UK-based mixture supplier

Only EU/EEA-based importers and downstream users can submit a notification under Article 45 (poison centre notifications). Furthermore, the obligations have to be fulfilled by each duty holder individually. If your company is based in the UK and has notified a mixture to the relevant appointed body in the Member States where your EU-based distributors place it on the market, this asset cannot be transferred. The information submitted will remain in the database and will be available to the appointed body once they get access to the harmonised submissions. 

Nevertheless, the EU company will need to submit a notification themselves if they intend to import the same mixture into the EU. The EU company cannot rely on the notification made by the UK supplier.

If you want to continue doing business in the EU/EEA after the transition period, you have the option of moving your operations related to the mixture to a legal entity within the EU (who can be the formulator or the importer). Alternatively, you can support your EU customers by providing the necessary information to allow them to comply with the submission obligations.

Note that a UFI code generated with a UK VAT can still be used by EU companies. The reason being that the ultimate role of this code is only to link the product on the market to the submitted information. 

In general, if you want to export mixtures to the EU after the transition period of the UK withdrawal , your products will have to comply with the EU regulations, including the CLP Regulation. This means that you, together with your EU-based importer, will need to classify and label your products in accordance with CLP.

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