UK Government Publishes No Deal Technical Notes

The UK Government has published technical notes on certain topics in the event of a 'no deal Brexit'. Of particular interest to industry will be the REACH technical notes.

Link: click here

Specifically on the 'Regulating Chemicals if There is No Brexit Deal', the Government notes:

• Companies registered with REACH would no longer be able to sell into the European Economic Area (EEA) market without transferring their registrations to an EEA-based organisation. Companies would therefore need to take action to preserve their EEA market access.

• UK downstream users currently importing chemicals from an EEA country would face new registration requirements. Under the UK’s replacement for REACH, importers would have a duty to register chemicals. Similarly UK downstream users of authorisations would no longer be able to rely on authorisation decisions addressed to companies in the remaining EEA countries.

It is also noted that in terms of registering EEA substances within the UK, the UK authorities need to know the identity of the substance and the companies who are manufacturing or importing it. There will be a requirement to notify the substance to the UK authorities through a new REACH-IT system. The notification process will be ‘simple’, requiring at this stage merely substance name, company name and intended volume. Companies will have 60 days to notify for all chemicals they intend to import after the start date of 30th March 2019. The key point (and the issue for industry) is that some form of detailed registration, with data, will be required “later” - this later registration will likely inlcude an IUCLID dossier. 

For more information on REACH or Brexit, please contact either Matt Davies or Paul Baxter at [email protected] and [email protected] respectively.