Letter explaining CPL’s position regarding REACH and supply chain protection post Brexit, from our Global Director of Product Safety and Compliance, Alan Osbiston

Posted

Brexit- Chemical legislation and Supply Chain                                                                     3rd December 2018

 

The Current Situation for Chemicals

 

Currently the UK chemicals industry is regulated through a framework largely based on the EU REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) legislation. REACH requires EU companies to register chemicals with the European Chemicals Agency (ECHA) before placing them on the market and puts in place additional controls on hazardous chemicals.

 

On March 29th, 2019 the UK will leave the European Union. If at this time no transition arrangements are in place, the UK will be immediately responsible for regulating chemicals through its own legislation and will be treated as a “third country” by the EU.

 

According to the GOV.UK website* the EU withdrawal Act would preserve REACH as far as possible. The Health and Safety Executive (HSE) will act as the lead UK regulatory authority, with a transition period for the UK registration of existing EU registered chemicals.

*‘Regulating chemicals (REACH) if there’s no Brexit deal’ is one of the technical guidance documents published on the GOV.UK website.

 

Implications and Actions for CPL

 

We are working with our suppliers to confirm that any raw materials produced, or imported into the UK in relevant quantities, with existing EU REACH registrations are automatically grandfathered into the UK regime.

 

We are also working with our suppliers to ensure that any raw materials produced and registered in the UK continue to be EU REACH compliant post Brexit so that any of our fragrances exported to EU are also compliant.

 

Supply Chain after Brexit

 

In case of delays at customs borders, following the UK’s exit from the EU, CPL has begun to take steps to mitigate potential supply chain disruption.

 

Only 10% of our raw materials come from the European continent. To mitigate any supply issues CPL will either build up our own stock or ensure UK agents of those producers build up adequate stock as contingency.

 

We will also ensure that our ERP system is updated with the possible longer lead times from these suppliers.

 

None of the fragrances supplied by CPL Aromas are imported from the other EU27 countries: all are made in the UK.

 

CPL has recently acquired dM fragrances of Spain based in Barcelona and formed CPL Aromas Spain. We are in the process of investing in the Barcelona site to increase its capacity and to bring it in line with the production facilities elsewhere in the group. In the case of significant supply chain disruption at customs borders we will be able to switch manufacturing sites as necessary to ensure continuity of supply to our EU based clients.

 

Alan Osbiston

Director Product Safety & Compliance