PREPARING FOR BREXIT: WHAT IS QUIN DOING?

As we write, talks are continuing in Brussels about the intricacies of the UK's exit from the European Union and whether or not the two administrations can reach a trade deal.

As with so many UK businesses, here at Quin Global we're hoping for the best, while preparing for the worst – the increasing likelihood of a no-deal Brexit.

Over the past few months we've been hard at work making sure that our customers experience the absolute minimum impact come January 1; that our products can continue to be sold and used right across the EEA, and that our supply chains are not disrupted in any way.

Interestingly, it's not just Brexit creating challenges for businesses like ours, that deal in the manufacture of chemical-based products. While a whole raft of new legislation and compliance is being introduced for the UK, the EU is also making changes to the way these products are classified and labelled. We would like to reassure our customers that we are taking steps on both sides to ensure that our entire product range remains compliant and in line with the new rules.

HOW ARE SUBSTANCES CLASSIFIED IN THE EU – AND WHAT'S CHANGING?

Within the EU, products manufactured using hazardous substances are classified and labelled under the UN's Globally Harmonised System (GHS). This worldwide database was introduced as a replacement for all the different classification and labelling systems that existed in different countries. The GHS has standards for hazard testing, labelling and safety data sheets which reduces risk for the end user and supports international trade.

The GHS was formally adopted into European law under the Classification and Labelling of Products (CLP) Regulation. Under EU-CLP, any company that manufactures or imports chemicals in the EU must notify those products to Poison Centres, which hold centralised information about their formulation and what to do in the event of a poisoning incident.

On the same day as the UK leaves the EU, a new annex to the CLP Regulation legally comes into force. Annex VIII was added to CLP in 2017, and the first compliance deadline is January 1, 2021. It has been designed to harmonise the way that information about hazardous mixtures is reported to the Poison Centres, ensuring that the same information is available for all products in all EU countries. It also requires products to be labelled with a Unique Formula Identifier (UFI) code so that they can be identified even if they exist under different brand names.

WHAT DOES THIS MEAN FOR QUIN GLOBAL?

The UK has made provision to set up 'mirror images' of all the EU's mechanisms for the classification, labelling and indeed restriction of hazardous substances and mixtures. These new systems will be administered by the Health and Safety Executive (HSE).

As well as a UK-GHS and UK-CLP, there will also be UK-REACH and UK-BPR. REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals, and requires importers and manufacturers to prove that all the ingredients in their product, no matter where they come from, are registered for use in the EU. BPR is Biocidal Products Register, which exists to make sure disinfectants and antibacterial products – like Ramsol – are regulated.
Right now, the biggest piece of work for Quin Global is compliance with Annex VIII of the CLP Regulation, because this is completely new. We are submitting twice – once for the EU, and once for the UK-CLP which will remain in line with the EU.
Because our products were already registered with EU-REACH and EU-BPR, they will be grandfathered into the new UK systems. However, this doesn't mean we are resting on our laurels.

WHAT ELSE WE'RE DOING TO PREPARE

We are viewing this as an opportunity to ensure that our entire supply chain is compliant with the new EU and UK legislation from the bottom up. This means liaising with all our suppliers to ensure that they are taking the appropriate steps to ensure their continued compliance and reduce any risk of supply rupture. We are also working hard internally to eliminate these risks.
Work is ongoing to submit all necessary harmonised notifications and UFI codes for our products. We will also supply our customers with all the necessary UFI codes and PCNs. We are also in the process of reviewing and updating all our labels and Safety Data Sheets to ensure full compliance with the CLP regulations.

Last but by no means least, we are reviewing ALL internal systems to ensure they are primed and ready to deal with any issues Brexit may cause. This includes reviewing critical and longer lead time products and increasing inventory levels as required, as well as the creation of a stockpile in the Netherlands to mitigate for any short-term cross-channel disruption. We're liaising closely with hauliers and our own key suppliers, reviewing the necessary customers documentation for both ourselves and our freight forwarders to ensure we're ready, and adapting our internal IT systems to account for VAT implications.

It's been a massive piece of work. We're determined that the UK's departure from the EU will impact minimally on our business and therefore on the operations of our customers, no matter where they are in the EEA. We're as ready as we'll ever be!