With such a fast paced and changing narrative, we understand how difficult it is proving for our clients in the cosmetic and chemical industries to plan for Brexit, in whatever guise it materialises on 29th March. And that’s assuming that we will still leave the EU on 29th March, which is correct at the time of writing! So we thought this round up of resources for your Brexit checklist will help offer practical tips on how to prepare.
How a no-deal Brexit might impact REACH
Government notice about how a no-deal Brexit might impact REACH
The UK Government issued this advice on 19th December 2018 concerning the implications of a no-deal Brexit on REACH regulations. The article explains how the UK’s Health and Safety Executive would assume the responsibilities of the ECHA, the implications for existing REACH registrations and the Government’s plans for ensuring access to markets and upholding safety standards.
ECHA advice for UK and Europe 27 based companies
How the UK withdrawal affects you
Where you are based, and where you sell your products, will dictate the impact of Brexit for your business. ECHA has issued a Brexit checklist based on a variety of scenarios, with clear tips on what to do next. Their REACH FAQs also provide a useful resource.
HSE guidance on chemical regulation
Health and Safety Executive advice on Brexit
This resource explains what the status will be for companies throughout any implementation period, what might happen in a no-deal scenario and contains further guidance on regulating chemicals after Brexit including impacts on biocides, CLP, PIC, PPP and REACH.
CTPA: Advice and viewpoints from the cosmetics trade body
As the voice of the Cosmetic,Toiletry and Perfumery industry, CTPA has been active in lobbying for clarity and reassurance throughout the Brexit negotiations. It presents information to its members from the viewpoint that an ongoing customs union would be preferable for the industry but clarifies the current and possible future positions well.
Contingency planning advice in the event of no deal
CTPA’s positioning paper on Brexit plus fact sheets and further reading
European Commission preparedness notice for cosmetic and biocidal products
If you can work through the legalese, this document states the legal position of the European Commission on cosmetic products post Brexit, including the role of the Responsible Person, use of the Cosmetic Product Notification Portal and rules around the Product Information File (pif) and labelling.
For those manufacturing or distributing biocidal or active ingredients, the EC published this set of FAQs on 23rd October 2018. It includes guidance on what test data will still be accepted after Brexit and information about the UK ceasing to be an eCA (evaluating Competent Authority.)
If you have any further useful resources, please share them below.
