A few more words about the Chemical Industry.
Chemicals are ubiquitous: plastics, fuel additives, adhesives, cosmetics, cleaners, toiletries, paints, paper, construction, inks, biocides, pharma feedstocks, preservatives... 1/18

Chemicals are regulated almost everywhere in the world but when EU-REACH (Registration, Evaluation and Authorisation of Chemicals) was designed, Brexit was not considered. The contracts drawn up for data sharing assumed that all parties would be in the EEA/EU. 2/18

Unsurprisingly, HMG has decided to eschew anything to do with EU-REACH and instead to pursue UK-REACH by duplicating EU-REACH. So it’s aligned then? Isn’t that good?
No, not really, the rationale is the same, the initial classifications will be the same but there it ends. 3/18

Key to EU-REACH is Registration and Registrations are not carried forward and with UK now a “third country” how could they be?
Any UK-based country wanting to sell chemicals into Europe must Register them with ECHA (European Chemicals Agency). 4/18

Registration in needed even if the same company had Registered them before when the UK was an EU-member. Sounds harsh? Maybe, but the UK left the EU and now needs to gain access to that market via another route. 5/18

To Register means preparing a Dossier and probably a Chemical Sfety Report. Getting the data for these means either re-testing chemicals or more realistically, because almost everything has been tested before, buying the data from someone who has it. 6/18

Cannot someone not reuse the data they had before?
Well, yes, if those data are owned by you then that’s fine but the contracts to sell the test data usually only provided a licence to use it to use it the Register for EU-REACH by a company in a member state. 7/18

A UK company wanting to continue to sell into the EU now needs to negotiate a new contract and pay again to use the same data it licensed a few years ago when it was a company in a member state. Data can be expensive; think 10's or 100's of thousands of € per substance. 8/18

Just to add to the complexity as the UK is now a "third country" any UK company now needs an agent or “Only Representative” in the EU to handle all this EU documentation, to record its exports and actually make the Registrations. 9/10

The total cost to the UK Chemical Industry re-register under EU-REACHisn't too bad but with the data requirement is estimated to be around 500M€.

But that’s not even the half of it. 10/18

All UK companies must also now register under UK-REACH to make or import chemicals to sell into its home market.
Again, they need to pay Registration fees and once again will need to pay for tests or buy a licence to use data that they do not already own. 11/18

HMG are nothing if not magnanimous however; they may let a company grandfather any registrations they already had under EU-REACH which will save a few thousand pounds. The problem is of course is that the data holder may not license the data, which is the expensive bit. 12/18

That’s a lot of extra money the UK Chemical Industry has to find once more to sell into Europe and again to sell into the UK. This double whammy when totalled up is around £1.1 Billion.

But it doesn’t finish there. 13/18

Just like the automotive business many chemicals are not made locally but need to be imported. Chemical plant is expensive, takes a long time to build, test and commission.

The UK is not self-sufficient, the UK needs to import chemicals. 14/18

All chemicals coming from Europe, Asia or USA need to be registered in UK-REACH, even if they were already Registered in the EU. Registration needs test data which means expensive testing or purchases. Possibly the same data bought before but licensed only for EU-REACH. 15/18

So, to sell into the UK means more registrations and more data mean more costs.

Some suppliers see this as prohibitive many have already decided to exclude the UK from their market.

With no local supplies no feedstock means products will disappear from the UK market. 16/18

Exporters and Importers will look to the 27 (plus EEA) not to the 1.
Already EU, US, Chinese and Indian companies have cut their offer to the UK. EU companies have moved away from buying UK-made chemicals. Most chemicals from UK are already available from elsewhere. 17/18

UK-based chemicals companies, particularly those owned by multinationals have already relocated or rationalised their chemicals away from the UK. Those that stay face higher costs which they can pass on or perish. 18/18