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Posted on

Another month and we are still living in BREXIT limbo!

Hopefully the politicians can finally get their act together and next week’s votes will provide some desperately needed certainty.

On the plus side, ECHA have clarified procedures for UK companies to transfer registrations to an EU-27 legal entity where this is possible.  (Link here).

The ECHA window for beginning transfers is due to open on 12th March.

The UK have said that the time to notify your substances to qualify for the ‘grandfather’ clause under UK REACH has been extended to 120 days (from 60).  This is primarily because it is looking unlikely that the UK IT system will be ready in time; the fall-back option is spreadsheet and email!

Good luck to all those struggling through the BREXIT mess.


Posted on

At the 28th Meeting of Competent Authorities for REACH and CLP (CARACAL) in November, some provisional timings intended to help clarify for all actors under REACH how the duties concerning dossier updates as referred to in Article 22 of REACH i.e. clarifying "without undue delay" - some of these provisional timings are given below:

Change triggering
(M/I/OR) or identity/address

 6 months                 
 Substance Composition
- if change covered by joint reg   
- if updated CSR reqd

3 months
1 year

 Change in tonnage band
- decrease 
- increase (testing proposal)

3 months
6 months

 New uses
- no CSR reqd
- CSR change reqd

3 months
1 year 

Early plans are to bring a proposal to the REACH Committee in February 2019 with a view to bringing it to a vote in April 2019.

Tagged in: ECHA REACH