The Withdrawal Agreement Bill has successfully passed through the House of Commons and is now being debated in the House of Lords. This is expected to be finalised by end Jan. Once the Bill is passed, which ratifies the Withdrawal Agreement negotiated between the UK and the European Union, the UK will enter into an implementation or transition period on 31st January 2020 until the 31st December 2020 . During this implementation period the UK will continue to apply EU legislation (including REACH) as if it were an EU Member State.

In preparation for a no deal scenario, some UK companies supplying to the EU initiated a transfer of their registration to an EU OR. This activity can be put on hold until later in the year. Whether or not this can be done during the transition period (1st February to 31st December 2020) has yet to be clarified. As such there is no current requirement to transfer UK held registrations to an EU 27 legal entities by 31st January 2020 in order to retain EU market access.

Many uncertainties still remain. The extent of the UK’s ongoing participation in REACH will be determined by the outcome of the negotiations during the implementation/transition period. If at the end of the implementation/transition period on 31st December 2020, the UK is no longer a participant of REACH, then UK companies will need to take action to retain EU market access. The current end December 2020 End of Transition date may also change, of course, as many dates have already.

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