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Product Stewardship

What BREXIT is and what chemicals importers/manufacturers should care

A point of view from UK companies.

By March 30th, UK will permanently leave the European Union after more than 25 years of “marriage” with other 27 countries but many questions have been raised by companies all around the world: are we ready to this? Will UK and European Union reach a deal at least for their “daily” import-export of chemicals?

There is no answer.

Not yet at the moment.

Time is running out and a choice must be made by UK in less than one month, either with a so called “deal” or with a so called “no deal”.

What does “deal-Brexit” or “no-deal Brexit” mean for those companies whose core business involves manufacturing or importing chemicals?

The former choice, “deal-Brexit” (otherwise known as “soft Brexit”), stands for the least impact scenario, i.e.:

  • UK exits from European Union but remains in the European Economic Area (EEA);
  • UK cannot refer to European regulations as such (e.g. REACH regulation, CLP regulation, biocides regulation, plant protection products, etc.) but can set up, for example, its own UK-REACH in order to have a mutual recognition with EU-REACH;
  • UK chemical manufacturers and importers can still use their REACH registration numbers at certain conditions;
  • European customers of UK companies could keep purchasing chemicals without interruption or specific regulatory actions.

The latter choice, “no-deal Brexit” (otherwise known as “hard Brexit”) is instead the worst scenario at all. For example, it may happen that:

  • UK exits from European Union and from European Economic Area (EEA);
  • UK cannot refer to European regulations as such (e.g. REACH regulation, CLP regulation, biocides regulation, plant protection products regulation, etc.) and must set up from the beginning a new chemical legislation;
  • UK Only Representatives can no longer represent extra-European companies;
  • UK chemical importers can no more use their REACH registration numbers and they must get their regulatory compliance again through new UK- national laws;
  • European costumers cannot buy chemicals from UK companies unless they want to register substances as importer;
  • UK Only Representatives can no longer represent extra-European companies;
  • Extra European companies must appoint a new European Only Representative if they want to keep on selling chemicals without interruption.

As one may see, no-deal Brexit can be considered as a regulatory apocalypse, especially for UK companies whose business relies on chemicals trading with European partners.

What can UK companies do for preparing themselves to BREXIT?

Some simple moves, for now:

  • Keep on updating on regulatory news. Click here to follow our linkedin page.
  • Start evaluating your business continuity through a precise analysis of your suppliers and customers: may the origin country of your suppliers/customers affect your business? Contact us!

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