Following Britain’s recession from the European Union, ECHA had advised UK-based companies to transfer their registrations to EU-based locations before the end of the transition period. In order to continue doing business in the EU/EEA in 2021, it was possible to appoint an only representative to manage the registrations, and to transfer to an EU-based legal entity any operations related to the registered substance.
On April 26th, 2021, ECHA announced that all UK-based registration transfers have been completed and successfully transferred to companies in the EU, EEA or Northern Ireland. Of these registrations, 2964 have not been transferred and are therefore legally void. These are indicated in ECHA’s database and website as “revoked”.
ECHA invites registrants to review the information contained in the registrations transferred from the UK. As indicated in the Commission’s Implementing Regulation on dossier updates ((EU)2020/1435), registrants will have up to 3 months to update administrative information, while they will have up to 6, 9 or 12 months for more complex updates.
This obligation to update applies to REACH registrations and previously notified substances (NONS) under the Dangerous Substances Directive. It is also pointed out that since March 2021, ECHA has also been monitoring the completeness of chemical safety reports, in addition to the information contained in the REACH dossiers already sent.