Welcome to GPC UK

Brexit Current Status – July 2020!

In private communication with HSE, we have been updated, that, UK is still in the transition period (TP) until 31 December 2020, and UK businesses need to continue to comply with EU REACH in their current roles in their supply chains.

Actionable Summary for Chemical Businesses
  1. Prepare Inventory of substances being placed in the UK in qty. greater than 1 TPA
  2. Check if the substance is registered in EU-REACH.
  3. Identify EU-REACH LR and check if it's going to also take Lead in UK-REACH.
  4. Initiate a discussion with the EU-REACH LR on the data access for the UK – discounted, administrative charges only, free, etc.
  5. Identify the OR facility that you may opt to appoint for UK-REACH.
  6. GPC-UK is an OR facility fully equipped to offer OR services in the UK.
  7. Keep yourself updated on UK REACH developments at www.gpcgateway.com.

 We have already set up a UK based OR facility ‘GPC UK’, to support our existing and new potential clients, to be able to comply with the challenges posed by Brexit, on substance exports to the UK.

Brexit Background

Brexit has been Britain’s exit meaning the UK’s split from the European Union (EU). The EU is an economic and political union involving 28 European countries and it allows free trade and free movement of people within these 28 countries, to live and work in whichever country they choose. The UK had joined the EU in 1973 (when the latter was known as the European Economic Community) and has now become the first member state to withdraw from the EU.

A public referendum was held on 23rd June 2016, to decide whether the UK should leave or remain with the EU. The majority (52%) voted in favor of leaving the EU. The referendum turnout was very high at 72%, with more than 30 million people voting and 17.4 million people opting for Brexit.

Brexit was originally due to happen on 29th March 2019 after the then Prime Minister Theresa May triggered Article 50, the formal process to leave the EU and kicked off negotiations. During Mrs. May’s tenure, the deadline was delayed twice after MPs rejected her Brexit deal, thereby eventually pushing the date to 31st October 2019. However, in October 2019, Mr. Boris Johnson, who replaced Mrs. Theresa May as the PM, had to request for another extension, a third one, after MPs failed to pass a revised Brexit deal into law.

With the third extension, Brexit was finally implemented on 31st January 2020. With this implementation, the UK has formally left the EU with a withdrawal deal and has now gone into an 11-month transition period which will end on 31st December 2020.

Latest News

Brexit Update July 2020!

Brexit being implemented from 31st January 2020, the UK has formally left the EU with a withdrawal deal and it is currently in transition period up to 31st Dec. 2020. The UK and the EU have ruled out the possibility of extending the transition period beyond December 2020.

In private communication with HSE, we have been updated, that, UK is still in the transition period (TP) until 31 December 2020, and UK businesses need to continue to comply with EU REACH in their current roles in their supply chains.

HSE indicated that, at this point, we are not able to provide definitive advice regarding arrangements after the TP. The Statutory Instrument (SI) that would have implemented UK REACH in a ‘no-deal’ scenario did not come into effect as the UK left the EU with a withdrawal agreement. The extent to which the provisions in UK REACH (as it is currently drafted) will come into effect at the end of the TP will largely depend on the outcome of the UK-EU trade deal negotiations that are occurring throughout this year. Depending on the outcome, we may need to change some or all the provisions. Any transitional provisions will give sufficient time for companies to comply.

  • UK REACH is based on a grandfathering system to allow companies to transfer existing authorizations and registrations over with minimum data. Full datasets will need to be submitted within two years.
  • The EU's demand for full alignment on REACH in return for access to Echa's data is a sticking point, and something the UK government has rejected. It is set on implementing UK REACH from 1st January 2021, mirroring the EU legislation but with possible future divergence.
  • Further, parliamentary undersecretary of state at Defra Rebecca Pow, said in her letter that UK REACH would be implemented on 1st January 2021, restating that the government was not seeking associate membership of Echa or participation in REACH.
  • Earlier this year, The UK has also released policy papers on its draft UK-EU Comprehensive Free Trade Agreement (CFTA) and the annexes on its plans for the future trade relationship with the EU. The draft specifically does not mention about REACH, but it proposes to cooperate on chemicals regulation, share data, and align approaches towards classification and labeling. The draft annex suggests that both parties would agree to continue and strengthen their cooperation on chemicals regulation to facilitate trade in a way that benefits consumers, businesses, and the environment and provides for the protection of human and animal health. This may include promoting and encouraging cooperation between the respective public or private organizations responsible for the manufacture, distribution, sale, or regulation of chemicals.

We have already set up a UK based OR facility ‘GPC UK’, to support our existing and new potential clients, to be able to comply with the challenges posed by Brexit, on substance exports to the UK.

Brexit and UK REACH Regulation: Latest Updates

With Brexit being implemented from 31st January 2020, the UK has formally left the EU with a withdrawal deal and it is currently into an 11-month transition period. The UK and the EU have ruled out the possibility to extend the transition period beyond December 2020 and the UK will now exit the transition period on the said date, 31st December 2020.

The UK has also released policy papers on its draft UK-EU comprehensive free trade agreement (CFTA) and the annexes on its plans for future trade relationship with the EU.  The draft specifically does not mention about REACH, but it proposes to cooperate on chemicals regulation, share data and align approaches towards classification and labelling. The draft annex suggests that both parties would agree to continue and strengthen their cooperation on chemicals regulation to facilitate trade in a way that benefits consumers, businesses and the environment and provides for the protection of human and animal health. This may include promoting and encouraging cooperation between the respective public or private organisations responsible for the manufacture, distribution, sale or regulation of chemicals.

In our private and recent communication from June 2020 with the UK authorities, they have indicated that during this transition period, the UK businesses need to continue to comply with EU REACH in their current roles and in their supply chains. The UK authorities have indicated that, the extent to which the provisions in UK REACH will come into effect at the end of the transition period will largely depend on the outcome of the UK-EU trade deal negotiations. Based on the outcome of negotiations, the authorities might need to change some or all the provisions and any transitional provisions will give sufficient time span for the companies to comply.

We have already setup a UK based OR entity ‘GPC UK’, to support our existing and new potential clients, to be able to comply with the challenges posed because of Brexit on substance exports to the UK.

For more information or queries, please write to us at: [email protected]