BREXIT - The immediate consequences for UK based Only Representatives (OR).

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BREXIT - The immediate consequences for UK based Only Representatives (OR).

NON-EU MANUFACTURERS- if you have a UK based OR this will affect you.

UK Based Manufactures if you do not have an OR currently appointed this will affect you.

Protect your registrations and pre-registrations done through your UK based OR and ensure that you appoint an OR that will be in the territory of the EU-27/EEA after UKs withdrawal from the European Union.

When the UK leaves the EU at the end of March UK based companies will no longer be able to act as Only Representatives for the purpose of REACH regulation 1907/2006, as according to REACH article 8, Only Representatives shall be legally established within the EU. After the UK withdrawal, this will mean the territory of the EU-27/EEA.  Companies that have appointed a UK based OR will need to appoint an Only Representative in one of the EU-27 Member States or the three EEA countries.

This change of Only Representative must take place ahead of the UK withdrawal (i.e. before end of March 2019). It must be notified to ECHA (through the ‘Legal entity change functionality’ in REACH-IT) without undue delay, and you will be required to provide proof of the new Only Representative’s appointment from the non-EU company. The registrations will have to be transferred to that new Only Representative, this will need to be completed by the new OR within 120 days after withdrawal.

Please note that the legal entity change fee (€1631) is a one-off fee and will be charged per non-EU company represented (i.e. per REACH-IT account), and not per substance registered. If the transfer is split into two stages or split between more than one OR the fee will be charged per stage or transfer.


In order for Cambridge Environmental Assessments (CEA), part of RSK ADAS Ltd., to be able to provide ongoing consultancy support and continued OR services to our clients from within the EU, CEA has set up a new legal entity as “CEA part of RSK ADAS Europe (Ireland) Ltd.”

The company is based in the offices of RSK Environment (Ireland) Limited, Office Suite B, Bluebell Business Centre, Old Naas Road, Dublin 12, Ireland.

CEA has already carried out this move for many of our non-EU clients moving their OR from CEA UK to CEA Ireland.

In addition to supporting our existing customers CEA can offer to provide an OR service for non- EU companies looking to move their OR from a UK based company to an EU based company and to UK based manufacturers that have not yet appointed an EU based OR to act on their behalf after the withdrawal. If this is a service we can assist you with please get in touch.

If you need help preparing for a no-deal EU exit, please contact Peter Godfrey ( or Sarah Henly ( to discuss how we can help.

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