Labelling Advice Example 2
processes that may confer originating status to the goods. The ceramics industry in the UK is a really good example of this. A while ago a rule was passed to protect the ceramics industry in Stoke in particular. To be able to label ceramics as made in the UK the first firing has to be done in Stoke-on-Trent. This is what is known as a specific production process. Unfortunately, Kate says that it is not this simple with other product types. The final rule, change of tariff classification, refers to when a product is ‘substantially changed’ to the point that it requires a different classification. Of the three methods this is generally the one used when exporting or importing goods. One of the clearest examples of this is raw material versus finished product. If you take leather for example, when you turn this leather into a bag its product classification then becomes a leather bag because it has a different end use. Before it is the skin of a cow, afterwards it is something used to carry items. But Kate warns, it is not always this simple.
Substantial changes To further understand product classification and what counts as a substantial change to a product, many manufacturers in the UK follow the Trading Standards Act 1968, which states that goods shall be deemed to have been manufactured or produced in the country in which they last underwent a treatment or process resulting in substantial change. Until there is a new law or a new act, this is the one that is adhered to.
An example of this is a hi-top van. Even if the company is not British-owned and the parts are imported from overseas, as long as the van is assembled in the UK and sprayed and finished in the UK, it can be labelled as made in the UK. This is because the last substantial change took place in the UK. However, a printed mug where the clay comes from overseas and the first firing is done overseas, even if the transfer is applied in the UK, this cannot be labelled as made in the UK as the last substantial change happened overseas. Kate says that the example that she most gets asked about and which is particularly relevant to the printwear market is the printed T shirt. When can a printed T shirt be labelled as made in the UK? If the fabric is knitted overseas and the cloth is cut and stitched in China, even though the T shirt has been printed and the label has been sewn on in the UK, this T shirt cannot be labelled as made in the UK. This is because the substantial change took place in China.
If the cotton for a simple printed dress is grown, spun and woven in India, then taken to Turkey where it is dyed and then printed, before being transported to London where it is then stitched in a factory, this can also be labelled as made in the UK as the last substantial change took place within the UK
So, what does the EU say about rules of origin? As the UK is still within the EU at present, these are the rules that manufacturers within the UK follow. The EU’s product classification has three main criteria; the first being the ‘value added’ rule, the second being the ‘specific operations’ rule and the third being the ‘change of tariff classification’. If your product fits one of them, then that defines where your country of origin is. Value added is understood to be the ex-works price minus the customs value of each of the materials incorporated which originate in the other countries. Put simply it takes the cost of the materials that you import and then how much value you add on them in the UK. Generally, this is seen as about 40-50%, so you need to add on at least half of the value in the country that you want to label the products as. The specific origins rule generally dictates specific production
www.printwearandpromotion.co.uk
The main question to ask yourself before establishing if you can label your product as made in the UK is ‘did my product have the same end use before this process was carried out?’. By following the rules of origin, you won’t go far wrong.
●This content has been taken from a podcast hosted by Kate Hills, founder of Make it British. To listen to the podcast in full visit
www.makeitbritish.co.uk
What can’t be labelled as made in the UK?
It is a well-known fact that people will pay a premium for products that are made in the UK. But don’t fall into the trap of stamping your product as such by remembering that the following attributes alone mean you cannot label your products as made in the UK.
●Designed in the UK. ●Developed in the UK. ●Whether the company is British-owned. ●Labels, packaging or decoration.
November 2020 |65 |
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72
