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British Rubber & Polyurethane Products Association

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Regulation Guidelines

Posted on 18 January 2019

The Government intends to set up a regime for the regulation of chemicals that follows as closely as possible the existing EU regulatory regime (REACH). The Department for the Environment, Food and Rural Affairs has recently issued a draft Statutory Instrument giving effect to this new regime.

Any business using chemicals (even if it does do not make them or trade in them) needs to take action to prepare for the possibility of the UK leaving the EU without a deal.  You may take on new regulatory responsibility you did not previously have.

 For example if you import chemicals from the EU you may need to become the registrant for UK REACH.

•             Visit the HSE Brexit webpage

for information on how each of the chemicals regimes will be affected

•             Refer to the Additional Guidance for specific information on REACH, including actions for businesses using but not producing chemicals.

•             Check contingency plans across your supply chain to understand what information you may need to supply to UK agencies, logistics providers, suppliers and customers.

The UK bespoke chemicals regime purports to be fully in line with REACH. However it does pose a number of problems that the chemicals and allied industries, through a grouping of which BRPPA is a member, has raised with the Government. They feel that these proposals are unworkable and unsustainable.  The proposals rely on the unrealistic assumption that UK companies have ready access to testing data; they will almost certainly increase animal testing; and will impose an unsustainable additional regulatory cost on UK companies. Above all, the proposals assume that a UK version of REACH can be achieved in just two years – a regime that took the EU and a fully-resourced European Chemicals Agency ten years to implement. BRPPA will continue to join industry efforts to secure substantial improvements, and if you have any issues of concern please let us know.