- Date 14 Dec 2020
British companies who currently hold registrations under the EU REACH regulation, and have not yet transferred their registrations to an EU legal entity, need to act quickly to continue to trade with the EU, EEA or Northern Ireland – and Ricardo stands ready to help!
The end of the Brexit transition period at 23:00 GMT on 31 December marks a key moment of change for those trading chemicals between the UK and the EU that are controlled under the Evaluation, Authorisation and Restriction of Chemicals (REACH) regulations. At that point, EU REACH will be brought into UK law and UK REACH will begin; UK REACH will be a replication of EU REACH but will apply only to Great Britain (England, Scotland and Wales), while EU REACH will continue to apply to the EU, EEA and Northern Ireland. This means that – regardless of whether a free trade agreement is reached between the UK and EU ahead of the end of the transition period, there will be two different sets of REACH regulations that UK organizations wanting to trade across Europe will need to consider.
Crucially, for British organizations wishing to continue uninterrupted trade with the EU, EEA or Northern Ireland, it will be necessary to transfer their EU REACH registration to an EU-based legal entity before the end of the transition period. This can be the organization’s own EU entity such as a subsidiary, a manufacturer or importer of the chemical, or an ‘Only Representative’ (OR).
This is a critical step for organizations based in Great Britain as Ricardo is aware that many that trade within the EU have not yet transferred their EU REACH registrations to an EU-based legal entity. If they fail to act, their registrations will be null and void from the end of 2020, and their products will no longer be permitted legally to be marketed legally within the EU.