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Changes to UK REACH Statutory Instrument
The Statutory Instrument (SI) in relation to UK chemical regulations post Brexit has been recently updated. This is the second time the original SI has been updated and the changes made can be found here.
A key change relates to the ability to ‘grandfather’ substances. Previously, if companies had a valid UK based registration they could grandfather existing substances as long as a registration was held by the UK entity 2 years prior to exit day.
As the exit day has moved a few times (and could possibly move again) they have now changed this 2 year period to a fixed date; 29 March 2017.
This now makes decisions about whether/when to transfer registrations to an EU Legal Entity slightly easier as you would no longer be at risk of accidently falling outside the 2 year period if the Brexit deadline keeps moving, and you will maintain the ability to granfather your registration into UK REACH.