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This looks to have nothing to do with Brexit and everything to do with something that's been in the offing for years.

HS3202 is defined by HMRC as
"Synthetic organic tanning substances; inorganic tanning substances; tanning preparations, whether or not containing natural tanning substances; enzymatic preparations for pre-tanning"

The EU as a whole has been talking about banning these for some time, here's an article discussing it from 2017

https://www.chemistryworld.com/news/toxic-tattoo-inks-face-eu-chemicals-agency-controls/3008198.article

So it looks like mini paints have been caught in the fallout from something completely unrelated to both their intended use and Brexit.

No doubt it'll get corrected in about 5 years once the EU machine has ground its way through the objections.

But why just Germany and Spain? Why not the whole EU?

most courier service have one or two big hubs in Europe and ship by air, so most likely it is Spain and Germany because the logistic hubs are there (and I know everything I order is moved to Germany first before it got back here although the plane lands in my country) and the courier does not want to get into risk and ship things that are forbidden since years (we have a ban on liquids by air mail for ~10 years now) but now are easy to spot because of the more strict controls

 Mad Doc Grotsnik wrote:
This may impact Vallejo too, depending on what exactly is banned.

The quoted bit in the OP suggests it’s the dyes and pigments involved, and says you cannot ship into Spain or Germany.

If these are common pigments across ranges, it could mean even Vallejo won’t be able to ship within Spain.

The paper behind this would probably clear it up, if anyone has the foggiest of where to start looking.

it is not one pigment, those codes mean all pigments and similar, if it would be general ban you would not be able to import printer supply to Germany

So does this mean lots of manufacturers paints are no longer able to be sold there now? Or is it just importing like this?

OP does say paints, without specifying a certain range.

 Jidmah wrote:
Knowing how these kind of agencies operate in Germany, it's probably either someone forgetting to add these numbers to the right list or some odd overlap where paint is equated with fried calamari because of a law with roots in the colonial age.

Slightly off-topic. While I realize you are being sarcastic, does that sort of thing crop up now and then in Germany? Some obscure law from Barbarossa's day is suddenly applicable again, and until the legislature takes it off the books, the effected parties have to bend over backwards to comply.

Back in university, there was a historical example of peasants in one of the Germanies (this was in Martin Luther's time period) going to their lord's private lake or pond, and eating all his fish, raw. This was a protest against his policies, and there was some odd loophole if they ate the fish raw, it wasn't poaching, and so he did not have a legal reason to punish them. {These memories are 30 years old now, so I may very well be wrong, and I don't have better sources.}

modern German law is rather new compared to others and the oldest parts go back to 1900
there are no ancient loopholes like that and while mistakes with HS codes happens from time to time, nothing of that kind that a whole range of products would be banned from import

 Mad Doc Grotsnik wrote:
OP does say paints, without specifying a certain range.

OP says HS codes 3202 - 3215, this is everything, not only paints, or a certain brand/range, but everything from to powdered pigments to make paints up to printer inks

 Mentlegen324 wrote:
So does this mean lots of manufacturers paints are no longer able to be sold there now? Or is it just importing like this?

this only means that EU citizens cannot order paints from Wayland as their courier service does not ship them any more, the same way as you cannot order Spray Cans in GB online shops because no one is shipping via air freight them to the EU for safety reasons

 kodos wrote:
modern German law is rather new compared to others and the oldest parts go back to 1900

Well, 1900 will be the Civil Code (BGB), which is a true work of art. The Commercial Code (HGB) is older. As is some more obscure stuff, I think. But your point is correct: Germany‘s laws are (almost) entirely codified, and it is known where to find them. So unfortunately, no funky medieval get-out-of-jail free cards if you know a secret ritual or something like that. But if you want to have a laugh (and if that‘s your thing), look up the BGB‘s detailed rules on the do‘s and don‘ts of following and recovering your escaped swarm of bees (to be found in sections 961-964). I think nobody had the heart to delete this.

And re my comment on titanium dioxide: it‘s widely used, also as a food colorant. Think of most processed white foods, like sweets etc. Health concerns are only linked to inhaling it in powdered form. Your TiO2 intake from licking paintbrushes will pale (haha) compared to what you get from eating. So don‘t panic (except your work is in powder-coating and you don‘t use protection).

TheGoodGerman wrote:
So don‘t panic (except your work is in powder-coating and you don‘t use protection).

well everyone is in panic in my company because now we need to get special waste treatment for the fine TiO2 dust (like empty bottles that now need to be washed before you can throw them away) but nothing about a ban in import/export from or to Germany

 kodos wrote:

TheGoodGerman wrote:
So don‘t panic (except your work is in powder-coating and you don‘t use protection).

well everyone is in panic in my company because now we need to get special waste treatment for the fine TiO2 dust (like empty bottles that now need to be washed before you can throw them away) but nothing about a ban in import/export from or to Germany

Yeah, see. At my work, we make products that have minimal amounts of TiO2 and then the whole industry became super-cautious and effectively banned TiO2 altogether. Not strictly required by law and the connected health risk is about zero I think, but you also don‘t want to be the last one using it.

White spray primer might be at risk though.

I don’t know if it’s related but I noticed that the label on newer Citadel paints I bought give the Dublin GW store as their “representative”. I have no knowledge of commercial law so someone else can explain it to me.

 Horla wrote:
I don’t know if it’s related but I noticed that the label on newer Citadel paints I bought give the Dublin GW store as their “representative”. I have no knowledge of commercial law so someone else can explain it to me.

Probably because they have to give an EU address for product liability claims etc.

Northern Ireland is affected, though I am not sure if it is the same mess or just a similar one.
I was told that the couriers will no longer carry acrylic paint from the mainland but I am not sure how seriously to take this or if I misunderstood what I was told but Vallejo was specifically mentioned.
Spray paints were previously a problem, you could not send them by post but some couriers would take them.

 NAVARRO wrote:

TheGoodGerman wrote:
To me this looks as if someone might have overreacted after seeing the new rules about titanium dioxide, which among other things is a common pigment (and has been re-assessed to be potentially carcinogetic if inhaled as dust). Or something like that.

If thats the case these items should be banned... Some people lick brushes.

Heavy metal pigments such as cadmium and cobalt are not banned, and surely much worse for brush-lickers than something that is dangerous when inhaled.

 kodos wrote:
modern German law is rather new compared to others and the oldest parts go back to 1900

*cough* Reinheitsgebot *cough* You were saying?

DDR had new, modern law, BRD has a mess with some modern elements and some medieval nonsense (hell, within my lifetime a woman in Germany was sent to prison for 'blasphemy', aka saying 'god is stupid' - and said law is still on the books even though people pretend to not remember it's there). Fun fact - democracy aside, for women and minorities German reunification meant massive regress in rights (part rarely mentioned in schools these days because eastern block bad) to the point east German woman in 70s had more decision making power about herself, medical treatments, body, and legal rights than her granddaughter does now. Same thing is true about rest of the Warsaw Pact, BTW, but Germany is particularly bad example because DDR law was really progressive and ahead of its time in places.

Though I suppose paints would be covered under commercial law, which in Germany is constantly updated and kept current because profits are important, unlike pesky human laws and these uppity disadvantaged forgetting their place

 Irbis wrote:
*cough* Reinheitsgebot *cough* You were saying?

The Reinheitsgebot became a law in 1918.

DDR had new, modern law, BRD has a mess with some modern elements and some medieval nonsense (hell, within my lifetime a woman in Germany was sent to prison for 'blasphemy', aka saying 'god is stupid' - and said law is still on the books even though people pretend to not remember it's there).

That's not how that law works. You can get report someone for insulting your religion, just like you can report someone for insulting you. Whether that actually amounts to anything depends on the circumstances, but saying "your god is stupid" will definitely not amount to anything.

German woman in 70s had more decision making power about herself, medical treatments, body, and legal rights than her granddaughter does now.

I am very curious to know what rights a German woman is allegedly missing right now that they had in the DDR in the 70s.

 Irbis wrote:
Fun fact - democracy aside, for women and minorities German reunification meant massive regress in rights (part rarely mentioned in schools these days because eastern block bad)

I'm glad to inform you that this is absolutely wrong. When you talk about the DDR and socialist states in school, especially gender equality is discussed as one of the big advantages of their systems.
In fact, I had to write a graded essay on why gender equality was so important in the context of Lenin's and Marx' teachings, and why the west didn't adapt (spoiler: because eastern block bad, primarily driven by the USA).

Recently, there has been a lot of misinformation about what is and what is not taught in German schools - essentially whenever someone claims that something is being covered up, not taught or falsified in German teachings you can safely assume it's a lie. These rumors usually have their origin in far right anti-German groups on social media and rarely have any resemblance of truth.

Germany committed one of, if not the worst crimes in all of history, there is literally zero reason to lie about anything else because nothing even remotely compares. If things are skipped it's usually because they are historically irrelevant, but this especially doesn't apply to any parts of WW2 or the cold war. From 1871 onwards you basically go through each year one by one.

 Irbis wrote:

 kodos wrote:
modern German law is rather new compared to others and the oldest parts go back to 1900

*cough* Reinheitsgebot *cough* You were saying?

DDR had new, modern law, BRD has a mess with some modern elements and some medieval nonsense (hell, within my lifetime a woman in Germany was sent to prison for 'blasphemy', aka saying 'god is stupid' - and said law is still on the books even though people pretend to not remember it's there)

fun fact, both of those are modern "new" laws and not leftovers from medieval times
the Reinheitsgebot was not a thing (or better said a German law) until 1906 and prior that it was only in Bavaria after ~1870 (prior that there was no such law or tradition, except for a medieval variation of modern Quality Management which just made sure what you can sell as beer or wine and was not a thing any more after ~1600)

and the Blasphemy Law is from 1969, as there a more general law replaced the old Prussian law from 1850

modern German law is some kind of ClusterF* but for different reason and not because there is some medieval nonsense, as there is none everything there is modern law by today's standards (no matter how stupid it is)


Removed - off-topic politics have NO place here.

Hate to uh... you know, interrupt the discussion and all. But how is abortion related to importing paints exactly?

Back on topic right now please.

 Kid_Kyoto wrote:
But why just Germany and Spain? Why not the whole EU?

Legislation takes time to catch up, Germans are early adopters and implement dictat more rapidly. Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.


Automatically Appended Next Post:

 Horla wrote:
I don’t know if it’s related but I noticed that the label on newer Citadel paints I bought give the Dublin GW store as their “representative”. I have no knowledge of commercial law so someone else can explain it to me.

Irish market labelling? It would be easy to customise paint labels as it doesnt interfere with the actual product.

 Orlanth wrote:
Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.

Some companies do. The politicians that have implemented this don't even know they exist. I can affirm with total certainty that this has nothing to do at all with any attempt at "killing the UK based miniatures paint market".

They would have to be at least barely competent to pull that off, and they're not.

Seriously, we're talking about a government that's actually campaigning against jamón serrano and beef, some of our strongest exports. There is not enough facepalm.

 Orlanth wrote:

 Kid_Kyoto wrote:
But why just Germany and Spain? Why not the whole EU?

Legislation takes time to catch up, Germans are early adopters and implement dictat more rapidly. Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.


Automatically Appended Next Post:

 Horla wrote:
I don’t know if it’s related but I noticed that the label on newer Citadel paints I bought give the Dublin GW store as their “representative”. I have no knowledge of commercial law so someone else can explain it to me.

Irish market labelling? It would be easy to customise paint labels as it doesnt interfere with the actual product.

Germans are early adopters of dictat? Stop reading British tabloids please. You and Irbis seem to know the German legal system REALLY well, it seems…

Back on topic, I doubt that GW has multiple versions of their paint pots for the EU‘s Single Market. So they obviously chose Ireland as the leading branch for handling paints within the EU.

 Albertorius wrote:

 Orlanth wrote:
Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.

Some companies do. The politicians that have implemented this don't even know they exist. I can affirm with total certainty that this has nothing to do at all with any attempt at "killing the UK based miniatures paint market".

They would have to be at least barely competent to pull that off, and they're not.

I thought about that, but don't believe it is the case. Wargaming is not a major market, but it is a notable market. Once legislators look into who makes what paths become apparent.
Legislators will be asked to look at the new EU dictat, see how it effects Spain then act, ignore or stall.

 Orlanth wrote:

 Albertorius wrote:

 Orlanth wrote:
Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.

Some companies do. The politicians that have implemented this don't even know they exist. I can affirm with total certainty that this has nothing to do at all with any attempt at "killing the UK based miniatures paint market".

They would have to be at least barely competent to pull that off, and they're not.

I thought about that, but don't believe it is the case. Wargaming is not a major market, but it is a notable market. Once legislators look into who makes what paths become apparent.
Legislators will be asked to look at the new EU dictat, see how it effects Spain then act, ignore or stall.

Seriously, it's not the case. I mean, you might continue believing that it is, but all evidence is against that belief.

Wargaming migh feel like a notable market here, for us, but... it's really not. People might even know Warhammer, and most stiil get flumoxed when they learn that you actually have to assemble and paint the fethers ^^.

Also, and more important... this affects paints, but also a wide, wide range of other stuff. Thinking that this legislation has been made to specifically have an effect on miniatures paint is... sorry, deluded. Kinda like saying that the "sausage war" is about sausages... technically true, but hugely misleading and dismissing.

But hey, speculating about stuff is fun, so speculate away I guess xD.

Good to see our pallid gamer culture being protected, can't have our lockdown indoor anti-tans undone by mucky make up / tanning chemicals

 Orlanth wrote:

 Albertorius wrote:

 Orlanth wrote:
Spain are normally a lot slower, but in this instance has a vested interest in killing the UK based miniatures paint market.

Some companies do. The politicians that have implemented this don't even know they exist. I can affirm with total certainty that this has nothing to do at all with any attempt at "killing the UK based miniatures paint market".

They would have to be at least barely competent to pull that off, and they're not.

I thought about that, but don't believe it is the case. Wargaming is not a major market, but it is a notable market. Once legislators look into who makes what paths become apparent.
Legislators will be asked to look at the new EU dictat, see how it effects Spain then act, ignore or stall.

„EU dictat“…

But you are also wrong. I‘m pretty sure there is not a single person in said legislative body who would even know what you‘re talking about when you mention „wargaming paints“. And you’re also ignoring the fact that the customs numbers mentioned at the start of this discussion are not specifically for wargaming paints at all.

 Kid_Kyoto wrote:
But why just Germany and Spain? Why not the whole EU?

Going by stuff that's been popping up in recent months, it's most likely because previously the UK would have been covered by EU regulations on ingredients for those products, allowing an existing restriction in those countries to be waived, and now that they're not part of the EU they run afoul of a blanket ban. This has been an issue for various products.

 insaniak wrote:

 Kid_Kyoto wrote:
But why just Germany and Spain? Why not the whole EU?

Going by stuff that's been popping up in recent months, it's most likely because previously the UK would have been covered by EU regulations on ingredients for those products, allowing an existing restriction in those countries to be waived, and now that they're not part of the EU they run afoul of a blanket ban. This has been an issue for various products.

That sounds like the most plausible explanation; a resurgence of existing restrictions would explain why it’s suddenly happened without apparent changes in EU regulations and is only affecting limited locations. The only other thing I could think of is that, given the very stretched supply chains everywhere at the moment, courier firms might be looking to focus on easier to deliver stuff. If there’s a type of product that requires significantly more paperwork and processing, they might just kick it onto a restricted list than deal with the impact on deliveries.

Funny enough i've bought mixers for alcoholic drinks in California that contain titanium dioxide, i've literally drank that stuff. It gives a white pigment to pina colada mixers.