There was a “final” meeting of representatives in Geneva on 3rd and 4th December. It was confirmed that Sealing Devices were on the A list of products to be added to the EGA. This appears a positive position.

However serious differences exist between Europe and China, and the US position has become unclear following the election of president elect Trump, who is not a supporter of environmental trade agreements.

So there appears to be a major political stand-off and Trade Ministers are still grappling with a solution, without any clear outcome at this moment in time.

HS Codes

As part of the EGA it was recognised that both ESA and FSA members were using differing HS Codes, and as the EGA is to specify products by HS code, it was agreed a working group of members of both organisations would consider this issue with a view to having an agreed universal standard for each product HS code.

The group has met a couple of times and good progress has been made on what the correct codes should actually be. We have general agreement on most HS codes already but there are still one or two where opinions differ. The code for AF sheet and cut gaskets is perhaps the one with most disagreement.

The basic rule is that if a gasket is made of more than one base material (like AF sheet) then the product is classified by the material that gives it its “essential character”. For AF sheet is this Rubber (chapter 40), or Mineral fillers (chapter 68)? In the case where the essential characteristic is equally established then the higher chapter number is the one to be used. Members use both 6815 and 4016 (and 4008) for AF sheet, and sometimes different divisions within the same global organisation use different codes!

The next meeting is planned for 23rd January, where final agreement may be found, and members circulated with the working group’s recommendations.

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David Mitchell, Standard and Legislation Director