if current registrations need to be replaced by importers or Only
Representatives (ORs) in the EU. UK-based ORs that have made
registrations for non-EU manufacturers will also need to relocate
to keep their presence in the EU.
Recently, over 100 companies signed an open letter urging lead
Brexit negotiators to seek a three-year transitional period after
withdrawal.2 The chemical industry hopes to see an extension of
REACH throughout the transition. However, it is not certain that
the EU will agree to grant such an extension. The EU wants to
maintain its current membership and therefore will not be likely to
grant non-EU members the benefits of EU membership for free.
The future of regulatory compliance in the UK
Much is still up in the air with respect to the impact of the UK’s
withdrawal from the EU. The outcome of negotiations over the next
months will have a huge impact on how companies do business in
the UK. We can expect complicated policy shifts and new legislation
that will impact regulatory compliance and international trade.
Companies that operate in the UK will need to carefully
consider their presence in the EU, ensuring that steps are taken to
prepare for the inevitable legislative changes.
Visit https://echa.europa.eu/uk-withdrawal-from-the-eu for the latest
information from ECHA on the UK’s withdrawal from the EU.
Updated CLP Guidance
In July 2017, ECHA released version 5.0 of Guidance to Regulation
(EC) No 1272/2008 on CLP of substances and mixtures and
version 3.0 of Guidance on Labeling & Packaging in accordance with
Regulation (EC) No 1272/2008.
Several revisions have been made to the guidance on the classification,
labeling and packaging document, including partial
updates to follow the 8th Adaptation to Technical Progress to the CLP
Regulation and removal of unnecessary information, including sections
pertaining to the repealed Dangerous Substances Directive and
Dangerous Products Directive.
A new section of particular interest in the revised guidance on
labeling and packaging is 5.4.2 Packaging Used for Consolidation of
Supply Packaging During Transport. This section has been added to
clarify the issues surrounding CLP labeling of multi-layer packages
during transport.
CLP labeling rules apply to all layers of packaging used for
supply purposes. Transport packaging, used for the consolidation
and/or protection of supply packages during transport, is outside
the scope of CLP and is not required to have CLP labeling. Once
the product is no longer in transport, the transport packaging
must be removed to enable the CLP label to be visible or a CLP label
must be added to what was previously the transport packaging.
The full text guidance documents can be found at https://echa.
europa.eu/guidance-documents/guidance-on-clp. SPRAY
1https://echa.europa.eu/regulations/reach/registration/registrationstatistics/
overview-all-countries
2http://www.cbi.org.uk/news/more-than-100-firms-sign-letter-to-leadbrexit
negotiators/
December 2017 SPRAY 31