA is simply awful – if I can then I fly Lufthansa or Air France in preference. Long Haul New Zealand Air / Scandinavian.

the regulation did earlier say in NI for a rep but never enforced and the HMRC guide gives no advice, similair to the new gpsr regs, no advice on hoow to implement proof of if its a 100% requirement. The law is unenfoceable and how do they stop personal 2nd hand sales.
As for "the its to stop Temu and other imports from China" it is an open secret that these chinese companies are the target, but putting into a document creates an international incident if not trade war – have you given such thought Bunkermeister (MIke), the UK and EU generally have a policy of free trade, protection isnt something that is about, but with the current manufacture base being eroded in the west I think this will become a bigger thing

how do they stop personal 2nd hand sales

The Regulation does not affect private sales.

The legislation is aimed at certain Chinese megastores that copy products, then sell them for pennies – it's these products that are often unsafe, or at least of such poor quality that are barely fit for purpose. Perfectly reasonable legislation IMO.

Unfortunately, as we in the UK chose to leave the EU, we are now liable to such legislation, and the consequential bureaucratic hurdles. Sunlit uplands, apparently.

Perhaps once it has come into effect, things will settle down, once everyone has worked out how to make it work. Some UK based manufacturers have already reversed their decision, now that they have an agent.

Part of the problem is that some Americans don't get that a tariff is a BARGAINING CHIP.

You use a tariff to get the other nation to offer favorable trade concessions. Because while it's true that consumers pay the cost of the tariff, a high enough tariff causes consumers to buy something else— these aren't necessities, they are luxuries. When that happens, the exporting nations lose the income they get from the market nation. Since they don't want to lose that income, they come to the negotiation table (sometimes for Thanksgiving, apparently) to try and offer a deal which the tariff-setting leader will accept and thus not impose the tariff. And lo and behold, it works. The target nation offers a better deal, and the tariff doesn't ever happen.

"Next!"

Unfortunately, I can't comply with the legislation, so I'll be ceasing sales from the BigRedBatShop into the EU and Northern Ireland from Monday.