• Antony Kirrane

Another BREXIT post..

Updated: Feb 4, 2019

Some happy British people enjoying the warm Summer last year.

Yes. Another. I am sorry.

Following on from the REACH post below, you can see the UK have been busy publishing draft regulations ready for a withdrawal. Very Busy!

Clicking on the hyperlink above will take you the page of all of the draft regulations the UK has been busily preparing.

It seems that these drafts prepare us for a "hard exit" - where the UK is no longer part of the EU, its institutions and regulatory bodies. It separates us from things like ECHA and the framework for the marketing of goods. As best as I can tell, they transpose EU law exactly, warts and all, but demand UK specific implementation where it was previously EU wide, such as:

  1. A UK importer address will be needed

  2. A UK responsible person is needed

  3. UK specific registrations are needed after Brexit day

  4. UK notified body activity will no longer be valid for the EU

  5. A UK mark in place of the CE mark

Of course, the EU told everyone about this last year...

What should I do?

Don't Panic! It is the UK's stated intention that all of the regulations should remain the same and, from the small bits I have read, it seems they are sticking to that promise. It also seems they are trying to implement an 18 months period of transition, wherever they can.

If a product was safe under the meaning of the law before, it will remain safe under the meaning of the law after.

I recommend the following:

  1. Map the EU regulations that you currently need to comply with

  2. Consider who is the responsible entity: importer manufacturer etc

  3. Consider how the EU will treat you after Brexit (will you need a new address since your current one is in the UK?)

  4. Consider how the UK will treat you after Brexit (will you need a new address since your current one is in the EU)?

  5. Look at registrations, notifications and other EU input and be prepared to copy the same into any new UK framework

  6. Ensure your EU products are properly labelled - Some EU member states may start enforcing quickly

  7. Hold tight on making changes to UK products, the UK are yet to finalise the regulations and we don't know what the UK mark will look like yet

If you haven't done this sort of exercise, you must do it now. I'm afraid to say that the "unlikely event of no deal" is becoming more likely day-by-day.

Happy Brexiting!

Photo by John Cameron on Unsplash

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