Exit day is 31st October 2019
I posted before on UK Chemicals Regulation after UK Exit. This is a reminder post.
On the 25th March, HSE (the UK REACH chemicals regulator) published further instructions on access to UK REACH – here.
[the UK documents endlessly refer to a “Deal” – this is the Withdrawal Agreement, and for our purposes merely provides a new Exit day of 31st December 2020, not new trade arrangements with the EU]
These HSE instructions make it clear the online service ‘Comply with UK REACH’ will replace ECHA’s REACH-IT platform for UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), from Exit day.
Live on Exit day, the new online system will allow:
* Businesses that have existing UK-held REACH registrations to validate their registrations (‘grandfathering’)
* Businesses that import chemicals from the EEA to submit downstream user import notifications
* Business to register new substance registrations or PPORD notifications (Product and Process Orientated Research and Development)
In order to minimise disruption to in the event of a no-deal Brexit, businesses that currently hold a REACH registration are encouraged to access their ECHA REACH-IT account and ensure that all the information relating to their business is downloaded. Information required to comply with UK REACH includes registration confirmation documents and ECHA decisions.
Under the new requirements, from Exit day –
* UK businesses that manufacture a chemical (those currently registered to EU REACH) will need to validate their existing registration with the Health and Safety Executive (HSE) within 120 days of the UK leaving the EU.
* UK businesses that import a chemical substance from the EU will need to notify HSE within 180 days of the UK leaving the EU.
* UK businesses that export chemicals to the EU will need to have an EU REACH registration in place once the UK leaves the EU.
In addition, more technical information will need to be submitted by businesses to HSE within two years of EU Exit.
Current HSE instructions are here.
[the Exit day may change, please continue to follow this Blog]