February 27, 2018
A Brexit negotiator said to me recently: “Don’t talk to me about Single Sky.” This tells us how sensitive the issue is – and the same could be said for REACH!
The difference in attitude between the two negotiating teams is surprising. To this day the UK position remains unknown. But when I telephone the Barnier team, with no difficulty they give me lots of information about the 3 potential options.
Option 1 is British participation in the European Economic Area (EEA). REACH would continue to apply. But the UK would only have a consultative role in the system, and would have to accept free movement of workers (which it opposes).
Option 2, equally impossible, involves the UK creating a new system from scratch for 5,000 substances.
Option 3 comes under ‘Soft Brexit’ via mutual recognition of authorisations between REACH and the new British system, combined with co-operation between ECHA and whatever equivalent body is set up by the UK. The complexity will be even greater because producers established outside the EU (in other words, the British) will have to entrust all of their REACH dealings to an intermediary that is established in one of the EU-27, since the UK will have become a ‘third country’.
Without any doubt, this is a lose-lose situation.Daniel Gueguen