The United Kingdom (UK) has formally left the European Union (EU) on the 31 of January 2020. However, the realisation of Brexit is still to be defined by key decisions of the EU and UK, leaving minimal time for any involved party to prepare. Unless otherwise decided, British chemicals no longer remain in the common EU market. This would mean that UK companies’ EU REACH registrations would be void at the end of the transition period, and companies purchasing chemicals from the UK suppliers would be EU REACH importers, needing registrations according to the rules of EU REACH.
Chemical Watch summarises the key dates of Brexit as follows:
- 31.1.2020: UK leaves EU – the transition period begins
- Early 2020: European Commission to publish its draft negotiating objectives for approval
- 30.6.2020: Deadline for extending the transition period
- 31.12.2020: End of the transition period (unless decided to be extended)
- 2022: England’s chemicals strategy to be published
What does this mean for companies?
EU-REACH registrations: current registrations will terminate at the end of the transition period. UK companies having registrations need to transfer their registrations to an EU-27/EEA based company or an Only Representative by the end of the transition period. An authorisation granted to UK based companies will also cease at the end of the transition period. Transfer of authorisations to an EU-27/EEA based Only Representative is recommended by ECHA for securing the supply chain.
UK-REACH registrants will need to provide basic information within 120 days of the country leaving the EU. A transition of 2 years is planned for providing technical information for tonnage bands under UK-REACH. There are still important details to be solved.
There are Statutory Instruments (SI’s) under preparation for creating national UK laws for REACH and CLP Regulations, Prior Informed Consent (PIC) Regulation, Biocides Regulation, Cosmetics, Detergents, Restrictions of hazardous substances in electrical and electronic equipment (RoHS).
The UK Environment Bill was published in October 2019, giving the environment minister powers to amend the UK REACH and its enforcement regulations. The Chemicals Strategy is under preparation. Its expected due date is 2022, well after the transition period (unless decided to be extended).
In January 2021, the UK will start a completely new relationship with EU – either with an agreed and ratified trade deal, or without it.
Are you an importer or user of chemicals within the EU? Are you concerned about how Brexit will affect your business? Our chemical experts are here to help you! Contact us
Senior Consultant, Ecobio Oy
Reference: Global Outlook 2020: How will the Brexit endgame shape up? Chemical Watch 28.1.2020.