Companies should continue their Brexit preparations



With regard to the decision of the European Council to extend the UK withdrawal negotiation deadline, ECHA advises companies to continue preparing for a new, flexible withdrawal date.

As the extension allows the UK to ratify the Withdrawal Agreement at any point before the end of October 2019, ECHA recommends companies to continue preparing for a new, flexible withdrawal date.

With regard to the transfer of registrations and other assets from UK entities to EU-27 entities, ECHA’s previously published instructions remain valid. Companies need to make their own business decisions about the timing of initiating the transfer, or to terminate the transfers initiated but not yet completed. This can be done directly in REACH-IT, following the step-by-step guidance. However, if companies need to update their dossiers, they need to terminate or complete the transfer to enable the updating.

Under the PIC Regulation, the EU-27 companies should still use the manual notification form for any planned export taking place less than 35 days after the UK withdrawal.

For the Biocidal Products Regulation (BPR), the recent changes to R4BP 3 that ensure that UK authorities can no longer be selected as evaluating or reference Member States within the tool will continue to apply.

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