REACH 2018
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BREXIT

Brexit will impact upon the REACH chemicals management legislation, both for parties inside and outside the UK conducting chemicals business.

A “UK REACH additional guidance if there is no Brexit deal" document has been published on the UK HSE website in December 2018, containing information on several scenarios:

Scenario 1: You are a UK-based EU REACH registration holder wishing to maintain UK market access
Scenario 2: You are a UK-based downstream user or a distributor of an EU REACH registered chemical and wish to maintain UK market access
Scenario 3: You are a UK importer of chemicals from outside the EU/EEA, or rely on a UK importer for your supply from outside the EU/EEA, and wish to maintain EU/EEA market access
Scenario 4: You are a UK-based REACH authorisation holder wishing to maintain your use or the supply for a use in the UK
Scenario 5: You are a UK downstream user of a REACH authorisation held by an EU/EEA-based company, wishing to maintain your use or the supply for a use in the UK
Substances of Very High Concern and Restrictions
Scenario 6: You are exempt through a PPORD
Scenario 7: You are awaiting an ECHA or EU Commission decision

This Additional Guidance expands on, and should be read in conjunction with, the guidance on "Regulating Chemicals (REACH) if there is no Brexit deal" (“Technical Notice”) published on 24th September 2018, to help businesses prepare for the possibility that the UK leaves the EU without a deal.

The ECHA Brexit webpage is likewise highly recommended viewing.

ECHA Q and A (short doc.)

ECHA Questions and answers for companies

K&L Gates Briefing Five

K&L Gates Briefing Four

K&L Gates Briefing Three

K&L Gates Briefing Two

K&L Gates Briefing One

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