This section provides information on the impact of Brexit on the safe use of chemicals.

• During the Brexit transition period, EU laws will continue to be applied in the UK. However, EU Chemical Regulation will no longer be applicable to the UK and vice versa from Jan 1, 2021.
• Going forward, new equivalent regulations will come into force in the UK similar to EU’s REACH, BPR, PPP, and Cosmetics.

Who Will Be Impacted?

• Chemical companies based in the UK and EU
• Non-EU based Chemical companies operating through the UK-based companies/ representatives for manufacturing/importing into EU countries

More-specifically

• UK-based REACH registrants: UK-based REACH assets will be void and they need to be transfer to EU-27/EEA based subsidiary or only representative (OR)
• UK-based only representative (OR): Will no longer be applicable for EU RECAH
• UK-based supplier/manufacturer of Biocidal active:EU-27/EEA based representative only needs to be appointed
• UK-based supplier/manufacturer of Biocidal Product:NeedEU-27/EEA based Authorization holder, same will reflected on product labels.
• Downstream chemical user based in EU-27/EEA supplied by UK supplier: Needs to confirm that the substance has valid REACH authorization
• Companies based outside UK, exporting Chemicals, Biocides to UK: Need to comply to new equivalent regulations that will come into force in UK (e.g. UK REACH, Link)

Reference: https://echa.europa.eu/uk-withdrawal-from-the-eu

How Freyr can Support

• Regulatory Strategic Support for Transitioning
• Only Representative services in EU-27 for REACH and Biocides
• Regulatory Support for New UK Regulations for Chemicals (UK REACh), Cosmetics, Biocidal Products (UK-BPR) (yet to be finalized)
• Supply chain Regulatory Compliance Review/Assessment
• Updating Chemicals and Biocides Dossiers and Notifications

Impact of Brexit No-deal Scenario:

Chemical companies will be impacted significantly in case of Brexit No-deal

• Separate regulations in EU and UK leads to doubling the efforts in term of registrations, data and cost to bear. This will lead to huge additional cost for complying with UK REACH.
• EU-UK supply chain of chemicals will get impacted in both directions
• Several specialty chemicals may disappear from supply owing to additional Regulatory burden

Reference: https://www.ft.com/content/d7343616-732d-4ab1-9af5-f1d5fbd0d658

Backlink: CSRA Microsite: https://csra.freyrsolutions.com/