Frequently Asked Questions

The Brexit transition period is of 11 months which has already begun from 31st January 2020 and will last until 31st December 2020 ( also known as Implementation period [IP] completion day). During this period the UK will effectively remain in the EU’s customs union and as a single market.

During this transition period: 
 

  • EU REACH will continue to apply in the UK and businesses do not need to take any action to comply with the UK REACH 
  • There is no requirement to transfer UK held registrations to an EU 27 legal entity to retain EU market access 
  • Registrations, authorizations, and restrictions in place before the UK left the EU to continue to be valid  
  • The process for registering new chemicals under REACH remain unchanged, UK companies are still required to register with the European Chemicals Agency (ECHA).
  • The UK will recognize all new decisions relating to REACH made by the EU

Post transition period/IP completion day, to continue with your exports to the UK, you will need to appoint an “Only Representative” (OR) in the UK, and the substances to be exported will have to be notified to the UK authorities before exporting.

The exact details of UK REACH registrations will be known once UK REACH comes into force and the UK REACH-IT opens after 31st December 2020. More information will be updated here during the last quarter of 2020.

OR facilitation charges are likely to be on the parallel grounds as that of EU service charges
and letter of access (LOA) cost details would be as per the actuals of the Lead registrant and
will be available after the transition period and/or in the last quarter of 2020.

The roles and responsibilities of ECHA will be taken up by the UK’s Health and Safety Executive (HSE) in the UK.

Existing EU REACH registrations held by UK-based companies and those including only
representatives will automatically be ‘transferred’ and will become UK REACH registrations.
This means that qualifying registrants will not have to re-register their substances in the UK,
and they will continue to have access to the UK market.

The UK agency will no longer have access to the substance data held by ECHA and it will need to build that database itself. Therefore, although qualifying EU REACH registrations will automatically ‘transfer’, all transferring UK registrants will need to provide that data over a period of two years, in two stages:

  • Basic data about the market and the substance will need to be submitted within 120 days of IP completion day/transition period; and
  • Full information appropriate to the registrant’s tonnage band will need to be submitted within two years.

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