Q&As

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The UKs withdrawal from the EU

REACH

My company is a manufacturer of a substance, located outside the EU/EEA. We place the substance on the EU/EEA market through a UK-based importer. What do we need to do in preparation for the UK withdrawal from the EU?

If your substance has been registered by the UK-based importer, its registration will no longer be valid after the UK withdrawal. This means that the imported substance will need to be registered by an EU-27/EEA-based legal entity:

  • You can appoint an Only Representative located within the EU-27/EEA to carry out the required registration of the imported substance.
  • The substance can also be registered directly by its EU-27/EEA-based importer(s).
My company is a manufacturer of a substance, located outside the EU / EEA. We have appointed an Only Representative, who is located in the UK. What do we need to do in preparation of the UK withdrawal from the EU?

You can appoint a new Only Representative, located within the EU-27/EEA. This requires that the old and the new Only Representatives collaborate in making a ‘legal entity change’ in REACH-IT. The new appointment must take place ahead of the UK withdrawal and be notified to ECHA (through the ‘Legal entity change’ functionality in REACH-IT) without undue delay.

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