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Existing UK-based importer or distributor of substances sourced from outside the EU/EEA

  • Importers of chemical substances sourced from outside the UK will have a duty to hold a UK REACH registration. If you hold an EU REACH registration as a UK-based importer of a chemical substance from outside the EU/EEA, your registration will be grandfathered into UK REACH.

Access to the EU/EEA market

  • UK-based companies that act only as importers of substances will not be able to appoint an Only Representative (OR) under EU REACH (only a manufacturer, formulator or producer of articles can do so). This means that, as a UK-based importer, you will not have the option to transfer your EU REACH registrations to an EU-based OR to continue selling into the EU/EEA. To continue to sell chemicals to EU/EEA customers in a no-deal scenario, you may either work with:
    • your EU/EEA-based customers to help them register with ECHA as importers
    • the non-EEA-based manufacturer supplying you to encourage them to appoint an OR based in an EU/EEA country, which can register the substance with ECHA. You will need to consider in each case whether this registration will be sufficient to allow you to export the substance into the EU/EEA.
You want to You need to By when

access the UK market

1. Open an account on UK REACH IT

2. Enter basic info on UK REACH IT

3. Provide technical information required under UK REACH

 

120 days post-exit day

2 years post-exit day

access the EU/EEA market

EITHER ensure your EU/EEA customers hold a valid EU REACH registration as importers

OR ensure the non-EU/EEA manufacturer supplying them appoints an Only Representative based in an EU/EEA country

Exit day (see ECHA guidance for details)

Exit day (see ECHA guidance for details)

Updated: 2020-01-15