Quin Global UK Ltd is classed as downstream users under REACH. None of the products (adhesives) we manufacture is required to be REACH registered – only the applicable raw materials (substances) used within the products are REACH registered.
The vast majority of the substances we use in our products are sourced from the EU, which are REACH registered covering the UK market. From the 1st deadline back in March, the EU suppliers of these substances had UK representatives in place, so the flow of goods between the UK and EU remained.
If the UK leaves the EU without a deal, the online service 'Comply with UK REACH' will replace ECHA's REACH-IT platform for UK REACH.
From the day the UK leaves the EU, substance formulators will be able to use the service to:
1) validate existing UK-held EU registrations ('grandfathering') – so for formulators (substance supplier) who are an existing EU REACH registration holder they will need to validate their EU REACH registration(s) with the UK within 120 days after exit, for them to continue to be legally recognised in the UK.
2) submit downstream user import notifications (DUIN): for downstream users or distributor importing a substance in quantities of one tonne per annum or greater from an EU registered EU/EEA supplier in the two years prior to the UK leaving the EU, you are required to make a notification of import to the HSE.
The advice from DEFRA, HSE, and the government is deal or no deal, supply will continue after Brexit, but extra duties may be required to comply with the UK REACH within a certain time frame.
This means that UK-EU trade will be able to continue on the same terms as now until the end of an implementation period.
Last updated in June 2020.