Germany decides on MR applications from UK if filed before Brexit

Date: 27 June 2019

On 26 June, the German Federal Office of Consumer Protection and Food Safety (BVL) published an important revision of an earlier German position concerning processing of applications after the Brexit. Mutual recognition applications filed in Germany before the date of the UK's exit from the EU will be processed and decided in Germany even after the Brexit. This change of policy is the result of several expedited proceedings at the administrative court in Brunswick (Az 9B 23/19, not published). The court kept explicitly open if this legal position will also be valid for MR applications filed after the date of the UK leaving the EU.
Click here to read the official BVL's note in German.

ECHA recommends companies to transfer registrations before the UK's withdrawal

Date: 4 April 2019

ECHA continues to recommend companies to prepare for the UK's withdrawal without a transition period, now expected to take effect on 13 April 2019, at 00:00 hours CET (i.e. 12 April 2019, 11 p.m. UK time). For more information, view ECHA's news release.

RMS switch due to Brexit: A number of biocidal active substances have been assigned to new RMS

Date: 3 April 2019

Commission Delegated Regulation (EU) 2019/227, applying from 30 March 2019, amends Regulation (EU) No 1062/2014 as regards certain active substance/PT combinations for which UK was the designated evaluating competent authority (eCA). In its Annex, it provides a table (on active substance/PT combinations and respective Rapporteur Member States) which replaces Annex II to the Delegated Regulation (EU) No 1062/2014. It defines the new eCAs taking over the role of eCA from the UK.

Regulation (EU) 2019/227 also defines the time lines for the new eCAs to inform the participants of the fees payable under Article 80 (2) of Regulation (EU) 528/2012 (BPR) and to send the assessment report and conclusions.

Impact of Brexit on parallel trade of plant protection products

Date: 8 March 2019

On 6 March 2019, the German Federal Office of Consumer Protection and Food Safety (BVL) published a note stating that, in the event of a no-deal Brexit, Germany would not recognise parallel trade permits issued for plant protection products, sourced in the UK, unless permits have been prolonged. The German position corresponds to the official statement of the European Commission. Click here to read the official BVL's note in German.


NL pic vol19 no1Vol. 19, No. 1 – SCC Newsletter – Brexit/Chemical Substances

Date: 27 February 2019


Whereas the political uncertainty about the withdrawal agreement and about the Brexit overall seems to continue forever now, we urge our clients not to wait until the last week in March 2019 with decision making in the desperate hope of getting final clarity about the future contractual agreements between all the parties involved. If a ‘no deal’ scenario was to materialize that late in the process, severe supply and market disruptions would be impossible to avoid. We thus strongly encourage you to prepare for the worst and secure your business critical supply relations for chemical substances and products while continuing to hope for the best.

The SCC key contact for all Brexit queries is This email address is being protected from spambots. You need JavaScript enabled to view it., Head of Chemicals/REACH, Consumer Products, Cosmetics, Feed & Food Additives.

We would love to hear what you think about the SCC newsletter, so please do not hesitate to share your feedback and comments with us. Please contact us by e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it..

read more

Registration of plant protection products – Germany pursues EU Commission’s policy on Brexit

Date: 27 February 2019

The German Federal Office of Consumer Protection and Food Safety (BVL) has officially confirmed that it is going to take the position of the European Commission on Brexit, intending to treat the United Kingdom as a “third country” after the withdrawal deadline. From that moment on, the Regulation 1107/2009 will consequently cease to apply for the UK.
Please read the full communication in German on the BVL’s website.

New Communication on RZMS and Brexit

Date: 26 February 2019

The interest group PPP Zonal has recently uploaded the following document on CIRCABC: Communication Central Zone on ZRMS and Brexit.pdf.
This document answers the question what happens when the UK is zRMS (Zonal Rapporteur Member State). Read the communication on the CIRCABC website.

HSE offers stakeholder events preparing for EU Exit in a no-deal scenario

Date: 18 February 2019

The Health and Safety Executive (HSE) is holding a series of one-day stakeholder events across the UK covering EU Exit and its impact on the chemicals regimes in a no-deal scenario. For more information, please check the HSE website.

Recent guidance on the UK exiting the EU

Date: 7 February 2019

In preparation for the UK’s withdrawal from the EU, the British government organizes a one-day stakeholder event in Antrim, Northern Irland, on 26 February 2019. The event, presented by HSE (GB) and DEFRA, will cover the Brexit issue and its impact on chemical regimes in a no-deal scenario. Please click here, to view the details.
Further to this, Cefic and Chemical Industries Association (CIA) issued a briefing note on Brexit: Preparing for a future “UK out of REACH scenario” on 28 January 2019.
ECHA is also planning to publish a communications package to provide guidance to businesses placing chemical substances on the EU market in preparation of Brexit. SCC will follow up on this.