The following actions are based on the UK leaving the EU without a deal on 29/3/2019. If article 50 is extended and / or a deal is agreed the situation may change.

This information is based on the ‘No deal’ guidance published by the UK Competent Authority (HSE). It is based on the UK leaving the EU without a deal on 29/3/2019. If article 50 is extended and / or a deal is agreed the situation may change.

We can help you carry out Brexit planning and preparations in relation to REACH.

Planning

Tonnage tracking analysis

We can help you determine which products require REACH registrations in the EU Market Place and / or the UK market place based on your import/export quantities. If imports into the UK alone are <1t per annum no UK REACH registration will be required. If imports into the EU alone (excluding the UK) are <1t per annum no EU REACH registration will be required.

Advice on setting up an EU/EEA Legal Entity.

Pre-emptive Actions

UK Based REACH Registrant

If the UK leaves the EU without a deal, you will no longer be able to access your REACH-IT accounts and your registrations and pre-registrations will no longer be valid.

In order for your REACH registrations to be valid in Europe after a ‘no deal’ exit, you will need to transfer them to a Legal Entity in Europe before that date. See our Brexit page for more information on this.

We can manage Legal Entity asset transfers of your REACH registration(s) in REACH-IT.

 To Access the UK Market

Your registration(s) will be legally recognised in the UK REACH system at the point that the UK leaves the EU. This recognition is called ‘grandfathering’

We can collate the necessary information in advance to enable immediate action once UK REACH-IT is live:

Information required for grandfathering:

  • Company details to open an account
  • Initial information for each REACH registration you want the HSE to ‘grandfather’ across – required within 60 days of the UK leaving the EU (full technical information is required within 2 years).

A UK REACH Registration number will be issued upon submission of the initial information.

EU Based REACH Registrant

If the UK leaves the EU without a deal, EU companies will require a UK registration as importers.

In order to ensure continued access to the UK market and to maintain supply chains, the HSE will implement a ‘notification’ system before full registration obligations apply.

To Access the UK Market

We can work with your UK based downstream users to complete notifications

  • Setting up accounts in UK REACH-IT
  • Uploading the necessary information to enable the notification (required within 180 days of the UK leaving the EU)

There is no fee from the HSE for this notification.

The notification is a holding position and allows EU manufacturer 2 years to appoint a UK based Only Representative and complete the UK REACH registration.

We can work with your UK based Only Representative to complete the notification and subsequent registration.

If you have a UK based Only Representative in place and completes their registration within 180 days of the UK leaving the EU this relieves their downstream users of the need to carry out any notification.

We can collate the necessary information in advance to enable immediate action once UK REACH-IT is live:

Information required for notification:

  • Company details to open an account
  • Initial information for each substance you want to ‘notify’ – required within 180 days of the UK leaving the EU (full technical information is required within 2 years).

UK Based Downstream User (DSU)

If the UK leaves the EU without a deal, EU/EEA countries will be in the same situation as non-EEA countries for the purposes of the UK REACH Regulation.

This means that companies procuring substances and mixtures from EU/EEA suppliers either directly or in articles would become importers under UK REACH. These companies will have an obligation to hold a UK registration as importers.

In order to ensure continued access to the UK market and to maintain supply chains, the HSE will implement a ‘notification’ system before full registration obligations apply.

Notification will not incur any fee from the HSE and the notification doesn’t tie you to your existing EU/EEA supply chain.

To fulfil your obligations under UK REACH

We can complete ‘notifications’ on your behalf

  • Setting up an account in UK REACH-IT
  • Uploading the necessary information to enable the notification (required within 180 days of the UK leaving the EU)

The notification is a holding position and allows you 2 years to complete the registration. Alternatively, your EU manufacturer may choose to appoint a UK based Only Representative (OR) to take on the UK REACH obligations.

We can work with your EU Manufacturer UK based OR to complete the notification and subsequent registration.

If they complete their registration within 180 days of the UK leaving the EU this relieves their downstream users (you) of the need to carry out any notification.

We can collate the necessary information in advance to enable immediate action once UK REACH-IT is live:

Information required for notification:

  • Company details to open an account
  • Initial information for each substance you want to ‘notify’ – required within 180 days of the UK leaving the EU (full technical information is required within 2 years)

 

Contact us on +44(0)1484 866777 or info@coracle.global to discuss how we can help you.