Effect of Brexit on REACH registrations & Only Representation

A customer recently asked us, “I have UK-based customers, what are the consequences of Brexit for my REACH registrations?”

This is a very good question indeed, for which we can offer the following answer.

The UK (Great Britain) has voted to withdraw from the European Union (EU). Whether the UK withdrawl from the EU will be a ‘hard’ or a ‘soft’ exit is unfortunately not yet clear, but more will be known in the upcoming weeks.

Please follow this link to the Brexit statement letter compiled by the ORO group – of which Caplinq is a registered ORO member – explaining the expected consequences regarding REACH.

Though it is a fairly technical document, we can summarize by saying that the Brexit result in the UK no longer being part of the EU and will therefore be outside the scope of EU-REACH per the withdrawal date of 29 March 2019.

If you are a Non-EU manufacturer and you currently have an EU-based Only Representative (OR), then the currently registered substances that go to your UK based customers might have to be registered again, likely under a new “yet-to-be-implemented” UK-REACH.  In order to do so, you will need to contract with a UK-based Only Representative (OR).

If you are a Non-EU manufacturer and you currently have active registrations, pre-registrations or an OR agreement with a UK-based REACH Only Representative (OR), then you need to take immediate action. We suggest you to contact us to look at the possibilities of switching to Caplinq Europe B.V. as your EU-based OR before the withdrawal date.

If you would like to learn more about Caplinq’s REACH services, would like to learn about Caplinq’s REACH OR service, or have any questions or are uncertain about your scenario or how Brexit will affect your business to Europe and the UK, please contact us at reach@caplinq.com.