March 16, 2004

UK Soap Makers Take Notice, EU Regulations Change

Reported by Rose, "As some of you may already know, here has been a change in the regulations governing the Pollution, Prevention & Control Regulations (PPC) which implement the European Integrated Pollution, Prevention & Control Directive (IPPC) and incorporate the current UK Integrated Pollution Control Regulations (IPC).

This covers, amongst many other things, the production of soap and surfactants. Until recently the IPC regulations had a 'triviality' clause which covered us, which is why few of us will have even heard of this law.
This clause has now been dropped, meaning that no matter how small a soap business we may have, we will now face the same audits as Cussons et al. The estimated cost of this will be between £40,000 and £60,000 in the first instance, and between £6000 and £60,000 per year, every year after that. This will be the administration charges; it will make no difference if you can demonstrate that you produce no waste at all, let alone any potential pollutants. It will make no difference if you only make a dozen bars annually for the local school Christmas Fair or if you make a ton of soap a day.

The legislation will be policed by the Environment Agency (EA); it has nothing to do with Cosmetics Legislation, and will cover anyone making soap whether at home or in premises, whether compliant with any of the other legislations or not. Please note that it will not cover melt and pour; only those of us who make soap from oils and alkali.

It will, simply, put virtually every single handmade soaper in the UK out of business, and probably many small commercial soapmakers out of business too, because of the charges involved.

As the UK regulations stem from an EC Directive, the only way the UK will change it's stance is if the European laws are changed. The UKCPI (UK Cleaning Products Industry association) have agreed to go to Europe and try to do this on our behalf, and on behalf of all the smaller soapmaking concerns in the UK.

The Commission have indicated that they will review the implementation of the Directive and this will be our best chance at having some sort of exemption or threshold taken up. The UKCPI will attempt to demonstrate that the 'cottage industry' of handmade soap will be wiped out by the costs, and to further show the effect of the resultant loss of jobs and of trade for something that has a minimal environmental impact.

The UKCPI needs urgently two pieces of information. Firstly exactly how many people or businesses will be affected (that is, how many of us making handmade soap there are) and what sort of turnover do those people or businesses make (this will be shown up against the costs we would face, and give an indication of the loss in trade to the country).

I have set up a poll group, the UKSoapmakersPoll, and I ask you all, even if you have only sold one bar of soap to please go and vote in the poll. It will ask you to vote for one of four options; turnover up to £10,000, up to £50,000, up to £50,000 or up to £3 million. You will need to join the Poll to vote; there is no other option with Yahoogroups, but it has no membership list whatsoever, and so will be as anonymous as I can make it. There are no logs or records generated by a yahoo group for poll votes, only the running votes are recorded. You may unsubscribe immediately after voting; when the poll is concluded, in a couple of weeks or so, I will post the results on the home page so that it can be seen without needing to rejoin.

The results will be passed on to the UKCPI. It is vital for us all to go and vote, so please do! I also ask that if any of you know a soapmaker who is not a member of this list and has internet access, to ask them to vote. It would also help if this poll can be broadcast on any other lists or forums where there may be UK soapmakers; I am on very few these days, so if you are a member of such a list please, please ask the list mums permission and post about this!

To discuss this further amongst other UK Soap Makers: UKSOAPING Group

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