Time Running Our For UK Textile Supply Companies To Complete Their EU Reach Regulation Registration
Image Courtesy of REACH/ECHA
All registration processes on dossiers submitted by UK companies will be terminated if they are not fully completed before the end of the transition period on 31 December 2020.
Helsinki, 21 December 2020 – REACH registrations submitted by UK-based manufacturers, importers and only representatives that have not by 31 December 2020 gone through all the steps required to complete the registration, both by the registrant and by ECHA, will not be processed further.
If UK companies are currently submitting a new registration, or updating an existing registration, they need to be aware that the registration process will be terminated if it is not finalised by 31 December 2020.
In addition, any transfer of registrations by a UK company needs to be initiated before 31 December 2020 and accepted by the successor as soon as possible in 2021, and latest by 31 March 2021. Failing to do so will lead to the revocation of the registrations.
This means in practice that after the transition period:
All pending UK submissions in REACH-IT will be terminated.
No registration numbers will be issued to UK companies.
Companies in the UK cannot perform any actions as duty holders in REACH-IT.
All registrations held by or returned to UK companies will be revoked gradually in REACH-IT.
The above does not apply to dossiers submitted by companies in Northern Ireland, who have updated their country code in REACH-IT.
REACH continues to apply to these companies due to the Protocol on Ireland and Northern Ireland.
The UK’s withdrawal from the EU will affect companies including those that manufacture or use chemicals in the UK as well as in the EU-27. ECHA’s updated web section aims to help affected companies who have registered substances or use authorised chemicals in supply chains.
How the withdrawal will affect companies depends on their role in the supply chain.
ECHA has published new web pages that guide companies through the consequences and give advice on how to prepare for the withdrawal.
For some companies the withdrawal can have significant consequences.
For example, if a company based in the UK registered a substance under REACH, the registration with ECHA will no longer exist after the withdrawal.
If a UK manufacturer of chemicals wants to continue doing business in the EU/EEA after the UK’s withdrawal, they can:
appoint an only representative within the EU-27 to manage registrations; or
move operations related to the registered substance to a legal entity within the EU.
REACH, CLP, BPR and PIC will no longer apply to UK companies that place chemical substances, mixtures or articles, biocidal products or active substances on the market only in the UK.
This is also the case when companies export certain chemicals directly from the UK to non-EU/EEA countries.
The new web section also gives advice to EU-27 downstream users relying on REACH authorisations granted to UK suppliers and many more actors facing changes resulting from the UK withdrawal.
