Are you a UK-based company holding biocidal product authorisation and REACH registrations in the EU-27 Member States, EEA countries or Switzerland?
In order to maintain the validity of your biocidal product authorisations in the EU, all the authorisations should be transferred as a matter of priority to a legal entity established in EU 27 Member States, EEA countries or Switzerland by using the relevant case types in R4BP 3 (NA-TRS, SA-TRS or UA-TRS).
Please note that the transfers have to be notified and implemented before the UK withdrawal. Similarly, all applicants should transfer, by using the transfer functionality embedded in the cases, all their ongoing R4BP 3 cases for which the prospective authorisation holder is a UK-based company.
BREXIT will also impact your REACH registrations. Article 3 (4), (9) and (11) of the REACH regulation stipulates that registrants must be established in the EU. Consequently, after 30 March 2019, all UK-based registrants will need to appoint a new Only Representative based in the EU to take over respective REACH registrations.
Kerona Scientific Ltd, who’s head office is based in Dublin, IRELAND is currently assisting a number of clients with their transfer. Please don’t hesitate to contact us if we can be of service or you would like to discuss this further.