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Libra Speciality Chemicals – Brexit Contingency Plan

To ensure ongoing REACH compliance and uninterrupted continuity of supply to our UK/EU customers

Libra Speciality Chemicals is legally based in the UK, importing and exporting products throughout Europe, and as such we wish to ensure that suppliers, customers and interested parties in the UK and the rest of Europe are fully informed of our plans to remain fully compliant with EU REACH and also the emerging UK chemical regulatory scheme, during this transitional period.

On 22 November 2018, a draft Withdrawal Agreement was reached between the UK and the EU, which included a commitment for the UK and the EU to explore the possibility of cooperation between UK authorities and the European Chemicals Agency (ECHA). The details of these commitments are not yet clear, however, the UK and the EU both recognise the mutual benefits of the UK remaining in the EU REACH system, or a UK version thereof.

To take effect, the agreement now needs to be ratified by both sides and, based on our current understanding of the political situation in the UK, we hope that this will occur soon. If the draft Withdrawal Agreement is not ratified, the UK Government has said that it will create a UK REACH Regulation, which initially will be a “copy and paste” of the EU REACH regulation. All products supplied by Libra are fully EU REACH compliant and we intend to maintain this position after Brexit.

Our contingency plan to ensure ongoing REACH compliance and full, uninterrupted continuity of supply to our UK/EU customers.

In the event of a ‘no-deal Brexit’ or a position in which the UK falls outside of the EU customs union, Libra has identified and prepared a contract with an EU Only Representative (“OR”). In this event, a transfer of our REACH registrations to our European based OR will occur in a timely manner relative to the date of the UK exiting the EU (or during a subsequent transition period, should this be implemented by the EU & ECHA authorities).

Based on currently available information provided by the UK authorities, a new UK chemicals regulatory system will require all chemicals placed on the UK market to be registered using a new UK IT system. Initially, all EU REACH registrations currently held by UK companies will be carried across (“Grandfathered”) into the UK system. Accordingly, we are working very closely with our non-UK suppliers to ensure that in the event of either a ‘no-deal Brexit’ or transitional agreement scenario all relevant chemicals imported by Libra into the UK will be supported under the new UK regulatory system.

If you have any questions, please get in touch with our Regulatory & Quality Officer.

Email: Susan.Elliott@librachem.co.uk

Tel: +44 (0)161 667 0392