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CBA Chairman’s letter On Brexit and Aftermath

30 June 2016

In the aftermath of the Brexit vote, all member companies are trying to work out the implications for their businesses and CBA has been asked for its guidance on the issues involved – particularly in relation to REACH and the 2018 deadline.

At this stage, before Article 50 has been triggered, it is impossible to provide specific guidance.

In terms of REACH, assuming the proposed timetable continues to apply, it is clear that the legislation will remain in force for at least two years following the UK giving notice under Article 50.

REACH will continue to apply to substances ‘placed on the market’ within the EU regardless of the Brexit vote and the UK will therefore be subject to the 2018 deadline. UK companies exporting to the EU would still have to ensure that their products comply with existing legislation, such as REACH, biocides and CLP irrespective of the Brexit decision.

Substances manufactured outside the EU and imported for the use of UK customers will remain subject to existing legislation for the period prior to the UK’s formal exit from the EU. By that date, the UK will have to create its own legislative framework for the industry.

Though it is pure speculation at this stage, it seems highly likely that any subsequent UK framework would be based on the EU model. Given the trend towards global harmonisation, this approach seems both logical and practical. Radical deregulatory measures in the UK are therefore considered unlikely.

The uncertainty resulting from the Brexit vote will probably continue for sometime and CBA will continue to monitor the evolving situation – as regards our links with Europe and any proposed changes to the industry’s regulatory framework or the environment in which it operates.

We are fortunate in that CBA has forged strong links with Westminster, Whitehall and Brussels and will be in a position to provide its member companies with the latest information on Brexit developments as it emerges in due course.

For the time being, however, it remains business as usual.

Yours sincerely

Christopher Hayman
CBA Chairman

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