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GENEVA (AP) The European Union, the United States and other donors on Tuesday pledged billions in new funds for Afghanistan, hoping to salvage years of work aimed to foster peace and stability in the country and coax along uncertain peace talks between the government and Taliban rebels at a time when Islamic State extremists have increasingly caused havoc and bloodshed.

A largely virtual pledging conference for Afghanistan, co-hosted by Finland and the United Nations in Geneva, drew representatives from nearly 100 countries and international groups in the first such event in four years. It comes as the COVID-19 crisis has commanded worldwide attention, and its outbreak in Afghanistan has compounded persistent ills like corruption and extremist violence.

Many countries set conditions for their future commitments, mostly on progress toward peace and demands for better governance to foster democracy and root out corruption.

Donors pledged more than $3 billion for the first year of the upcoming quadrennial, with annual commitments expected to stay at the same level year on year, said Ville Skinnari, Finlands minister for development, cooperation and foreign trade.

That $12 billion was a rough estimate extrapolated from the pledges for next year alone, officials said, adding that donors would review their commitments each year. Even at $12 billion, it marked a drop from the more than $15 billion drummed up at the last such conference in Brussels in 2016.

Mohammad Haneef Atmar, Afghanistans foreign minister, hailed an impressive figure tallied on Tuesday, adding: Its more important because it comes at a time when there is hardly any nation that has not been affected by COVID-19 in its economy and revenue.

That represents an enormous amount of generosity when every nation has had its own challenges, that on top of that, it did not forget about our shared responsibility to succeed in Afghanistan, he said.

Countries like Britain, the Netherlands, Germany, the U.S. and Canada offered hundreds of millions in pledges, which came after speeches from officials like Afghan President Ashraf Ghani and U.N. Secretary-General Antonio Guterres, who hailed the countrys ambitious agenda for development and reform.

The United Nations stands with the people of Afghanistan on the path toward peace, development and self-reliance, Guterres said, expressing hope that donor pledges will translate into real progress and concrete improvements for the people of Afghanistan.

That was a familiar refrain about Afghanistan, where progress has been underpinned by international support and remains fragile, amid perennial hopes that peace and stability can emerge.

Nearly 20 years after a U.S.-led international coalition toppled the Taliban government that supported al-Qaida, Afghanistans woes remain complex and its future uncertain. Violence has increased in recent months, Taliban rebels and the government are currently taking part in peace talks in Doha, Qatar; and the Trump administration recently announced a further drawdown of U.S. forces.

Even as the meeting took place, a roadside bomb exploded in the central Afghan city of Bamyan, killing at least 13 civilians and a traffic police officer, and wounding 45 others, an Afghan official said. No one immediately claimed responsibility. But the IS affiliate has claimed responsibility for the most recent attacks in Afghanistan, including two that killed at least 50 people mostly students.

While hoping to help along the peace talks, donors pointed to their own commitments both with forces and funds over the years, and warned that their continued help would be contingent on efforts by Afghans themselves and no backsliding on progress. Many of the commitments were for a four-year span from 2021 to 2024. others were for just one year.

The EU pledged 1.2 billion euros ($1.43 billion) in assistance to Afghanistan over the next four years but joined others by making its support conditional on the strife-torn countrys commitment to democracy, the rule of law, human rights and gender equality.

Afghanistans future trajectory must preserve the democratic and human rights gains since 2001, most notably as regards womens and childrens rights, EU foreign policy chief Josep Borrell said. Any attempt to restore an Islamic emirate would have an impact on our political and financial engagement.

Germany pledged another 430 million euros (about $510 million) per year through 2024, Foreign Minister Heiko Maas said.

U.S. Secretary of State Mike Pompeo said the Doha talks offered a new and unprecedented opportunity set for peace and prosperity, but noted that Afghanistan faced challenges such as the pandemic from Wuhan, and unacceptably high levels of violence, alluding to the COVID-19 outbreak that began in China.

I want to be clear that the choices made in peace negotiations will affect the size and scope of future international support and assistance. The United States looks forward to reviewing progress in the areas I mentioned in one years time, Pompeo said.

U.S. Undersecretary for Political Affairs David Hale added that Washington would pledge $600 million for Afghanistan in 2021, but only half would come now with the remaining $300 million available as we review progress in the peace process.

Hale cited significant progress in negotiations in Doha on Tuesday including a tentative agreement on rules and procedures that should allow the negotiators to move ahead to start setting an agenda. But he also said the U.S. was monitoring disturbing reports about unspecified efforts to delay, disrupt and for the progress for which the negotiating teams have worked so hard.

Hales comments signaled the first sign of progress since the two sides in the Afghan talks sat down in Doha on Sept. 12. The government team was likely to demand the first item on an agenda be a cease-fire a prospect that the Taliban have until now refused to accept.

Atmar, the Afghan foreign minister, said the two sides had reached an agreement on 20 points but one on the legal basis for the negotiations remained unresolved. He expressed hopes that if the logjam is resolved in the coming days, it would mark a huge step in the peace process.

Deborah Lyons, the U.N. secretary-generals special envoy for Afghanistan, said the country was facing a time of unprecedented opportunity but also deep uncertainty and rising anxiety, and said Afghans were committed to preserving the gains of recent years but needed ongoing support from abroad.

Now is not the time to walk away, said Lyons. In the past, she has said that despite some progress, Afghanistan remains one of the worst places in the world to be a woman or a child. She has criticized a sharp rise in casualties in the fighting, both from Taliban assaults and U.S. and Afghan bombing raids.

Statistics in Afghanistan are still grim after decades of help. The poverty level during the COVID-19 pandemic has shot up to 70% up from 54% last year. Despite billions of dollars that have poured into the country in the last two decades, more than half the population lives on $1.14 a day. A U.S. watchdog has said over $19 billion of U.S. money alone had been lost to abuse, fraud and waste.

Ghani touted a strategic plan for Afghanistan, acknowledged lessons learned from abroad, pointed to the development of a robust civil society and free press, among other gains

A new Afghanistan has emerged over the past two decades, and with it, an entirely new set of expectations from our citizens, Ghani said by video. The main theme of our development agenda is to meet these new expectations by doing much more with much less in the face of daunting challenges.

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US, European Union, other donors step up with funds to help Afghanistan - FOX40

On 12 October 2020, the Council adopted Decision (CFSP) 2020/1466[1].

The Council Decision renewed the existing restrictive measures until 16 October 2021, and updated one entry on the list of natural and legal persons, entities and bodies subject to restrictive measures as set out in the Annex of Decision (CFSP) 2018/1544.

The Candidate Countries the Republic of North Macedonia, Montenegro and Albania[2], the country of the Stabilisation and Association Process and potential candidate Bosnia and Herzegovina, and the EFTA countries Iceland and Norway, members of the European Economic Area, as well as Ukraine and Georgia align themselves with this Council Decision.

They will ensure that their national policies conform to this Council Decision.

The European Union takes note of this commitment and welcomes it.

[1] Published on 13.10.2020 in the Official Journal of the European Union no. L 335. p.16.

[2] The Republic of North Macedonia, Montenegro and Albania continue to be part of the Stabilisation and Association Process.

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Declaration by the High Representative on behalf of the EU on the alignment of certain third countries concerning restrictive measures against the...

Swedish Prime Minister, Stefan Lfven, holding a press conference during the European Council Meeting in June 2017. Photo: European Council

As the final piece of our series on Swedens Arctic strategy, this article seeks to shed light on two key characteristics of Swedens EU policy in general. In doing so, it, where applicable, seeks to use Arctic related examples in order to demonstrate or support its arguments.

For Sweden, joining the European Union (EU) was more than just joining an economic club. The EU was portrayed as a political union that would not only allow Sweden to play a more active role in global affairs. Rather, it would also enable Stockholm to regain and strengthen its European identity while simultaneously influencing the EUs institutional and doctrinal developments. Conservative politicians were particularly relentless in their promotion of discourses which essentially equated neutrality with isolationism and the EU membership as a sign of active internationalism.1)Agius, C. (2011), Transformed Beyond Recognition? The Politics of Post-Neutrality. Cooperation and Conflict. Vol. 46(3), pp. 370395

As such, and to further boost their chances of a desired transition to post-neutrality, a concerted and well-orchestrated campaign of media leaks and agenda setting took place which effectively helped to de-mythify the delusion of neutrality.2)Agius, C. (2011), Transformed Beyond Recognition? The Politics of Post-Neutrality. Cooperation and Conflict. Vol. 46(3), pp. 370395 Not only did newspapers begin reporting on Swedens secret arrangements with Western powers but many pundits and politicians alike were now arguing that states can never be truly neutral and hence it (neutrality) had a false relationship to the identity of the nation state.3)Agius, C. (2011), Transformed Beyond Recognition? The Politics of Post-Neutrality. Cooperation and Conflict. Vol. 46(3), pp. 370395

Once in the bloc, Stockholms policy stances and its broader conduct have been largely dual in nature: to play a leading role in setting policy norms4)Bjrkdahl, A. 2008. Norm Advocacy: A Small State Strategy to Influence the EU. Journal of European Public Policy. Vol. 15(1), pp. 135-154 while retaining a high degree of strategic independence so it can go its own way when its interests clash with those of other EU Member States.5)McCallion, M, S. and Brianson, A. (2017). How to Have Your Cake and Eat It Too: Sweden, Regional Awkwardness, and the European Union Strategy for the Baltic Sea Region. Journal of Baltic Studies. Vol. 48(4), pp. 451-464 And in spite of the common belief, it has not, at least not systematically, sought to form and lead a common Nordic block within the EU. On the contrary, it has been in a soft competition over status and influence with its Nordic counterparts.6)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

Starting with its decision to stay out of the Monetary Union, Sweden has demonstrated a persistent determination to follow its own path in the EU and that it has not shied away from revealing policy preferences that differ from the majority of EU members on issues of the environment, social policy, and defence.7)McCallion, M, S. and Brianson, A. (2017). How to Have Your Cake and Eat It Too: Sweden, Regional Awkwardness, and the European Union Strategy for the Baltic Sea Region. Journal of Baltic Studies. Vol. 48(4), pp. 451-464 Its response to the COVID pandemic is the latest example of this tendency for independence.

This attitude, in turn, has its root in Swedens initial reluctance to join the bloc, its desire for the preservation of its strategic and decision making autonomy, and a sense of, albeit narrowing, uniqueness all of which collectively have earned it the reputation of awkward partner.8)McCallion, M, S. and Brianson, A. (2017). How to Have Your Cake and Eat It Too: Sweden, Regional Awkwardness, and the European Union Strategy for the Baltic Sea Region. Journal of Baltic Studies. Vol. 48(4), pp. 451-464 In other words, Swedish awkwardness, or its awkward attitude towards regional integration processes within the EU, has both ideational and material underpinnings.

Moreover, some scholars claim that Swedens conduct within the EU and its general attitude towards the bloc is best described as one revolving around a solid logic of quid pro quo or delicate balancing; that is, it seeks to contribute to certain initiatives or policies in order to stay outside certain others without opening itself to criticism.9)Von Sydow, G. (2004). Frn Ordfrandeskap Till Utanfrskap. Stockholm: SNS Frlag For instance, Von Sydow10)Von Sydow, G. (2004). Frn Ordfrandeskap Till Utanfrskap. Stockholm: SNS Frlag claims that Sweden participated in and contributed to the EUs common foreign and security policy framework in order to cushion its rejection to join the Monetary Union.

With regard to the Arctic, it has been consistent in its call for the articulation and implementation of common European environmental policy frameworks11)Khorrami, N. (2019). Reviewing Stockholms Strategy for Sustainable Regional Development in the Arctic. Available from https://www.thearcticinstitute.org/stockholm-strategy-sustainable-regional-development-arctic/ but it has resisted initiatives, such as the Northern Dimension (ND), which facilitate a strong and active role for Brussels in the regions defence and security sectors.12)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

Put briefly, the main disagreement between the two with regard to ND boils down to their opposing view on and the weight they assign to the EU and its role within the Baltic Sea and Northern Europe. While Finland prefers a wide-ranging and expanded role for Brussels in the region, Stockholm has traditionally favoured a limited role for the EU and instead has sought to put in place a distinctively regional mechanism for the management of regional affairs with itself at the realm.13)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

Sweden has been commonly identified as a staunch norm entrepreneur within the EU.14)Bjrkdahl, A. 2008. Norm Advocacy: A Small State Strategy to Influence the EU. Journal of European Public Policy. Vol. 15(1), pp. 135-154 Given its lack of military and economic power, Stockholm has consistently utilised its normative credentials to influence, and contribute to, the development of the EUs normative power ever since its joining of the bloc.

As a world leader in environmental sustainability and home to an environmentally conscious population, for example, Stockholm has sought to influence the EUs climate change and Arctic strategies by contributing to the articulation and implementation of detailed measures aimed at reducing global emissions of greenhouse gases.15)Khorrami, N. 2019. Swedens Arctic Strategy: An Overview. Available from https://www.thearcticinstitute.org/sweden-arctic-strategy-overview/ Similarly, it has been relentless in its efforts to ensure that EUs Arctic policies are, at least partly, reflexive of its own ideals of individual rights to security and prosperity, and thus enough attention is paid to the needs and interests of local communities and their resiliency.16)Khorrami, N. 2019. Swedens Arctic Strategy: An Overview. Available from https://www.thearcticinstitute.org/sweden-arctic-strategy-overview/

To this end, it has used various techniques and tactics, including framing, agenda setting, and use of presidency, in order to promote its own values and interests and align EU foreign and strategic decision making with its own. The EU is an ideal platform or arena for such undertakings since there is a natural synergy between its norms and values as a peace project and those of Stockholm as a liberal democracy.17)Bjrkdahl, A. 2008. Norm Advocacy: A Small State Strategy to Influence the EU. Journal of European Public Policy. Vol. 15(1), pp. 135-154

For a small state like Sweden in particular this is of paramount importance because it enables it to exercise power and yield influence by transferring its own domestic norms into the decision making procedures of a larger and more powerful actor. Norms and their wide adaptation do influence action and decision making and thus one can gain authority if its norms and values guide conduct and behaviour.18)Bjrkdahl, A. 2008. Norm Advocacy: A Small State Strategy to Influence the EU. Journal of European Public Policy. Vol. 15(1), pp. 135-154

There is a common assumption outside academic circles that Nordic members of the EU act in tandem, and that they tend to coordinate their policy stances at the EU. Their common history, close socio-cultural links, and geographical proximities are commonly singled out as the key facilitating factors.

However, a closer look at their conducts demonstrate a rather wide-ranging and substantial level of soft competition and disagreement over numerous issues.19)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

Part of this soft competition is due to their differing historical trajectories as well as political and national identities. This creates differing threat perceptions and interests with regard to the role of the EU in their region and how best to address security and commercial challenges.20)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

However, it is also due to their rivalry over status whereby these very similar nations small and well functioning democracies seek to outcompete one another over both the attainment of leadership pole in their own subregion and greater strategic worth in the eyes of their mightier European counterparts.21)Wohlforth, W, C, Carvalho, B, D, Leira, H, and Neumann, I, B. (2018). Moral Authority and Status in International Relations: Good States and the Social Dimension of Status Seeking. Review of International Studies. Vol. (44)3, pp. 526546 In fact, the nature of this status rivalry is particularly fierce amongst relevant comparison or ideational groups simply because they all have similar attributes and thus differentiating oneself from others could become a complex, and at times controversial, affair.22)Wohlforth, W, C, Carvalho, B, D, Leira, H, and Neumann, I, B. (2018). Moral Authority and Status in International Relations: Good States and the Social Dimension of Status Seeking. Review of International Studies. Vol. (44)3, pp. 526546

This is best demonstrated if one analyses Finland and Sweden. Given their common EU membership and close historical and communal ties, one might assume that they both pursue a similar strategy towards the Arctic. Until very recently, however, this had hardly been the case.

While Finland prefers a wide-ranging and expansive role for Brussels in the Arctic that include defence and security,23)Heininen, L. (2014). Foreign Policy Interests of Finland in the Arctic in Spruds, A and Rostoks, T. (2014) Perceptions and Strategies of Arcticness in Sub-Arctic Europe. Riga: SIA Hansa Print Stockholm has traditionally favoured a limited role for the EU when it comes to security policy. Instead it has sought to put in place a distinctively regional mechanism for the management of regional affairs with itself at the realm.24)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390 This explains why Stockholm persistently sought to frustrate Brussels and Helsinki efforts in implementing the Nordic Dimension. 25)Gebhard, C. (2013). Soft Competition: Finland, Sweden and the Northern Dimension of the European Union. Scandinavian Political Studies. Vol. 36(4), pp. 365-390

Overall, given its track record on Arctic related policies and initiatives at the EU as well as the minimal mentioning of the EU in its 2011 Arctic Strategy Document,26)There are only five sentences on the role of EU in the Arctic it is fair to suggest that Stockholms policy towards the block as an Arctic player has been traditionally ambivalent at best and unarticulated at worst. By a way of analogy, its attitude towards the EU in the Arctic has been akin to an individual who desires both having a committed partner and being in an open relationship simultaneously.

This, in combination with its soft competition with other Arctic states of the EU, in turn, have been a complicating factor in EUs efforts to develop a coherent Arctic strategy even though Brussels has, arguably, benefited from the Nordic states soft competitions; they have had the effect of halting the emergence of a united Nordic bloc.

Based on its recently released Arctic Strategy, however, it appears that Stockholms attitude towards the EU is softening; that is, it is now, similar to Helsinki, calling for a strong EU presence in the region.

A resurgent Russia, a declining America, and an overall increase of commercial and military activities by both Arctic and non-Arctic states seem to have convinced Swedish decision makers that the EU provides the least bad option in their search for a reliable economic and defence/security partner; at the very least, they can influence decision making in Brussels. Both Nordic cooperation as well as old in case of the US and new in case of Canada bilateral relations are still deemed as essential. However, it is the EU which is now at the centre-point of the countrys Arctic strategy. And the fact that its new Arctic ambassador is a veteran EU diplomat adds a degree of cogency to this observation.27)Raspotnik, A. 2020. The Great Illusion Revisited: The Future of the European Unions Arctic Engagement. Available from https://www.kas.de/en/web/nordische/single-title/-/content/the-great-illusion-revisited-the-future-of-the-european-union-s-arctic-engagement

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Partnership with a Healthy Dose of Distance: Sweden's Changing Attitude towards the EU as an Arctic Player - The Arctic Institute

OVERVIEW

As the post-Brexit transition period comes to an end on 31 December 2020, options to ensure compliance and uninterrupted trade for businesses placing chemical substances and mixtures on the UK and EU markets are becoming considerably limited. However, there is still time to take the necessary steps, such as transferring EU REACH registrations, to maintain immediate access to the EU and UK markets with minimal expense.

Businesses that do not directly manufacture or trade chemicals but use chemical substances in their products, such as cosmetics, medical devices, EEE or industrial applications, may also be impacted if their suppliers have not taken necessary action.

This alert summarises how chemicals will be regulated as of 1 January 2021 in the United Kingdom and what businesses need to doas a matter of urgencyif they have existing REACH registrations or if they intend to continue selling chemicals in the United Kingdom.

Where We Are

The United Kingdom left the European Union on 1 January 2020 and is currently in a transition period ending on 31 December 2020, during which all EU regulations, including REACH[1] and CLP[2], will continue to apply as before. The European Union (Withdrawal) Act 2018 (as amended by the European Union (Withdrawal Agreement) Act 2020) ends the supremacy of EU law in the United Kingdom and converts all EU law into UK legislation by 1 January 2021.

The UK authorities had initially hoped for the United Kingdom to remain a non-voting member at the European Chemicals Agency (ECHA), with UK businesses retaining the mandatory registrations for chemicals imported into the European Union and the United Kingdom with ECHA, as well as directly registering new substances with the ECHA. In February 2020 it became clear that the UK Government would no longer pursue associate membership with ECHA or be bound by EU chemicals legislation, and would instead develop its own chemicals regulatory system whilst striving for cooperation between the United Kingdom and the European Union.

The UK Governments negotiating document published in May 2020, the draft Comprehensive Free Trade Agreement (CFTA), sets out guidelines for the new UK regulatory regime for chemicals. CFTA Annex 5-E confirms the UK and the EU authorities commitment to cooperate on chemicals compliance and reiterates the importance of the UN globally harmonised system as well as OECD scientific and technical guidance. However, Annex 5-E clearly sets out that the United Kingdom will be setting its own priorities on chemicals regulation, including establishing its own levels of protection in respect of the environment, and human and animal health going forward, including having independent rules on trade.

It is most likely that the United Kingdom will retain its commitment to an independent regulatory regime for chemicals even if a trade deal is achieved with the European Union at the last minute.

UK-Based REACH Registrants

The EU REACH Regulation requires importers and manufacturers placing chemical substances on the EU market above one tonne per year to register such substances with ECHA. The last REACH registration deadline in the European Union was in May 2018, which means that the majority of businesses involved in the manufacture or import of chemicals in the European Union, including the United Kingdom, are not able to sell such chemicals unless they have existing REACH registrations.

ECHAs guidance for UK businesses holding REACH registrations has not changed since our previous alerts: on 1 January 2021 such registrations will be void, and the UK registrants will lose access to their REACH-IT accounts unless the registrations are validly transferred to an EU entity before the end of the transition period.

In principle, before the transition period is over, UK manufacturers can appoint Only Representatives (ORs) to take over their REACH registrations, UK importers can relocate their business functions to a new or existing EU group entity alongside with the REACH registrations, and non-EU manufacturers with an OR in the United Kingdom can appoint a new representative in Europe. However, transfers must be made in accordance with REACH and ECHAs guidance:

With so little time remaining, UK-based registrants that have not yet taken action should do so promptly, particularly if a new entity in the European Union must be established. Certain EU jurisdictions have longer lead times as well as hefty requirements for incorporation of a company, and thus considerations must be made on the costs and timing.

In addition to transfer of the REACH registrations, ECHAs recent Brexit guidance takes into account the Protocol on Ireland and Northern Ireland, and provides further advice to the UK entities on Poison Centre notifications post-Brexit, transfer of authorisations under the Biocidal Products Regulation, and changes with respect to classification and labelling.

A New UK Regime: Overview

The EU REACH Regulation provisions are by-and-large retained in the new UK legal act REACH etc. (Amendment etc.) (EU Exit) Regulations 2019 (UK REACH), as amended. Registration, evaluation, authorisation and restriction obligations are also set to apply under UK REACH, as are the classification and labelling rules based on the UN globally harmonised system.

UK Health and Safety Executive (HSE) will take over ECHAs functions in the United Kingdom and act as the lead regulatory authority under UK REACH. HSEs new responsibilities will include evaluating applications for registrations, coordinating the Candidate List of substances to be evaluated for authorisation, and evaluating restrictions. The Secretary of State will take over some functions currently performed by the European Commission, for example deciding on whether applications for authorisations should be granted.

To support the functioning of the new UK regime, the UK Department for Environment, Food and Rural Affairs (DEFRA) has been developing the United Kingdoms own REACH-IT portal, Comply with UK REACH. The new UK IT system, set to go live on 1 January 2021, will use the same software platform as REACH-IT (the International Uniform Chemical Information Database, or IUCLID).

UK REACH will be enforced by DEFRA and the Department for Business, Innovation and Skills as well as the Devolved Administrations for Scotland, Wales and Northern Ireland. It is yet to be seen how the penalties will change from those currently in force, if at all.

Northern Ireland will be subject to different rules from the rest of the United Kingdom, and EU REACH will continue to apply in Northern Ireland by virtue of the Northern Ireland Protocol. Both HSE and ECHA have published guidance specifically for businesses located in Northern Ireland. Because of the ongoing dispute between the United Kingdom and the European Union on the draft Internal Market Bill, the guidance from HSE and ECHA differs. ECHAs guidance regards transfers of chemicals from Great Britain to Northern Ireland as imports into the European Union, whereas HSEs guidance indicates that Northern Ireland will remain part of the UK customs union. The position in respect of Northern Ireland likely will become clearer as the EU-UK negotiations progress.[3]

Transitional Provisions and Key Changes

In an attempt to minimise disruption, UK REACH foresees transitional provisions for the registration of chemical substances placed on the UK market, and rules for downstream users purchasing such substances from non-UK suppliers as well as covering other regulatory processes in relation to restrictions, authorisations or identifications of substances of very high concern (SVHC). Whether companies can take advantage of these transitional provisions will depend on their role in the supply chain and which jurisdiction they are established in. HSE and DEFRA recently published further guidance on how each actor in the supply chain can prepare for the end of the transition period, although such guidance so far still remains rather basic.

EU REACH registrations held by UK entities can be carried across to UK REACH-IT (grandfathered) by opening an account on UK REACH-IT and submitting the required information to HSE by the deadlines set out in the table below. UK entities that held EU REACH registrations at any time in the period between 29 March 2017 and 31 December 2020 will also be able to benefit from the grandfathering provisions, even if such registrations have been transferred to an EU entity before 31 December. UK downstream users relying on an EU REACH registration will be able to continue importing after 1 January 2021 but will need to notify HSE using a Downstream User Import Notification (DUIN) by 27 October 2021.

Similar grandfathering provisions will apply to EU REACH authorisations held by UK-based entities or relied upon by UK-based downstream users. Article 9 exemptions (PPORDs) will also be carried over into UK REACH provided HSE is notified with the relevant information.

No grandfathering is foreseen for the REACH registrations held by EU-based entities that export substances to the United Kingdom. If such entities want to place substances on the UK market, they will need to make an inquiry with UK HSE and a subsequent new registration through a UK-based OR (if they are a manufacturer), by establishing a new UK entity acting as an importer, or by asking their UK-based customers to register.

Although HSE has provided no guidance yet, it is possible that in practice EU-based entities will not have to register until 2023, 2025 or 2027, respectively, as imports of such substances will be covered by the downstream users notifying to HSE. However, it remains unclear what action such entities should take if they wish to register before the established registration deadlines but no lead dossier has yet been submitted. Unfortunately, new entrants to the market without any prior REACH registration will find themselves in a similar situation.

In any event, all registrations which are not grandfathered will be subject to the same fees as currently charged by ECHA, ranging from approximately 1,000 per substance for the smallest tonnage band to 25,000 for the highest tonnage band registrants.

We summarise the key deadlines and the differences in certain regulatory processes between the EU and UK REACH regulations below.

UK REACH Regulatory Obligations

Data Sharing Issues

When grandfathering EU REACH registrations or registering from scratch as a UK manufacturer, importer or OR, EU REACH data must be transferred to the UK REACH-IT system for the review of UK authorities. There will have to be an agreement between the registrants as to who submits the data first, who can refer to it and how, as well as whether such legitimate access to data for purposes of UK registration will cost. Lastly, it will have to be determined who manages such data transfer and the UK REACH joint submission of data andwhere consortia managers existhow such work should be compensated. It is unlikely that any data sharing/consortia agreements grant powers to their managers to deal with UK REACH, and therefore the role and scope of their activities will also have to be reviewed.

Existing REACH Letter of Access agreements or Letters of Access for consortia members (where they exist) will likely only grant legitimate access to data for the purposes of EU REACH registrations. It will be a matter for individual companies to negotiate with their respective Lead Registrants or REACH consortia to determine whether the scope of the existing Letters of Access can be expanded to include UK REACH, or whether new Letters of Access will need to be granted, including the remuneration for such new access to UK REACH data. Similarly, where EU REACH dossiers rely on third-party data, Lead Registrant/REACH consortia will need to review their data sharing agreements and, where necessary, initiate data sharing negotiations.

Companies are reminded that the EU Implementing Regulation on Joint Submission of Data and Data Sharing should also be retained in the United Kingdom and as a result, data and cost sharing will have to follow the rules of transparency, non-discrimination and fairness, as well as provide detailed breakdowns with respect to the data costs where no waiver is agreed to.

It is also worth mentioning that new data constantly becomes available, including data currently being developed for purposes of complying with Korea REACH. As UK REACH will require registrants to take all available data into consideration when registering, the availability of new data in itself will be a new challenge when conducting available data review and negotiating costs for access to such data.

In conclusion, it is essential that companies requiring UK REACH registration start addressing data transfer issues as soon as possible so that all of the above issues are effectively addressed in time for the first registration deadline at the latest.

Practical Steps

We urge any company currently dealing with chemicals in the UK market to review how Brexit will affect them. Below are some practical steps to assist companies in reviewing their position:

Please note that as the situation with respect to the UK-EU negotiations is constantly evolving, the transitional provisions and deadlines set out above may be subject to change.

[1] Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals.

[2] Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures.

[3] Depending on the outcome of the negotiations references to UK should be read as being references to Great Britain only.

[View source.]

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Post-Brexit Chemical Regulation in the United Kingdom and the European Union - JD Supra

In May 2020, ECDC produced a set of short-term forecasts of the expected number of COVID-19 cases, deaths and hospitalised cases (subdivided into general hospital wards and intensive care units). Updated forecasts were published in September 2020. In this report we present slightly longer-term projections for each country, up until 25 December 2020.

Following widespread transmission of SARS-CoV-2 in the European Union (EU)/European Economic Area (EEA) countries and the United Kingdom (UK) over several weeks, the COVID-19 epidemic reached a peak in most of these countries in April or early May 2020. Following the implementation of non-pharmaceutical measures aimed at reducing contact rates between people, the number of confirmed cases and associated morbidity and mortality diminished sharply. In most countries, the intensity of these measures was subsequently lightened. By late October 2020, a resurgence of cases was observed in EU/EEA countries and the UK. As this was accompanied by increased hospital and ICU admissions and deaths the increase is considered to be a consequence of increased transmission, not solely increased testing rates. As a result, many countries have taken steps to re-introduce more stringent control measures to once again reduce the contact rate between people.

Mathematical modelling of SARS-CoV-2 transmission and associated COVID-19 disease is used to assess the potential progression of the epidemic within a population and to inform decision-making on potential interventions to ensure public health. The methodology inherently facilitates the quantification of uncertainty associated with these estimations and projections. In May 2020, ECDC produced a set of short-term forecasts of the expected number of COVID-19 cases, deaths and hospitalised cases (subdivided into general hospital wards and intensive care units). Updated forecasts were published in September 2020.

In this report we present slightly longer-term projections for each country, up until 25 December 2020. We continue to model a baseline status quo scenario, assuming all control measures in place in early November 2020 will be continued until the end of the projection period. However, we also include an alternative scenario which illustrates the potential impact on the number of cases, hospitalisations and deaths if the population returned to the behaviour they practised on 1 April 2020. We also illustrate the potential impact on hospitalisation rates if recently-implemented response measures are lifted before Christmas. The model is based on the epidemiological data and scientific evidence available at the time of publication. Further developments are anticipated as new information andepidemiological data become available.

The model was developed at ECDC and applied at a national level for EU/EEA countries and the UK. Mathematical models provide a helpful approach for quantifying uncertainty but their output should be interpreted and appraised in light of both the underlying assumptions and the completeness and potential bias of the data used to parameterise and calibrate them.

An assessment of the potential trajectory of disease and mortality caused by the COVID-19 pandemic, and the most appropriate response strategies, should be based on a comprehensive analysis of the specific epidemiological situation in each country, using modelling projections in context.

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Updated projections of COVID-19 in the EU/EEA and the UK - EU News