Yesterday the House of Commons voted against the proposed deal with the EU. This brought the odds of a no-deal Brexit (either intentional or accidental) to 4/1. A no-deal Brexit will almost certainly increase the tariffs applied to products imported into the UK from the EU, but what will it mean for your REACH Registrations?
In the event of a no-deal Brexit you can "Grandfather" EU REACH registrations over to the UK on the new UK REACH IT platform. To do this you will need a Government Gateway ID attached to a UK Registered Company, your EU REACH Registration number and registration date and you'll need your SDS in a separate file to send by e-mail. You'll have 120 days to submit this "light touch" registration (180 days for downstream users) and the original EU REACH Registration number must have been associated with a UK Legal Entity previously. Bear in mind that ECHA intend to "disappear" EU REACH IT UK entity accounts post Brexit: No pdf's will be stored on the account and no "tasks" will be visible but messages should still be accessible. You'll then have 2 years to complete the full UK registration but don't forget that data access will need to be re-negotiated!
In the event of a no-deal Brexit any substances which have an existing EU REACH Registration attached to a non-UK Legal Entity will need to appoint a UK Only Representative and submit a full registration to the UK REACH IT platform to continue to export to the UK market. The platform accepts IUCLID format dossiers (i6z).
It is currently intended that UK SIEF-like activities will be mapped out after the 180 day window for the light-touch registrations.
