Q&As

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The UKs withdrawal from the EU

REACH

My company is a manufacturer of a substance, located outside the EU/EEA. We place the substance on the EU/EEA market through a UK-based importer. What do we need to do following the UK withdrawal from the EU?

If your substance has been registered by the UK-based importer, its registration will no longer be valid after the end of the transition period. This means that the imported substance will need to be registered by an EU/EEA-based legal entity:

  • You can appoint an Only Representative located within the EU/EEA to carry out the required registration of the imported substance.
  • The substance can also be registered directly by its EU/EEA-based importer(s).

Please note that this reply does not yet take into account the impact of the Protocol on Northern Ireland which will become applicable as from the end of the transition period. The reply will be amended in due course accordingly.

My company is a manufacturer of a substance, located outside the EU / EEA. We have appointed an Only Representative, who is located in the UK. What do we need to do in following the UK withdrawal from the EU?

You can appoint a new Only Representative, located within the EU/EEA. This requires that the old and the new Only Representatives collaborate in making a ‘legal entity change’ in REACH-IT. The new appointment must take place ahead of the end of the transition period and be notified to ECHA (through the ‘Legal entity change’ functionality in REACH-IT) without undue delay.

Please note that this reply does not yet take into account the impact of the Protocol on Northern Ireland which will become applicable as from the end of the transition period. The reply will be amended in due course accordingly.

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