In order to prepare for Brexit you should take the below steps:
- Review your supply chain for chemicals you currently buy.
- Identify if you purchase any chemicals direct from UK sources.
- Can you change the supplier of your chemicals , in order to continue to purchase from within the EU and continue to be an downstream user?
- Are you in a position to take the role of importer and the implications that brings if you continue to but from UK post no Brexit deal?
Impacts under Registration
Currently if an Irish based company purchase chemicals from the UK, their role is a downstream user under Reach . After Brexit, if the company continues to buy from the UK, their role changes to Importer with new obligation. The best action to take is to speak with UK supplier to determine what their intention is post Brexit. The UK supplier may take the following action:
- Relocate to another EU member state through a legal entity change
- Appoint a new Only Representative (OR) and transfer the registration
You also have the options below:
- Source a new supplier for the product within the other EU member states and continue to be a downstream user.
- Continue to purchase from the EU supplier, but you will become and importer and wil have to follow the registration process.
If you are an importer into the EU the following applies
- Classify and label products based on the CLP (EC 1272/2008 ) Regulation
- Notify hazards to C and L inventory through ECHA
- Supply appropriate SDS
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