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Brexit Update: UK Authorities Provide Guidance in Case of “No Deal” Scenario; Draft UK REACH Published

EHSQ Alliance Affiliate

This post provides an update on UK REACH, which will replace EU REACH if the UK leaves the EU without securing a formal withdrawal agreement. 

Written by Scott Stephens, Regulatory Research Manager, Verisk 3E, an EHSQ Alliance Affiliate. 

(This post was originally published on the Verisk 3E blog on 17 December 2018 and it was updated on 22 January 2019. Republished with permission). 

The United Kingdom’s Department for Environment, Food and Rural Affairs (Defra) recently issued chemical regulation-specific guidance, which expands on the technical notice it issued initially in September 2018 and has since updated that explains the UK’s chemicals strategy for a ‘no-deal’ withdrawal from the European Union in March 2019.

Titled “UK REACH additional guidance if there is no Brexit deal,” Defra addresses how specific UK-based stakeholders would be affected if the UK left the EU without securing a formal withdrawal agreement.

Among other details, the guidance states that:

  • EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals – 1907/2006/EC) will be replicated in the form of UK REACH, with necessary changes made to allow it to work outside the EU
  • EU REACH’s key principles will be retained in UK REACH including the ‘no data, no market’ provision and the provision for Only Representatives (ORs)
  • Like under EU REACH, fees will apply for registering chemicals under UK REACH
  • Industry will have to register the same chemicals independently with both the UK and EU competent authorities
  • Companies currently holding EU REACH registrations will have 60 days to submit basic data on their substances
  • Companies will then have two years to complete the registration of their substances under UK REACH

The guidance was issued in the wake of UK parliament members’ overwhelming criticism of the Withdrawal Agreement concluded last November between the UK government and the EU, and subsequently rejected by the UK Parliament on 15 January 2019 by an unprecedented margin of 230 votes against.

HSE Online Resources on Steps to Take in ‘No Deal’ Scenario

The UK’s Health and Safety Executive (HSE) has also been actively promoting awareness of steps businesses need to take in the event of a “hard Brexit” by providing a webpage dedicated to REACH and what to do in case of ‘no deal’. The page also includes a summary table of the different possible scenarios, along with guidance and deadlines on the actions companies should take.

Draft UK REACH Statutory Instrument Published

On 9 January 2019, the UK government published a draft statutory instrument (SI) intended to replace the EU’s REACH Regulation (1907/2006/EC) with a national version in the event that no deal is concluded with the EU by 29 March, the date the UK formally leaves the Union.


Scott Stephens is a Manager of Regulatory Research for Verisk 3E™. Scott is in charge of tracking EHS regulatory developments in Western Europe for Verisk 3E, the leading global provider of intelligent compliance solutions. Scott’s responsibilities include keeping an extensive set of regulatory databases up to date, expanding regulatory coverage to meet client needs, fielding client questions concerning European EHS regulations, producing regulatory guidance for external and internal customers and providing regulatory support for product development initiatives.


Verisk 3E™ delivers intelligent compliance solutions that empower companies to reduce risk, drive continuous improvement and create new growth opportunities. For 30 years Verisk 3E has provided clients with the expertise, content, live 24-7-365 EHS support and award winning solutions required to increase chemical and workplace safety, improve product safety and stewardship, strengthen supply chain stewardship and optimize research and development decision support.



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January 31, 2019 @ 09:30 AM EST Chemical, Manufacturing Environment, Health & Safety

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