Over the last few months, the UK Government has been
publishing a series of "technical notices" outlining the
implications for businesses if the UK exits the EU without having
secured an exit agreement. This is the third instalment in our
series (see
Part I and
Part II), in which we focus on post-Brexit proposals for the
regulation of chemicals. More parts to follow.
It seems continuity is king when it comes to the
Government's no-deal plans for chemicals. This is perhaps not
surprising given the notorious complexity of the EU regime (the
REACH Regulation alone numbers over 800 pages, and took the best
part of a decade to draft). While this approach should smooth the
transition in the short term, this means the law in this area will
remain just as complicated as under the EU regime. What's more,
by aping the European approach and setting up separate UK regimes
for application and registration, the Government has doubled-down
on the administrative burden for those
