Written evidence submitted by the BASF Group (FRE0100)


About Us

At BASF, we create chemistry for a sustainable future. We combine economic success with environmental protection and social responsibility. The approximately 122,000 employees in the BASF Group work on contributing to the success of our customers in nearly all sectors and almost every country in the world. Our portfolio is organized into six segments: Chemicals, Materials, Industrial Solutions, Surface Technologies, Nutrition & Care and Agricultural Solutions. BASF generated sales of about €63 billion in 2018. BASF shares are traded on the stock exchanges in Frankfurt (BAS), London (BFA) and Zurich (BAS).

As Europe’s largest chemical manufacturer, BASF imports over a million tonnes of chemicals annually from continental Europe into the UK, providing key chemicals and materials for industries including automotive, aerospace, care, pharmaceutical and nutrition.

BASF UK contributes to export-led manufacturing growth, sustainable development, innovation partnerships, and employment, often in some of the UK’s more challenging economic regions. BASF UK generated over 1.2bn revenue in 2019, BASF UK plants sold €325m of product the majority of which is exported.

BASF Cheadle is the HQ for BASF plc. In the UK we have 9 UK manufacturing plants, largely unrelated to one another, but part of pan-Europe or global supply chains. These produce Polyurethanes (Alfreton), Industrial Chemicals (Bradford), Fatty acids (Callanish), Auto-catalyst recycling (Cinderford), Metal Coatings (Milton Keynes), Biopesticides (Littlehampton), Flooring Systems (Redditch), Concrete Admixtures (Swinton), and Rodenticides (Widnes).

With approximately 850 staff in 16 locations we are a significant UK employer. There are 140 home workers, and 25 staff working at customer sites (automotive plants).

We are a major sponsor of innovation in the UK with over 150 current partnerships. Around half of these are with British universities, the rest are local companies and research. These range from multi-level engagements with Imperial College and Birmingham University, to one-off projects with the National Physical Laboratory, or commercial partnerships with entrepreneurial SMEs. We have ongoing dialogue and liaison with stakeholders and investors including interests throughout the innovation continuum from blue sky research to venture capital investment, scale up and commercialisation.

Further information on BASF is available on the Internet at https://www.basf.com/gb/en.html


With a primary aim of improving human health and environmental protection, EU regulation, Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH), EC 1907/2006 came into force, 1st June 2007.

Since then, under the principle of “no data, no market” (EC 1907/2006, Article 5), industry across the EU including the United Kingdom, has been generating, summarising and submitting information to the European Chemicals Agency (ECHA) regarding safety and exposure to chemical substances.

Current Political Situation

The UK officially left the EU on January 31st, 2020. At this point, the transition period began during which the “future relationship” negotiations will take place. If there is no agreement or the transition period is not extended, a “no-deal” Brexit scenario for the UK is possible as early as 1st January 2021.

In Autumn 2018, the UK government shared how chemical legislation would be administered in case of a no-deal Brexit. The statutory instrument, The REACH, etc. (EU Exit) Regulations”, known as “UK REACH, passed through parliament in March 2019.


Future Relationship Negotiations

BASF believes it would be best for the EU/UK chemical sectors if the UK remains part of the EU-REACH framework, still accessing the services of the European Chemicals Agency (ECHA). A concept named “Associate Membership” in the government white paper, July 18 (paragraphs 30/31).

Following the December 2019 general election, BASF acknowledged the change in political position in the new government. Therefore discounting Associate Membership, a secondary position would be the EU & UK agree a dynamic data and information sharing mechanism with respect to dossier contents submitted and regulatory processes in both jurisdictions.

A preference for the UK to have a chemicals annex with data and information exchange system in place is referenced in the “UK’s Approach to Negotiations”, dated February 2020.
BASF welcomes the approach to have this an agreed outcome in the negotiation process.


Consequences of no Agreement in the Future Relationship Negotiations.

Since enforcement, it has been reported that the generation and submission of REACH information has cost UK industry in the region of £250mn. (The Future of Chemicals Regulation after the EU Referendum, Environmental Audit Committee Report, 29 April 2017)

Consequences of no agreement are as follows:


Consequences of UK REACH for BASF

The chemical sector is the “Industry of Industries” and BASF supplies chemicals into the UK market for applications including pharmaceutical, automotive, food and nutrition amongst others.


Anticipated Impact of UK REACH for Chemical Supply Chains

Due to the restrictive registration timelines, BASF is concerned about large scale supply-chain disruption. BASF also expects product and substance rationalisation in the UK market due to cost and commercial factors.

UK industry has already financially contributed into EU REACH supply chain compliance since 2007. By UK REACH policy not recognising this contribution whilst the UK was in the EU, UK businesses will be disadvantaged due to the additional UK REACH registration requirement.

Ultimately, BASF believes that;


Key Summary

Chemical value-chains are highly integrated and the majority of chemicals entering or leaving the UK are from or to other European countries.

To ensure market access equality across Europe, a dynamic data and information sharing mechanism should be sought during the EU/UK Future Partnership negotiations. BASF supports a shared European (CEFIC) and UK (CIA) chemical industry position as to how this could be achieved, (European Chemical Industry views on the future-relationship negotiations between the EU and the UK, 27 May 2020).

To minimise repetition of animal studies and achieve market access equality without a data and information sharing agreement in place, a UK policy change is required, ensuring that existing REACH compliant supply-chains are regulated in the UK without a dual registration requirement.




August 2020