At the end of the transitional period, on 31 December 2020, the chemical regulation EU REACH will cease to apply in the UK. This will automatically invalidate EU REACH registrations and authorisations held by UK companies. A stand-alone UK chemical regulation UK REACH will replace EU REACH in the UK. UK-based EU REACH registrants, therefore, need to transfer their registrations and authorisations to an EU-27/EEA legal entity, if they want to retain them. UK companies who manufacture or import chemicals will also need to ensure they have valid registrations under the new UK REACH regime.
The change to UK REACH will impact different supply chains in different ways, and the best solutions will also be very specific to those supply chains, for example, whether an “only representative” will be appointed to remove the burden from new UK importers. All potentially affected companies should review supply chains to identify the possible roles to be played by each “actor”; under UK and EU REACH to ensure the supply chain can continue to function smoothly and/or what adjustments may be necessary, or commercially sensible.
Anita Lloyd and Dave Gordon provide readers with updated insights on what this means in practice and the steps affected companies need to take, and by when, in their analysis available here.