Brexit Fallout: ECHA Declares 2,900 REACH Registrations Invalid

With the expiration of the deadline on December 31, 2020, the time allotted to British companies to  
transfer some 2,900 REACH registrations to European firms has passed. That number represents one fifth of the REACH registrations that were owned by British companies.  

According to the ECHA, this number could climb further if companies began the transfer process on time but fail to update the dossiers accordingly by changing the legal entity before the end of March 2021.  

EU Implementing Regulation (EU) 2020/1435, which has applied since December 11, requires an on-time update. Article 1 states: “Changes in a registrant’s status or in his identity: In the case of a change falling within point (a) of Article 22(1) of Regulation (EC) No 1907/2006, the registration shall be updated and submitted to the Agency by no later than 3 months from the date when that change takes effect.“ Accordingly, companies that wish to keep their EU registration must update their dossiers before the deadline at the end of March. 

What’s the reason for this large number of invalid REACH registrations? According to the British Chemical Business Association (CBA), most of the revoked registrations involve intermediate products that are processed into other chemicals for which a valid REACH export registration exists.  

The background for the rush is the EU-UK Trade and Cooperation Agreement reached on December 24. For companies affected by REACH, the agreement means that they may no longer use ECHA data for British REACH registrations.  

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