If your business of placing chemical substances, biocidal products or active substances on the market is limited to the territory of the United Kingdom (Great Britain) alone, as from the end of the transition period, your activity will no longer be subject to the provisions of the EU chemicals legislation. With regard to obligations arising from the CLP, BPR, PIC and REACH Regulations, your legal obligations towards ECHA as the EU’s respective regulatory Agency will also cease. Instead, it will be the UK legislation that applies to you.

You will therefore need to follow the legislative developments in the UK.

For businesses that are part of a cross-border supply chain, linking companies located in the UK(GB) with companies located within the EU/EEA Member States after the UK’s withdrawal, detailed advice can be found under the respective headings of these Q&A pages.

In Northern Ireland, REACH, CLP, BPR and PIC continue to apply after the transition period. Please refer to Q&As 1700 - 1711 for an overview.

Yes. With its withdrawal from the EU, the United Kingdom has become a so-called “third country”. The ECHA Helpdesk regularly replies to enquiries from companies based outside the EU/EEA. After the end of the transition period, UK(Great Britain)based companies should address ECHA via the dedicated contact form. 

After the end of the transition period, the UK will no longer have the obligation to maintain a national helpdesk to provide advice and assistance on matters governed by the EU’s CLP, BPR or REACH Regulations. You are advised to check with the UK authorities if they will nonetheless provide such advice in practice. You may also wish to address your industry association in the UK.

In Northern Ireland, REACH, CLP, BPR and PIC continue to apply after the transition period. Please refer to Q&A 1700 - 1711 for an overview.

As a company based in the EU/EEA, the obligations flowing from the EU chemicals legislation will continue to apply to you. Your interactions with UK(Great Britain)-based business partners, however, will be impacted by the UK withdrawal, as the United Kingdom has become a “third country” from 1 January 2021. 

For biocidal products, specific arrangements are put in place potentially affecting your company, as the UK cannot anymore act as a leading authority during the transition period.  In the end, you may face new and different UK rules on the import and use of chemical substances. You may also need to adapt your interaction in supply chains involving your UK(GB)-based business partners. The Q&A sections on the BPR, CLP, PIC and REACH Regulations will provide you with more detailed guidance in that regard.

In Northern Ireland, REACH, CLP, BPR and PIC continue to apply after the transition period. Please refer to Q&A 1700 - 1711 for an overview.

ECHA decisions concerning UK-based companies only apply until the end of the transition period.

If you, as a UK(Great Britain)-based company and an addressee of an ECHA decision, decide to challenge that decision or have already challenged it before the Board of Appeal, this may mean that the contested ECHA decision will then cease to have legal effect. In this case, unless the appellant provides evidence as to the existence of a material interest in ECHA’s Board of Appeal continuing to handle its appeal, the appeal proceedings may be discontinued, as there would be no need for the Board of Appeal to rule on such an appeal.

After the end of the transition period, legal entities established in Northern Ireland can continue to lodge an appeal with ECHA’s Board of Appeal on ECHA decisions listed in Article 91 of REACH and Article 77 of BPR.

The Q&As on this website solely provide advice on the impact of the UK withdrawal in relation to the chemicals legislation that ECHA manages. You will need to find information on its other effects on supply chains across the external frontier of the EU (e.g., customs, tariffs and quotas, rules of origin, standardisation, rules on transport from outside the EU, etc.) from other sources, such as the European Commission or your industry association.

 Such information is available, for instance, in the readiness notices published on the webpages of the European Commission.

The IE/NI Protocol provides that REACH, CLP, BPR and PIC regulations apply to and in the United Kingdom in respect of Northern Ireland. Thus, companies located in Northern Ireland will continue to have access to REACH-IT, R4BP, ECHA Submission portal and ePIC for most processes.

Northern Ireland companies with an existing account in these tools associated with the former “UK” entity will be required to create new accounts associated to the new entity “UK (NI)”.

With regard to poison centres notifications, companies established in Northern Ireland will be able to use the ECHA Submission portal to notify mixtures to be placed on the EU market, but not for those placed on the Northern Ireland market. The UK national system will have to be used for such purpose.

For applications for national authorisations of biocidal products (Article 29 BPR), for simplified authorisations (Article 26 BPR) and applications for mutual recognition (Chapter VIII BPR), the UK(NI) companies need to use the UK national system to make their applications. For other BPR processes, for example applications for active substance, R4BP 3 can be used.

Yes, if they intend to place those mixtures on the EU/EEA market, or Northern Ireland. CLP applies to and in the United Kingdom in respect of Northern Ireland.

Companies established in Northern Ireland will be able to use the ECHA Submission portal to notify mixtures to be placed on the EU/EEA market. However, when placing mixtures on the Northern Ireland market the UK national system will have to be used instead.

CLP does not apply in other parts of the United Kingdom (‘Great Britain’). Therefore, the obligations under Article 45 and Annex VIII will not apply to companies based in Northern Ireland if they intend to place a hazardous mixture on the market of Great Britain.

No, shipments of treated articles or biocidal products authorised in accordance with the BPR from Northern Ireland to the EU/EEA will not be considered as imports to the EU/EEA.

It will not be possible to submit such an application via R4BP 3. For applications for national authorisations of biocidal products (Article 29 BPR), for simplified authorisations (Article 26 BPR) of the BPR and applications in accordance with Chapter VIII (mutual recognition procedures) of the BPR, the UK(NI) companies need to apply through the national system of UK to make their applications. 

We suggest the applicant to contact the UK authority in respect to Northern Ireland to obtain further information on how to practically proceed with the submission.

• shipments of chemicals between Northern Ireland and the EU are not considered as imports or exports, and therefore the PIC Regulation does not apply to such shipments;
• shipments of chemicals between Northern Ireland and third countries – including Great Britain after the end of the transition period - are considered as imports or exports and therefore the PIC Regulation applies to such shipments.

• to notify upon the first export of the calendar year for each substance listed in Annex I to the PIC Regulation and each importing country;
• to report during the first quarter of each year, the quantity of each Annex I PIC chemicals exported from, or imported to the EU in the preceding year;
• to package and label the chemicals that are intended for export in accordance with the related provisions established in the CLP, BPR and REACH; in particular, a Safety Data Sheet (SDS) in accordance with the REACH Regulation shall accompany chemicals when exported;
• not to export chemicals and articles as listed in Annex V to the PIC Regulation. 

• the export of chemicals listed in Annex I to Regulation (EU) No 649/2012 from Northern Ireland to Great Britain has to comply only with the rules of that Regulation that implement the Convention. For example, the export of a chemical listed in Part 2 of Annex I to Regulation (EU) No 649/2012 from Northern Ireland to Great Britain has to be notified by the exporter but there is no requirement to get the explicit consent of the United Kingdom in respect of Great Britain; 
• the rules on packaging and labelling of chemicals only apply to exports of chemicals from Northern Ireland to Great Britain to the extent necessary to comply with Article 13 of the Convention.