UK withdrawal from the EU


On 29th of October 2019, the European Council adopted a decision to extend the date of UK's withdrawal from the EU until the 31st of January 2020, at the latest. The UK can leave earlier, on the 1st of December 2019 or 1st January 2020, if the deal is ratified by both parties.

ECHA have answered multiple questions concerning existing chemical registrations by UK companies with a clear statement. In order to continue supplying EU-27-based customers on the basis of your own registration, it will be necessary to either relocate to the EU-27 or to appoint an Only Representative within the EU-27/EEA.

The Arrow Regulatory team envisage that their established EU base in Dublin (Eire) may be of assistance to companies as cooperation is strived for and new regulatory procedures are put in place. ECHA suggest that companies may wish to avoid the possibility of their chemical registration becoming void by signing contractural agreements with a suspensive clause stipulating that appointment of an Only Representative takes effect on the date when the UK withdrawal from the EU takes effect.

The UK Government Environmental Audit Committee examined oral and written evidence before publishing on 25 April 2017 a report on the future of chemicals regulation after the EU Referendum:

  • The chemicals regulation framework established by the EU through REACH would be difficult to transpose directly into UK law.

  • Companies face significant uncertainty over the validity of current REACH registrations after the UK leaves the EU: the Government must clarify their position on the future regulatory framework as a matter of urgency.

  • In deciding the future of the UK's relationship with the EU's single market for chemicals, the Government should take a pragmatic approach. The most important element of REACH, which the Government should seek to remain involved in as a minimum, is the registration process for chemicals.

  • Establishing a fully stand-alone system of chemicals regulation for the UK is likely to be expensive for both the taxpayer and for industry.

  • The experiences of the US as it introduces an improved system of chemicals regulation could be useful for the Government when planning the UK's approach.

Consequently, the European Chemical Industry Council (Cefic) concluded in a position paper published in June 2018: a bilateral agreement between the EU and UK allowing continued British participation in the implementation of regulations administered by ECHA would represent "the most effective way" to ensure companies can continue to efficiently trade across borders and their operations are not disrupted by Brexit.

Contact us for information on how we can help you as UK withdrawal negotiations arrive at a conclusion.

Arrow Regulatory Limited

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Arrow Regulatory Limited is a company registered in England and Wales with company number 10171397. Registered Office: 149-155 Canal Street, Nottingham,  NG1 7HR, UK

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