Exporting Cosmetics to Spain after Brexit - Help please?

Discussion in 'International Business' started by lordgaz, Oct 7, 2020.

  1. lordgaz

    lordgaz UKBF Newcomer Free Member

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    Hi All -
    As part of my business, I currently export promotional cosmetics to Spain on a reasonably regular basis.
    After 31st December, the UK is no longer in the EU, and I am trying to establish what requirements need to be met to continue to export to Spain.

    (there are many changes, eg - I will need to appoint what is known as a responsible person in the UK to enter the cosmetics onto the EU Cosmetic Notification portal, and hold the product information file with all of the safety data) - but my main query is if Spain will require a Sanitation Licence/Certificate to allow a product from outside of the EU to be allowed onto the market in Spain. Currently, we do not need one as the products have been coming to Spain from within the EU - but soon the UK will be treated the same as if the products have been coming from China or USA (for example) and I know that sending goods direct from China to Spain have required a Sanitation cerificate.

    Does anyone have any knowledge of how the procedure is going to be after Brexit (and if so, how to obtain the correct licence/certificates)

    Many thanks
    Posted: Oct 7, 2020 By: lordgaz Member since: Oct 7, 2020
  2. Red Wood

    Red Wood UKBF Regular Free Member

    491 54
    With any product that has 3rd party approvals, I don't see why those approvals become invalid after the transition period. Currently your products are approved to the correct standards it seems, therefore there is no reason they should not be accepted post transition.

    As an example, we supply products that require multi approvals per item. Currently they are approved to homogeneous EU standards which are acceptable in the EU market (CE marked, CPR rated etc and various other tests) these products will still be valid after transition period all things being equal.

    Ironically it's the UK market that's going to give us a headache with the transition to the new UKCA mark and various other changes.
    Posted: Oct 7, 2020 By: Red Wood Member since: Jan 14, 2014
  3. Mr D

    Mr D UKBF Legend Free Member

    24,815 3,025
    Would you not have to meet current Spanish import requirements?
    Unless they happen to change them or we get a different deal than is known about.
    Posted: Oct 7, 2020 By: Mr D Member since: Feb 12, 2017
  4. The Byre

    The Byre UKBF Legend Full Member

    10,346 4,324
    I wish I could give you an answer, but unfortunately, we have idiots in power who issue 28 proclamations every week, some contradicting the others, and the reality is that we do not know. I have someone watching this almost full-time and she knows less and less with every one of the government's new idiotic statements making less sense each time.

    I hope this helps!
    Posted: Oct 7, 2020 By: The Byre Member since: Aug 13, 2013
  5. John Hemming

    John Hemming UKBF Regular Full Member

    390 62
    What you have to watch is a question of which body approved the cosmetics. If it is a body in the UK then its authorisation to give such authorisation will most likely disappear. If you have the cosmetics approved by an organisation in Spain that is more likely to survive, but noone really knows.
    Posted: Oct 7, 2020 By: John Hemming Member since: May 23, 2019
  6. lordgaz

    lordgaz UKBF Newcomer Free Member

    4 0
    Thank you for the replies - There are many changes which I can cope with (eg - once we leave officially, all cosmetic products need to be (re_)-registered on the Cosmetics Notification Portal by a "Responsible Person" allocated within the EU, all Safety reports need to have come from an assessor with a recognised EU or equivalent qualification, all reports need to be in the language of of the member state receiving the products (or I think in the language of the Responsible person) - What I am after is to find out if I need/how to get a Sanitary Certification from the Spanish government before they will allow the product to enter the EU (it will enter in France, but I will need I think? to make the clearance with Spain? (I don't know this for sure, but as the client will be paying the VAT on entry in to the EU, and the commodity code will fanfare "cosmetics" I cannot risk sending anything until I know the process - Maybe we will know more after the 15th October when we find out if a deal is possible - Until now, I have never needed sanitary certification as the goods were coming from within the EU
    Posted: Oct 7, 2020 By: lordgaz Member since: Oct 7, 2020
  7. lordgaz

    lordgaz UKBF Newcomer Free Member

    4 0
    Current requirements are different as the goods are coming from with in the EU currently, and there is free movement - but after 31st Dec, we become the same as China or USA, which requires more documentation / licence / Certificate - I am struggling to get any reply from Spain Government - so hope someone has experience.
    Posted: Oct 7, 2020 By: lordgaz Member since: Oct 7, 2020
  8. Mr D

    Mr D UKBF Legend Free Member

    24,815 3,025
    Sorry. I meant current requirement for import into Spain from outside the EU. Which is the current default position for us in a few months.
    You are unlikely to get a solid clarification from UK government any time soon. Probably because they themselves do not know.

    Import from outside the EU is not too bad.
    Posted: Oct 7, 2020 By: Mr D Member since: Feb 12, 2017
  9. lordgaz

    lordgaz UKBF Newcomer Free Member

    4 0
    Thank you for the reply - Yes, I understand - I am trying to find out what the requirements are for Spain for non-EU - it is not so simple unfortunately (Spain, Italy, and I think Switzerland have different procedures to the rest of EU when importing Cosmetics)
    Posted: Oct 7, 2020 By: lordgaz Member since: Oct 7, 2020