COVID-19 Face Mask Guidance and Trade Counters

29 Jul 2020

The new Face Mask / Coverings regulations in retail environments came into force on 24 July 2020.

Early informal guidance and comments from senior civil servants are that they believe that trade counters will be included in the regulations. (On the grounds that there is a face to face commercial transaction taking place which could conceivably include the general public.) This is consistent with the BFPA’s latest response from BEIS on the matter:

“The definition of shops through the safer working guidance and the re-opening of the economy has been to include hardware stores within the definition so [we] would be very surprised if the [more detailed additional regulations due for release next week] excluded trade counters and it would be very difficult to argue that they should not be included.”

The new more detailed guidance has now been issued but whilst being specific about retail outlets it still doesn’t specifically mention trade counters. It can be found at:

In light of this persistent explicit omission of trade counters BFPA has again been in direct discussion with the Government Retail Team and they are insistent that; “it is the view of our retail team that trade counters are retail environments… and are included.”   But it’s also worth remembering that their official guidance regarding shop staff also states that “it is not compulsory for shop [trade counter] or supermarket staff to wear face coverings, although we strongly recommend that employers consider their use where appropriate and where other mitigations are not in place”.

Shops [trade counters], are not expected to enforce the new rules, but to remind customers of them. The official wording is: Shops [trade counters], and supermarkets will be expected to encourage compliance with the law (as they would do more generally) and can refuse entry.

Chris Buxton comments: “In the unlikely event that members wished to do so, they could refuse entry to their customers or even call the police if any customer refused to wear a mask – and the police could fine the said customer. Needless to say, this is probably not in Chapter One of the ‘How to Build good Customer Relations’ manual and it is significant that today the major supermarkets have stated that they will not be confronting customers dropping in for their Weetabix without a mask. This is clearly a case of applying common sense. The parting words of the Government Retail Team did however, somewhat ‘focus my mind.’ They were; “Chris – it may be worthwhile pointing out to your members that this policy is being introduced to protect the sales staff, not the customers – Matt Hancock’s quote was that the death rate of sales assistants is 75% higher among men, and 60% higher among women than in the general population.” – a serious and sobering thought…”

In the guidance links you will also find a list of exemptions to the face coverings requirement for visitors to shops and other premises, covering issues such as breathing problems. A selection of printable and mobile phone based formal Government approved exemption badges can be found at:

These could be useful for member’s staff who have to visit various other premises in their day to day work and have issues with face coverings.