Q&As

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REACH

General questions

What is REACH and where do I find more information about it?

REACH stands for the Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals. The REACH Regulation entered into force on 1 June 2007 to streamline and improve the former legislative framework for chemicals of the European Union (EU). REACH also created the European Chemicals Agency (ECHA) which has a central co-ordination and implementation role in the overall process. ECHA is located in Helsinki, Finland and manages the registration, evaluation, authorisation and restriction processes for chemical substances to ensure consistency across the countries in which REACH applies.

The following sources of information about REACH are available:

The UKs withdrawal from the EU

General

What impact will the withdrawal of the United Kingdom from the European Union have on my UK-based company?

If your business of putting chemical substances, biocidal products or active substances on the market is limited to the territory of the United Kingdom alone, as from the date of the United Kingdom’s withdrawal, 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. You are also advised to follow the UK withdrawal negotiations with the EU which may determine your future obligations.

If your business is in any way part of a supply chain that links you to businesses located within the 27 EU Member States remaining after the UK’s withdrawal, you will face some fundamental changes. You will find more detailed advice under the respective headings of these Q&A pages.

Will UK-based companies still be able to rely on helpdesk support for advice and assistance related to the EU chemical legislation?

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

As from the date of withdrawal, 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

REACH

With a view to the UK withdrawal from the EU, does my UK-based company still need to submit a registration dossier for a phase-in substance to ECHA by the 2018 REACH registration deadline? Would we need to do the same for a non phase-in substance?

Until the date of the withdrawal of the UK, the UK remains an EU Member State in which the provisions of the REACH Regulation fully apply. You will therefore have to register your substance for the 2018 REACH registration deadline. Moreover, your registration obligations will continue until the date of the UK withdrawal. Even beyond that date, it will be advisable for you to follow the legislative development in the UK with regard to domestic registration obligations.

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