More time to transfer your responsibilities
ECHA will grant more time to companies to prepare for Brexit. As things stand, companies subjected to REACH thus have until 12th April at least to appoint an Only Representative (OR) in the European Union-27 or relocate their activities.
The “Brexit window” is a period offered by ECHA on its REACH-IT website, which was initially scheduled from 12th to 29th March 2019. This window is the only period allowing British companies to appoint an OR in the EU-27 and transfer them their responsibilities, that is, to proceed to a “legal entity change”. This window was extended following the European Council’s decision to postpone Brexit until at least 12th April.
With the appointment of an OR inside the EU-27 (or the European Economic Area), you will be able to transferyour REACH Registrations, Authorisations or pending applications for Authorisations to your OR, so as not to lose them at the UK’s exit from the EU.
Why transfer them?
To be able to keep on marketing all your products in the European Union after the effective Brexit date (be it on 12th April or later), EcoMundo recommends you proceed to this legal entity change.
Otherwise, the registrations made by British entities would become void, as would the authorisations obtained by them.
We encourage you, for more information, to consult the white paper on Brexit & REACH, available on our website.
EcoMundo can be the Only Representative for your company and help you through the whole transfer process.
An extension after 12th April?
It is still possible that Brexit be postponed again to later than 12th April. If British members of parliament ratify the agreement negotiated with Brussels, Brexit could take place on 22nd May (followed by a 21-months transition period). Before 12th April, the United Kingdom could also ask for a longer extension of negotiations. In that case, Brexit would be deferred to a relatively distant future.
With that said, companies should not wait for the last minute to get ready for Brexit. On the contrary, EcoMundo’s experts recommend they transfer their REACH responsibilities to an OR as soon as possible in order not to get trapped when it is too late, upon Brexit.
Wish to know more about Brexit and its impact on your substances?
For more information, do not hesitate to contact our expert, Mr. Fang Zhou by phone at : +33 1 83 64 20 54 for Europe, or +1 (778) 234 1607 for North America or even send him an email at contact@ecomundo.eu
