How BREXIT affects REACH regulations ECHA

Effect of Brexit on REACH registrations & Only Representation

A cus­tomer recent­ly asked us, “I have UK-based cus­tomers, what are the con­se­quences of Brex­it for my REACH reg­is­tra­tions?”

This is a very good ques­tion indeed, for which we can offer the fol­low­ing answer.

The UK (Great Britain) has vot­ed to with­draw from the Euro­pean Union (EU). Whether the UK with­drawl from the EU will be a ‘hard’ or a ‘soft’ exit is unfor­tu­nate­ly not yet clear, but more will be known in the upcom­ing weeks.

Please fol­low this link to the Brex­it state­ment let­ter com­piled by the ORO group — of which Caplinq is a reg­is­tered ORO mem­ber — explain­ing the expect­ed con­se­quences regard­ing REACH.

Though it is a fair­ly tech­ni­cal doc­u­ment, we can sum­ma­rize by say­ing that the Brex­it result in the UK no longer being part of the EU and will there­fore be out­side the scope of EU-REACH per the with­draw­al date of 29 March 2019.

If you are a Non-EU man­u­fac­tur­er and you cur­rent­ly have an EU-based Only Rep­re­sen­ta­tive (OR), then the cur­rent­ly reg­is­tered sub­stances that go to your UK based cus­tomers might have to be reg­is­tered again, like­ly under a new “yet-to-be-imple­ment­ed” UK-REACH. In order to do so, you will need to con­tract with a UK-based Only Rep­re­sen­ta­tive (OR).

If you are a Non-EU man­u­fac­tur­er and you cur­rent­ly have active reg­is­tra­tions, pre-reg­is­tra­tions or an OR agree­ment with a UK-based REACH Only Rep­re­sen­ta­tive (OR), then you need to take imme­di­ate action. We sug­gest you to con­tact us to look at the pos­si­bil­i­ties of switch­ing to Caplinq Europe B.V. as your EU-based OR before the with­draw­al date.

If you would like to learn more about Caplinq’s REACH ser­vices, would like to learn about Caplinq’s REACH OR ser­vice, or have any ques­tions or are uncer­tain about your sce­nario or how Brex­it will affect your busi­ness to Europe and the UK, please con­tact us at reach@caplinq.com.

About Danielle van Noorden

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