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4 February 2016 - Sussex Police 'fees & victuals' issue PDF Print E-mail

On 22 November 2014 wrote to Sussex Police concerning Guidance to Pedlars inaccuracies.

Correspondence updated 4 February 2016:


Dear Mr Robinson

Procedures re Application for a Pedlars Certificate - Sussex Police

Thank you for your reply.

We await a response from your Licensing Sergeant.

Guidance Notes - Inaccuracies

1 Incorrect Fee for a Pedlars Certificate

Police have no discretion to amend the statutory legislation for the fees applied to issuing a Pedlars Certificate.

The legislated fee is £12.25 and the current UK legislation can be found at this link:

Please confirm acceptance of the legislated fee and that the Guidance Notes will be amended forthwith.

2 Inaccurate reference to Perishable Goods

The following link provides archived research articles (circa 2011-12) that clarify interpretation of Section 23 of the Pedlars Act.

Police have no legislative discretion to refuse a pedlar's certificate to a pedlar of victuals.

Police may point out that in 1871 a certificate was not "necessary" for victual sellers.

Police may add that under current Street Trading legislation an unauthorised person (any person trading without a certificate, licence or consent) may be committing an offence.

Please confirm acceptance that no legislation prohibits the issuing of a pedlar's certificate to an intended seller of victuals and that the Guidance Notes will be amended forthwith.

In the capacity of Roll B Parliamentary Agent and administrator at the information portal I refer you to communications that have assisted Dorset Police amending anomalies and inaccuracies and have consulted with the PNLD and currently the Metropolitan Police

As pedlars are stakeholders in ongoing government consultations all pedlary communications are published for public scrutiny to assist policy formulation at BIS.

I await your earliest reply.

Yours sincerely

Robert Campbell-Lloyd



On 4 February 2014 wrote:

Dear Mr Robinson

You emailed me 20 November 2014 to expect a reply from your Licensing Sergeant.

To date I have received no response to questions of public importance.

You will be aware that government attempts to repeal the Pedlars Act failed and the focus of attention is now on determining a suitably objective test for 'good character' in a pedlar's certificate application process.

I/We at are engaged in ongoing consultation with BIS, the Met police et al and all such communications as this are submitted to government as evidence of the need for Guidance.

Pedlar Meriel [surname redacted] has returned from abroad and now seeks to collect her pedlars certificate from 'on-hold' at East Grinstead police station.

Please confirm that it is currently available for collection.

Please also confirm that I may expect a reply from your Licensing Sergeant within 7 days failing which the concern will be escalated to formal complaint.

Yours sincerely

Robert Campbell-Lloyd


On 4 February 2014 Sussex Police responded:

Dear Mr Campbell-Lloyd

Firstly may I apologise for the delay in responding to your concerns about pedlar's certificates.

I can confirm that the correct fee of £12.25 has now been implemented for future applications.

The issue pertaining to the granting of a pedlar's certificate for the selling of victuals is seemingly explained in section 23 of the application form. It also says on form A2 (a) guidance notes that if foodstuffs are to be sold to contact the licensing unit for advice.

I agree that no legislation prohibits the issuing of a pedlar's certificate for the selling of victuals. Pedlar's certificates have previously been issued by Sussex Police for the sale of victuals with an explanation given to the applicant that it is not a requirement - this is why the applicant is encouraged to phone in.

In essence I agree with your observations and hope that your concerns have been allayed.

Should you have any further concerns I will endeavour to work with you to ensure our application process is complying with legislation

Yours sincerely

Sergeant Mike Balmer

Sussex Police – Serving Sussex


On 4 February 2014 wrote:


Dear Sergeant Balmer

Thank you for your reply, the amendment to statutory fees and your acceptance that pedlars may trade in victuals.

We would be grateful to receive a copy of the amended/updated Sussex Police Guidance Notes and a link to the online version.

Once in hand we will review the documentation and revert as necessary.

We are grateful to have a named point of contact.

 Robert Campbell-Lloyd



On 9 July 2015 wrote:

Dear Sergeant Balmer

Application for a Pedlars Certificate - 9 July 2015 - Daniel & Joseph [surname redacted]

You will recall our previous communications below this email.

It is off serious concern that it comes to the attention of that two new Applicants for a Pedlars Certificate at East Grinstead Police Station have today been handed incorrect information in the Form A2 (a) Guidance Notes (West Sussex 07/11).

In February I requested copy of an updated form but did not receive same.

I note also the PEDLARS RECOMMENDER DETAILS final Question and request that it also be struck out for the following reasons:

The first element of the question is redundant because it is obvious that the person is applying for a certificate to trade as a pedlar as per the Pedlars Act.

The second element of the question is not required by law as a pedlar may trade "any goods" (Pedlars Act Section 3) any time, any place throughout the United Kingdom and retains the discretion to change the goods for other goods at any time and it could therefore not be incumbent on the Recommender to specify a particular item of goods to be traded.

I trust that you will attend this matter with some urgency as the applicants intend the formalities tomorrow Friday 10 July at East Grinstead station.

Please also confirm that the front desk clerk at East Grinstead is brought up to speed with the legislated fee structure.

Please also confirm that a successful applicant may attend his local police station (East Grinstead) for collection of the Certificate.

We at expect an updated copy of the Application bundle and link to the online information in due course.

We will revert in due course.

Yours sincerely

Robert Campbell-Lloyd

As pedlars are stakeholders in ongoing government consultations all pedlary communications are published for public scrutiny to assist policy formulation at BIS.

cc: Oliver Robinson Licensing Officer Horsham


On 9 July 2015 Sussex Police replied:


Dear Mr Campbell-Lloyd,

Please see the attached application form and guidance notes.

I note your concerns regarding the PEDLARS RECOMMENDER DETAILS. I have amanded our form accordingly and I thank you for highlighting this issue.

The staff at East Grinstead are aware of the legislated fee structure.

I can confirm the certificate will be made available for collection at East Grinstead should the application be approved.

I hope this addresses all your concerns

Yours sincerely

Sergeant Mike Balmer


On 9 July 2015 replied:

Dear Sergeant Balmer

Further Amendments to 8 page Sussex Police Application for Pedlars Certificate

We have reviewed the 8 page Form in more detail and have made some observations/recommended amendments on the relevant pages.

The amendment on page 2 re Ethnicity can be linked to this article.

The amendments on page 5 - same and follows our previous correspondence.

The amendments on page 7 include reference to EHD in this article on foodstuffs. 

Further amendments are for legal clarification.

This is a link to Chichester-v-Wood.

The amendments on page 8 may require our discussion and I am happy to do so.

Finally we refer you to our work with the Metropolitan police to assist in clarification of the on-line information.

I look forward to your earliest engagement with and acknowledgment of these amendments and I can confirm that they will not be circulated until the final text is mutually agreed.

Yours sincerely

Robert Campbell-Lloyd



On 10 July 2015 Sussex Police replied:

Dear Mr Campbell-Lloyd,

Thank you for you observations which I will address in due course.

I am unable to open your attached pdf document so am asking if it could be resent or amended so that I can view your recommendations.

Yours sincerely

Mike Balmer


On 10 July 2015 pedlars.inmfo replied:

Dear Sergeant Balmer

We attach several formats of the document that contains 4 pages from the set of 8 pages.

 Please see this link to the .pdf





On 4 February 2016 wrote:

Dear Sergeant Balmer

You will recall our previous communications.

Pedlars have requested an update which you undertook to address in July 2015.

I look forward to your reply.

Yours sincerely

Robert Campbell-Lloyd





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