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UK releases additional no-deal Brexit REACH guidance

Concept - Brexit choice ©shocky

The UK government has published additional guidance on UK REACH in the event Britain leaves the EU on 29 March without a deal.

It follows the agreement in principle between the two sides of terms set out in the withdrawal agreement, as well as the draft political declaration of 22 November.

"Nothing is agreed until everything is agreed," the UK's Health and Safety Executive (HSE) said on its Brexit webpage to accompany the new advice. "As such it is the duty of a responsible government to continue to prepare for all scenarios, including the unlikely event of a no deal."

In order to help businesses prepare for this "unlikely possibility", the additional guidance – released on 4 December – has expanded on, "and should be read in conjunction with", the technical notice on REACH from 24 September, HSE said.

In the event of a no-deal the UK will replicate EU REACH, while making the necessary operational changes.

Business scenarios

In the new guidance, the HSE has urged companies to review their roles within the EU and UK REACH regimes because they could change "significantly". They may need to take a number of actions in order to maintain or gain access to the EU/EEA and the UK markets, it added.

The additional guidance document sets out scenarios for:

  • a UK-based EU REACH registration holder wishing to maintain UK market access;
  • a UK-based downstream user or a distributor of an EU REACH-registered chemical who wishes to maintain UK market access;
  • a UK importer of chemicals from outside the EU/EEA, or those relying on a UK importer for supply from outside the EU/EEA, and wishing to maintain EU/EEA market access;
  • a UK-based REACH authorisation holder wishing to maintain use or supply for a use in the UK;
  • a UK downstream user of a REACH authorisation held by an EU/EEA-based company, wishing to maintain use or supply for a use in the UK;
  • those exempt through product and process-orientated research and development (Ppord) considerations; and
  • those awaiting an Echa or EU Commission decision.

For the UK market, there will be a "phased approach designed to minimise disruption and ensure continuity", HSE said. Some of the proposed timeframes will be kept under review, it added.

The latest guidance also includes advice on safety data sheets, Ppord exemptions and only representative provisions.

It adds that the IT system, which will mirror EU REACH-IT for registrations, grandfathering and downstream user notifications, will be "operable" from 29th March.

In September, the UK's National Audit Office said plans for the IT system may need to be "significantly reworked" to allow further long-term enhancements.

On 11 December, the UK Parliament is scheduled to vote on the agreed draft text on Britain’s withdrawal from the European Union.

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