Despite Brexit referendum, the May 2018 final deadline for registration of existing chemical substances, manufactured in or imported into the EU in annual volumes between one and one hundred tonnes, under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation would remain unchanged. UK companies will also need to complete the registration process to continue trading on the single market until Brexit is finalised, even though these registrations may end up being deactivated in the future, a report from the Hong Kong Trade and Development Centre (HKTDC) said. Other ongoing REACH obligations, e.g., in relation to Substances of Very High Concern (SVHCs) and restrictions, will also continue to apply until Brexit is finalised, the report said. The full impact of the referendum result will depend a great deal on the exit negotiations, which are likely to begin at the beginning of the next year after the UK formally initiates Article 50 of the Lisbon Treaty. But, until the negotiations are finalised and implemented, the EU’s chemical and environmental laws will continue to apply to all textiles and apparel exported to the UK. At the end of negotiations, if the UK stays part of the single market through continued membership of the European Economic Area (EEA) it will continue to be required to implement REACH. The UK would remain in the existing single market for chemicals and maintain its REACH registrations, but the UK would lose the ability to take part in EU decision-making, HKTDC said in its research report. Another possibility, at the end of negotiations, is the UK opting to leave the single market. In such case the REACH regulation would no longer apply for the UK based companies, which would have to get their importers or newly appointed only representatives (ORs) in the EU or EEA to register their substances. As a result, UK manufacturers may have to restructure their supply chains to enable compliance and will have to supply all relevant information and documentation needed for registration. In the second scenario of the UK opting to leave the single market, negotiators would decide on whether the around 5,000 REACH registrations that have been made by companies in the UK will be deactivated and replaced by those of importers or ORs in the EU.
