allow common labelling . However , divergence may occur as a result of changes to expiry dates in ASs if GB takes a different decision to the EU or makes a decision at a different time to the EU . This will impact on conditions of authorisations , data protection periods and MAPP numbers .” From 2021 , MR applications for PPPs based on authorisation in an EU MS cannot be accepted for authorisation in GB , but this is possible in NI . “ The HSE may use evaluations made by other jurisdictions , where these are relevant and appropriate to the data requirements and required risk assessments ,” Woolacott confirmed . As regards , zonal and renewal applications that were previously submitted to the UK but which have yet to be accepted and evaluated , applicants have three options :
1 . Await MS evaluation : The HSE may consider the outcome as part of its assessment
2 . Request that the HSE conducts the evaluation : The guidance at the time of submission will be used and extra fees charged as appropriate
3 . Submit a new application : New guidance and a new template will apply
In addition , applications for parallel imports can be issued . Existing permits will continue until their current expiry date or 31 December 2022 , whichever is the sooner . Applications for new permits will no longer be accepted for GB , but they will be in NI . The grace period under Article 46 will apply to the permits in GB .
MRLs
After the end of the transition period , said Julian Cudmore , MRL technical lead and consumer exposure specialist , GB will set MRLs based on its own assessments but existing MRLs will remain valid until they are amended . New applications will continue to be submitted in a similar format to before and there will be no changes in the data requirements or format for supporting information . GB-specific documentation will be available on the HSE website . New MRLs will typically be assessed within 12-18 months and MRLs for new GB uses will be implemented at same time as the decision on the authorisation . Temporary MRLs for emergency authorisations will be prioritised . Evaluation reports , reasoned opinions and decision documents regarding MRLs will be published and MRLs will be implemented by means of a statutory register ,
Cudmore added . Any confirmatory data should be submitted to the HSE . A formal MRL review programme will be implemented within three years , prior to which MRLs “ will be reviewed when required ”. The Internal Market Bill , which was going through Parliament at the time of the BCPC Congress , includes a new principle of MR to allow the operation of the UK internal market for goods . This will apply to MRLs so as to avoid trade barriers for food in the UK . However , MRLs may begin to diverge , so businesses should check the requirements of the target market .
Outlook
“ The current regulatory framework will still apply , but we will have flexibility in applying this framework outside the EU ,” concluded Adrian Dixon , head of operational policy for PPPs . “ We intend to deliver quicker , efficient , science-based decisionmaking without the EU process . And there is an opportunity in the longer term to develop a way forward within a GB framework .” The UK Government , Dixon added , is committed to maintaining standards of protection for human health and the environment . The HSE is developing peer review arrangements as part of an internal regulatory assurance process . To this end , it will have access to independent scientific advice through the Expert Committee on Pesticides and Pesticides Residues in Food , will take on board information provided in public consultation and other source and is “ developing measures to ensure we take appropriate account of new research and knowledge ”. •
J j
Chemical Regulation Division
HEALTH & SAFETY EXECUTIVE EU-exitchemicals @ hes . gov . uk www . hse . gov . uk / brexit
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