Awareness letter to MP’s, MEP’s and other elected representatives

Letter to MP’s – text below – this text is copyright free, meaning that it can freely be used by anyone. If you change anything that’s up to you – I will be delivering copies of this for each MP and other elected representatives to the House mail room early next week:

Urgent appeal for help for small businesses in the UK!

Over 180 small craft businesses in the UK wiped out by European Regulations, and these are only the ones we know about

Disaster for UK prosperity – It’s likely that small scale producers in your constituency are affected

Cosmetics Products Safety Regulations

An update to the above regulations became enforceable on 17th July 2013. At no time have self-employed or SME craft soap and toiletry makers ever been formally consulted about the effect that this regulatory update would have on their businesses. Concerns raised by the Guild leading up to 17th July to both BIS and EU Commission correspondents were essentially disregarded. Since then communications to both BIS and a previous EU Commission correspondent bringing to their attention some figures, proving that our earlier concerns were in fact valid, have also been ignored.

In July 2013 the Guild had a membership of 373 compliant crafters with a steady stream of new enquiries every week. In order to join the Guild members have to provide evidence that they are in compliance with the cosmetics products safety regulations.

Since then, following the amended regulations coming into force, we have seen membership drop to 184 (at end Sept 2013), this means that unless we receive any more overdue updates we are set to lose or have already lost over 180 members. These figures reflect Guild membership only, there are likely to be many hundreds more similarly affected compliant crafters UK wide that we do not know about.

180 plus small businesses forced to cease trading is a massacre representing a lot of pain and misery. Not only are those affected directly but the knock on effects through loss of business to their former suppliers, loss of their contribution to the local economy and so on are bound to be significant. Training providers have also suffered a loss of business. When all that everyone reads when they go online is about people going out of business and how tough it’s been to stay in business who can blame people for not wanting to train to set up a craft business? Anecdotal evidence indicates that this adverse trend is repeated throughout the industry, the Guild represents a relatively small number of compliant crafters. Our face book page for example has often attracted up to 8000 plus views of posts relating to the legislation, which indicates a high level of interest.

Not to mention the potential drain on public funds as a certain number of those members who have ceased trading will live in remote areas where opportunities for employment are not so plentiful. I’m particularly concerned that a number of people with disabilities, who can’t to a ‘regular’ job, have lost their businesses. This when our own UK Government are striving to keep disabled people gainfully employed while tightening the criteria that have to be met before they qualify for the help that they need.

Not a single one of our members has a problem meeting standards, however craft production is being treated on a par with large scale production line and plant production when craft is, and deserves to be, treated as a unique sub-division of the cosmetics industry. Why? Because as a rule craft toiletry makers work with ingredients that have a proven and safe history of use in cosmetics.

The approach adopted in implementing these regulations flies in the face of EU stated position of wishing to reduce the burden of legislation on SME’s as it recognises the contribution that such business makes to the economy and accepts that they are disproportionately affected by having to meet conditions imposed by regulation etc. An example of such from 2007:

http://www.esba-europe.org/sub-sub-section.asp?SectionID=5&SubSectionID=24&SubSubSectionID=191

What are we hoping to achieve?

That craft producers be consulted going forward and their unique position within the industry be taken into consideration – this does not happen at the moment

That proper reporting systems be put in place so that Crafters do not have to ‘stumble’ across information on changes to their industry sector, which is currently the case

That an amendment/amendments to the existing regulations be considered, taking into account the types of materials that craft producers tend to work with. Being treated on a par with large manufacturers who use chemicals in industrial process that crafters do not use is inherently unfair and makes it very difficult for crafters to develop their businesses