January 21, 2021

Volume XI, Number 21

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What’s Going on with the Brexit Transition Period? — A Conversation with Jane S. Vergnes, Ph.D. [PODCAST]

Lynn L. Bergeson, Managing Partner, B&C, and President of The Acta Group (Acta®), and Jane S. Vergnes, Ph.D., DABT®, Director of Toxicology, B&C, and Vice President of Scientific Affairs, Acta, recently dedicated an hour to all things Brexit and its effect on chemical industry stakeholders.  Dr. Vergnes leads Acta’s UK and Brussels offices and has been deeply engaged in EU Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and the impact of Brexit on Acta’s EU, UK, and U.S. clients.  At the end of this year, REACH regulation will no longer apply to chemicals that require registration in the UK, with an amended regulation known as UK REACH coming into effect.

Dr. Vergnes shares with listeners that in-progress chemical registrations under REACH are in limbo because UK entities will cease having legal status in the EU on January 1, 2021.  The only registrations that could go forward are those completed before the end of the transition period on December 31, 2020.  For a UK entity, the best path forward has been to appoint an Only Representative (OR) or to use one of their affiliates that remains within the 27 EU countries to process the registration under REACH.  This process applies only to chemical registration in the EU, and there is currently no agreement between the EU and UK to share REACH registration data that would allow chemicals registered under REACH to be grandfathered into UK REACH.

In addition to a thorough exploration of the transition period and the launch of UK REACH, Ms. Bergeson and Dr. Vergnes cover new obligations issued recently of which EU REACH registrants must be aware.  These include how the transition relates to biocides and plant protection products and what to expect at the end of the year.  Brexit has invited no small amount of uncertainty and anxiety for chemical stakeholders, especially against the backdrop of an already uncertain world.  This episode of All Things Chemical provides comforting clarity and useful thoughts on what to do as the transition period comes to an end.

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© 2020 The Acta Group All Rights ReservedNational Law Review, Volume X, Number 336
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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

202-557-3801
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