John Caunt Scientific Ltd Operates as JCS Nuclear Solutions (JCS).

To ensure JCS is prepared for all and any eventualities as a consequence of BREXIT, studies have been undertaken for the various scenarios that have thus far been articulated, or can be contemplated, including a “hard BREXIT” and a “no-deal”. 

The following areas are the key ones identified by JCS:

1. REGULATORY ISSUES
2. CUSTOMS AND VAT
3. MOVEMENT OF GOODS ACROSS EUROPE

REACH 

On exit from the EU and without any agreement to the contrary, the UK will become a so-called “third country”.  Placing Substances manufactured in the UK in the EU market will still be subject to REACH obligations but placing these Substances in the UK market will become subject to UK legislation.  The form of that legislation, or the possibility that REACH may apply across the EU-UK border, is still the subject of political discussion and negotiation. Whilst JCS hopes sincerely that the situation post-BREXIT is one where either the UK remains within EU REACH, or the UK adopts EU REACH into UK law in full or with minimal amendment, JCS will in any event be taking the appropriate action to ensure that its products are compliant with EU REACH legislation and any new UK legislation. 

CLP 

CLP is the EU implementation of the Globally Harmonised System of Classifications and Labelling (GHS).  On exit of the EU the UK Government has determined to transpose existing EU regulation into UK law.  We believe that, at the point of exit, there will be little change to the application of CLP.  Whilst there would remain the possibility of divergence into the future JCS will ensure that products remain compliant with all applicable versions of GHS globally. 

ADR 

ADR is a 1957 United Nations treaty that governs transnational transport of hazardous materials.  It is derived from the French name for the treaty “Accord européen relative au transport international des merchandises Dangereuses par Route”.  The UK is a member (not via the EU) and applies ADR with minimal exceptions.  It is anticipated that there will be no changes following BREXIT. 

DUTIES AND TARIFFS 

When leaving the EU, the UK will become a “third country”.  It is our hope that the UK and the EU will reach an agreement whereby trade can continue without being subject to customs tariffs.  However, if no agreement is made, WTO tariffs would come into force, for trade between the UK and EU and between the UK and the rest of the World.  The rates would be dependent on the respective product categorisation.  It is our hope that the UK would continue to make inward processing available, which would eliminate or mitigate some of the impact of the duty tariff. 

CUSTOMS PROCESSES 

Moving goods from the UK to the EU is likely to change, in terms of customs and VAT procedures – for example, export declarations may be required for goods leaving the UK and import declarations may be required for goods arriving in the EU.  JCS will take appropriate action to ensure that its procedures are in line with any new legislation and its supply chains are appropriate to maintain continuity, timeliness and efficiency of supply. 

Currently the movement of goods between the UK and EU benefits from “mutual recognition”.  We hope that this will continue.  The future legislation will determine how the goods are treated.  JCS will look to take steps to maintain effective supply chains. 

European Commission fact sheet  

The European Commission have also issued a fact sheet giving further information about how businesses in the EU27 might prepare for the UK’s withdrawal.  You might have already seen this fact sheet, but a copy can also be found online at: https://ec.europa.eu/taxation_customs/uk_withdrawal_en 

As the picture becomes clearer, JCS is increasing its level of preparedness internally and with its key stakeholders, to maintain the continuity of supply of our products to customers in the UK, the EU27 and the rest of the world. 

It is JCS’s intention that it will continue to be fully compliant and fully capable in all aspects 

of its business whatever the outcome of the BREXIT deal negotiations. In anticipation of this activity, JCS would like to thank you for your engagement in that discussion and any resulting actions. 

If you have any questions, please notify these through your normal JCS contact or directly to the undersigned. 

Oliver Caunt

Managing Director