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Brexit: Effects on Your Business in Chemical Regulations

How Will the Brexit affect Your Business?

The UK withdrew from the EU on 31 January 2020. UK based companies are advised to transfer registrations and other regulatory "assets" to EU companies before the end of the transition period provided for in the Withdrawal Agreement on 31 December 2020.

If your company is based in the EU/EEA, you will be affected whenever your supply chains as a customer or supplier extend to the UK.

If your company is established in the UK, the EU chemicals legislation, which includes REACH, CLP, BPR and PIC, will no longer apply to you after the transition period if your chemical substances, mixtures or articles, biocidal products or active substances are placed on the market only in the UK. This is also the case if you export certain chemicals directly to non-EU/EEA countries from the UK.

If your business is in any way connected to the remaining 27 EU Member States or the EEA countries, you will have to prepare for changes.

Identify your role -

and find out what we can do for you

From January 01 2020 you cannot register a substance under the REACH regulation. If you have done so in the past, the registration ends on 31 December 2020.
You will not have to update any dossiers associated with the registration.

But, if you want to continue doing business in the EU/EEA you can either appoint an only representative (in case you are a manufacturer or formulator) within the EU to manage your registrations or move your operations related to the registered substance to a legal entity within the EU.

In case you will require your registration to remain within the UK under UK-REACH, it will be automatically grandfathered. You will however need to notify HSE in such case.

CSB has the necessary expertise and experience, which we have gained from 10 years of OR work for clients worldwide.

If you represent a non-EU company and you are based in the UK, you will no longer be able to act as an only representative after the end of the transition period, unless you relocate to an EU or EEA country.

If the non-EU manufacturer that appointed you, wants to remain legally on the EU market, will have to find a new only representative, based in the EU/EEA. The registrations will have to be transferred to the new only representative.

CSB has the necessary expertise and experience, which we have gained from 10 years of OR work for clients worldwide.

Approval of Active Substances

You can apply for an active substance approval by submitting your application in an EU or EEA country. You can submit the application even after the transition period has expired.

Supplier of biocidal substances or products (Article 95 Listing)

The BPR stipulates that substance or product suppliers of biocides have to either be located in the EU or appoint an EU-based representative to be listed in the Article 95 list of substances and suppliers. Non-EU suppliers are included together with their appointed EU representatives.

As a UK-based supplier, you will need to appoint an EU-based representative before the end of the transition period (31 December 2020) to avoid being removed from the Article 95 list.

Non-EU companies listed under Article 95 of the BPR, that appointed an EU representative located in the UK will also need to get a new representative within the EU.

For both constellations we can assume the function of the EU representative.

EU-based companies must keep a close eye on their supply chains. Any substances bought from UK-based suppliers which are registered under REACH, will not be legally registered after the transition period ends.

To change that, the UK based supplier will need to appoint an only representative within the EU/EEA. Alternatively, you can choose to register the substance on your behalf as an importer.

In case your UK-based supplier is currently an importer of the substance from outside the EU/EEA, they can move their importing activity to the /EU/EEA. Or, again, you can choose to register the substance on your behalf as an importer.

If you require access to the UK market after the transition period, you or your UK based clients will need to comply with UK-REACH. IF you are eligible, you can either appoint an UK based Only Representative or support your UK based clients with their registration efforts under UK REACH. In a first step so called Downstream User Import Notifications (DUIN) need to be submitted to HSE in order to be able to further place products on the UK market.

Either way, we are your strong partner in all questions regarding EU-REACH and Brexit.

From 01 January 2020 EU legislation will no longer apply to the UK. REACH authorizations granted to UK-based companies for certain substances will no longer exist.

UK-based companies can transfer their application to an only representative within the EU.

CSB has the necessary expertise and experience, which we have gained from 10 years of OR work for clients worldwide.

We manage your
regulatory challenges.

Contact us with specific questions, a defined project or as a full-service partner for your regulatory needs.

We manage your
regulatory challenges.

Contact us with specific questions, a defined project or as a full-service partner for your regulatory needs.

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