Downstream users – how to prepare for Brexit

At midnight on 31 December 2020, the UK withdrawal from the EU will be final. For EU downstream users of chemicals this may have serious implications.

If you purchase chemical substances or chemical mixtures from a UK supplier, your role will change considerably after 31 December 2020. In that case you will no longer be a downstream user but an importer of chemical substances into the EU.

If you import more than 1 ton per year of a substance from the UK, the substance must be registered under REACH. It is possible that your UK supplier has already registered the substance but this registration will not be valid after the new year. Consequently, to import the substance from the UK into the EU may not comply with REACH and may therefore be illegal.

As a downstream user you have the following options:

  1. Check with your UK supplier if he has transferred his registration to an EU-based only representative (OR). In that case your import is still legal.
  2. Make your own REACH registration of substances imported from the UK in amounts exceeding 1 ton/year. Your registration must be in place prior to import.
  3. If your substances are already registered by EU-based companies, you may consider purchasing the substance from an EU distributor to be covered by his registration.

In addition to potential requirements for registration, as an importer you are also obliged to comply with other requirements in the CLP and REACH regulations such as classification, labelling and safety data sheets.

ECHA provides more information about the consequences of Brexit here

For further details or assistance, please contact:

Anne Rathmann Pedersen
Tel +45 4516 9370


Helle M. Andersen
Tel +45 4516 9023