KHUSH INGREDIENTS, REACH, BREXIT & ORGANICS NOVEMBER UPDATE
Khush Ingredients would like to further update our customers in the UK and Europe about the consequences of the upcoming exit of the United Kingdom from the European Union. The main update is that the new expected BREXIT date of 31st January 2020 is likely to be extended again or be part of a managed withdrawal agreement. Therefore for 2020, we expect product supply to be unaffected by BREXIT / REACH.
As this is a changing situation, we will update via our website when/if any significant changes occur.
Please note that after BREXIT, all our EU customers will be supplied by Khush B.V. (our subsidiary company in the Netherlands).
We can assure our customers that Khush Ingredients intends to keep supply continuous and where necessary register more products for REACH and will seek to fulfil any obligations for the expected new REACH UK, post BREXIT. We are particularly looking at REACH UK and the expected ‘grandfather’ clauses that have been discussed.
IMPORTS FROM THE REST OF THE WORLD
Our intention is to supply our UK customers with materials from the rest of the world from our UK warehouse imported via Heathrow and Felixstowe.
Our intention is to supply our European customers with materials from the rest of the world from our Rotterdam warehouse imported via Schipol and Rotterdam port.
IMPORTS FROM THE EU
We increased our stocks for the first exit date and will not be repeating that again as the most likely current outcome is for a managed exit.
REACH REGISTRATION – KHUSH REGISTRATIONS
We continue to work towards registrations for REACH as our volumes approach and exceed one tonne. Current intentions are to register Khush UK and Khush NL for CLOVE, NUTMEG & YLANG YLANG. This will mean that all products will each have a 1-10 tonne limit from the UK and from The Netherlands. Registration activity is a much longer process now the initial deadline has passed. Any other REACH registrations completed will be notified on our news page.
All other products we offer are imported below 1 tonne and the pre-registrations will continue.
REACH REGISTRATION – EU PARTNERS
Currently our EU producers have registered BERGAMOT, CLARY SAGE, LAVENDER, LEMON, MANDARIN. ORANGE and ROSEMARY. It is understood that these can still be imported into the UK by us registering a ‘Grandfather’ clause in the expected new UK REACH.
REACH REGISTRATION – PARTNER ONLY REPRESENTATIVE REGISTRATIONS
Currently our rest of the world producers have EU based Only Representatives for ANTHRANILATES, CITRONELLA, EUCALYPTUS GLOBULUS, PEPPERMINT PIPERITA, TEA TREE and WS3. After the leave date we also expect the ‘Grandfather’ clause to apply in new UK REACH.
ORGANIC OILS
Our rest of the world sourced organic oils are not affected before or after the leave date (as we are either UK registered or below 1 tonne). We are uncertain how the Certificates of Inspection system will work after the leave date, but we will work with the Soil Association and comply with any new requirements/systems.
Our EU sourced organic products principally: ORGANIC BERGAMOT, ORGANIC CHAMOMILES, ORGANIC FLORAL WATERS, ORGANIC HELICHRYSUM, ORGANIC JUNIPERBERRY, ORGANIC LAVENDER, ORGANIC OREGANO, ORGANIC ROSEMARY will be affected, and we will update our supply position after the leave date.
We fully intend to continue supply of all materials to all our customers and will respond quickly to whatever political/practical arrangements are in place after the leave date and will try and minimise any cost impact to our customers.
We are being asked questions from our customers every day. We will accumulate questions and answer via our website whenever new information becomes available.