UK-based REACH registrant
Only an EU/EEA-based company can register a substance under the REACH Regulation. If your company is based in the UK and has registered a substance under REACH, the registration will no longer exist after the UK withdraws from the EU. This also means that you will no longer have to update the REACH registration dossier after 30 March 2019.
If you want to continue doing business in the EU/EEA after the UK’s withdrawal, you have the option of appointing an only representative to manage your registrations. You also have the option of moving your operations related to the registered substance to a legal entity within the EU.
A registrant is responsible for the substances covered by their registrations. This means that the responsible staff and relevant documentation must be present at the address of the registrant – setting up a company on paper only in the EU-27 or EEA is not sufficient.
CLP notification - exporting substances to EU-27 countries
If you want to export substances to the EU after the UK’s withdrawal, your products will still have to comply with the EU regulations, including the CLP Regulation. This means that you will need to classify and label your products accordingly. However, you will no longer need to submit notifications to the C&L Inventory – this will have to be done by the importing company in the EU.
- If continuing business in EU-27/EEA appoint an only representative in an EU-27 or EEA country.
- Notify ECHA of only representative changes through REACH-IT as soon as this possibility is available.
- If you choose to appoint an only representative, make sure that they have sufficient knowledge and experience in handling substances and the information related to them. Remember that the only representative has all the responsibility under the registration title and other titles of the REACH Regulation.