Preparations for the UK’s departure from the European Union have taken a pause over the summer months while a new Prime Minister takes up office.

Arrangements for a ‘no deal’ with the European Union have already been put in place based on the original departure date of 23 March. A ‘no deal’ is the current legal default position which would need to be changed by an act of Parliament or avoided by an extension to Article 50, beyond the date already agreed of 31 October.

Under a ‘no deal’ the UK would temporarily default to World Trade Organisation (WTO) trading terms and the country has already set out its proposed temporary tariff table which would set the level of duty at a zero rate for the majority of imports with the exception of some agricultural and automotive products. The table is available at rates-of-customs-duty-on-imports-after-eu-exit

More generally the UK Government is encouraging businesses to get ready to import from the EU after Brexit by applying for an Economic Operator Registration and Identification (EORI) number as a third country situated outside the Union, deciding who will make customs declarations for the company and allowing companies to apply for simplified imports procedures. Guidance on these measures can be seen at to-uk-after-brexit.

Specific guidance for the chemical sector in the event of a ‘no deal’, of which petrochemicals and more specifically lubricants are a part, has been produced by UK Government and can be found at sector-and-preparing-for-eu-exit

More comprehensive advice for all businesses can be found at guidance-business

David Wright, UKLA Director General

The UK regulator, the Health & Safety Executive (HSE), has produced guidance on chemical regulation for UK businesses working in the supply chain. The principles of chemical regulation and the regulation as they specifically apply to chemicals through REACH, CLP and BPR for example, will not change immediately post Brexit, although arrangements for the administration of these regulations will need to change. HSE’s guidance can be found at guidance.htm

Specific advice on REACH in the event of a ‘no deal’ has been produced by UK Government and can be accessed at how-to-comply-with-reach-chemical-regulations

Guidance from the European Chemicals Agency (ECHA) about chemicals regulation for companies in both the UK and European supply chains has been issued, and can be accessed at https://echa.europa. eu/uk-withdrawal-from-the-eu

The Government’s position at the time of writing is to seek to agree the terms of the withdrawal of the UK from the European Union and, although ‘no deal’ is the default legal option, the Government’s intention is to agree both the terms of withdrawal as well as the terms of future trade with the European Union.

All businesses, whether based in the UK or abroad, should access and act on guidance from both the UK and EU. It is in everyone’s best interests to maintain effective trading relationships and efficient supply chains to facilitate continued trade between the UK and Europe.




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