Anyone who thinks that the juice manufacturers have got a simple task to stay in business are missing most of the picture. I have read on here people stating that 'reputable' manufacturers will be fine and I can assure you that most will not be.
Food hygeine rated preparation areas, HEPA filtration (in our case ULPA) and all the trimmings to ensure clean and safe manufacture aren't the problem. The main one being the reliance on flavour houses to supply the CAS numbers needed to notify the MHRA of ingredients - most won't play ball. Now the logical thing here would be for the government to accept flavour brand and names as part of notification - if they are already regulating the flavouring industry (if not, why not) then they will already have this data so why put the burden of information on manufacturers who cannot get the required information? It's counter-productive and incredibly restrictive.
Places like Capella are outright refusing to play ball with those that use them, smaller houses won't be able to supply for fear of releasing their unique chemical recipe (which this is asking for)
Having just sunk over £25k on a new facility (and counting, the cleanroom still needs another £5k+ spending to be completed) we are still left in the balance, we have the reputation for quality, we have the processes for clean manufacture, we have the capacity to supply the 13 countries that Colonel Boom's and Fallstreak ships to. What we don't have is a reasonable roadmap and costing for placing our products into the system for the required tests - this all needs to be finalised by 19th November and paid for in advance too.
We have figures from £60k to £500k+ being given to us - just for testing and notification costs. Both figures need to be in the bank and clear before we pay all the rest of our operating costs and even for a small to medium sized established company this is a lot of outlay.
If anyone thinks that TPD will stop disreputable sellers, bedroom mixers who sell homebrew through Fb they are wrong - they will carry on regardless without investing anywhere close to what we, Manabush et-al have done and yet it is we that will bear the full force of regulation to potentially put us out of business.
For the record, food hygiene rating on preparation and inspection for manufacturing along with notification to MHRA would have been welcomed actually - we already have GC-MS testing done to assure quality and consistency. It's the completely invented emissions and toxicology testing imposed that's the big issue, along with the requirement to supply detailed CAS breakdown on products we don't manufacture nor are covered in legislation to require their disclosure.
