Chemicals and Manufacturing

Potential impact

  • It has already been accepted that some legislation, including REACH, will not be able to be "cut and pasted" into UK law during the process of consolidating and repealing EU legislation. However, as REACH harmonises the conditions under which chemicals can be placed on the European market, the UK will need to continue to comply with it, potentially even after it has left the EU.

  • Around 75% of chemicals imports (including vital raw ingredients) come from the EU, according to the Chemical Industries Association. Trading terms and tariffs will be critical to the continuation of those imports.

  • Product standards, including for example CE marking and Eco-labelling, will continue to be a requirement for products placed on the EU market. This is likely to mean that those standards need to be reached by UK manufacturers if they are to continue to supply EU customers.

What to do at this stage

  • The House of Commons Environmental Audit Committee is starting an inquiry into the REACH regime and how it can function post-Brexit. It is important to ensure that you engage with trade associations and other bodies that may be in a position to make representations on your behalf to Government, and also that you track developments as the inquiry progresses.

  • Most companies will know which of their substances and products fall within REACH.  If you do not, now is the time to start an inventory. The same process needs to be repeated to itemise everything that is covered by the CE marking regime.

  • It is worth trying to identify raw materials suppliers outside the EU, especially for more specialist substances.