All Chemicals used by the composites sector are currently regulated under the EU REACH regulation administered by the European Chemical Agency (ECHA). When the UK leaves the EU, the UK government is proposing to set up a duplicate UK REACH system – this will be managed through HSE under the government department of DEFRA. This means that a company supplying chemicals will have to register the substance twice, once on each system, which comes with an additional cost for both registration and data submission.
It is a concern of the Material Suppliers subgroup that some key raw materials will become unavailable in the UK market due to the costs of registration and costs of obtaining data whilst at the same time being available within the EU market. The group believes the scale of the knock-on effect has not been fully understood or considered for both our sector and many others, and that this will be especially pertinent to the use of small-scale additives which are extensively used in our sector.
Whilst the previous Brexit deal had some provision for negotiating regulatory alignment with the EU, the current one does not. We thus ask that those involved in the UK composites industry consider lobbying their local MP on this matter to ensure the issue is brought to the attention of government when they come to consider the details of the future relationship with the EU.
Composites UK will continue to provide evidence to central government on the matter.
This briefing was prepared by the Composites UK Materials Suppliers Sub Group.