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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.