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As a UK-based manufacturer, following the UK withdrawal from the EU you will be regarded as a non-EU manufacturer. Only manufacturers and importers based in the EU / EEA have registration obligations. However, if you wish to continue supplying to your EU-27 / EEA-based customers, you may consider one of the following options:
- Like any EEA-based legal entity, you can transfer your existing registration to an EU-27 / EEA legal entity, which maintains the manufacturing role if this transfer is the result of a legal entity change, i.e. it must fall into one of the following scenarios:
- The UK-based manufacturer goes through an acquisition or relocation to the EU-27 / EEA.
- Intragroup transfer of the whole operations / manufacturing activity (e.g. transfer of the activity from a UK-based mother company to an EU-27 / EEA-based daughter company).
- You can appoint an Only Representative (OR) within the EU-27 / EEA. For further details (particularly with regard to the timing), please refer to Q&A 1464.
- Alternatively, your EU-27 / EEA-based customers can continue sourcing from you by registering the substance(s) themselves, as importers.