Preparing for Brexit

Brexit Preparations

Ingevity has been closely monitoring the development of the U.K.’s anticipated exit from the European Union, commonly referred to as “Brexit.” Ingevity has worked tirelessly as a multi-disciplinary team to ensure we are prepared. We have assessed potential consequences and are implementing robust processes to reduce any potential impact on our customers.

Ingevity U.S.-Only Representative Relationship

Ingevity has a longstanding relationship with ITS Testing Services (U.K.) Ltd, a subsidiary of Intertek. Intertek has acted as Only Representative in the European Union for Ingevity for many years. In anticipation of Brexit, the registrations held in the U.K. on behalf of Ingevity have been transferred to Intertek Deutschland GmbH in order to provide seamless compliance with Regulation EC 1907/2006 (REACh) within the European Union.

Ingevity U.K.-Only Representative Relationship

Ingevity has also appointed Intertek Deutschland GmbH to act as Only Representative in the European Union for the substances manufactured at our Ingevity U.K. site in Warrington. Since an Only Representative cannot act on behalf of an entity manufacturing under the auspices of REACh within the European Union, the existing REACh registrations held in Warrington shall be transferred to the Only Representative in Germany at the point that the Brexit transition period ends.

U.K. Chemical Control Law Compliance Post-Brexit

The U.K. Health and Safety Executive (HSE) has indicated that REACh registrations located in the U.K. prior to Brexit will be “grandfathered” into the post-Brexit U.K. chemical compliance law, whether they are transferred to a European Union entity for continued compliance within the European Union or not. Ingevity and Intertek will work to notify the existing registrations to the HSE.

Continued Trade

Ingevity is committed to working with its suppliers and transportation partners to mitigate any potential delays resulting from interrupted custom clearance processes, if the U.K. were to exit the European Union without a deal (so called “hard Brexit”). We have taken steps to arrange for additional storage of input materials and finished products in strategic locations to help mitigate potential delays. These steps do not guarantee an uninterrupted supply of product from Ingevity. If you have concerns about upcoming supplies, please contact your local sales representative or customer service contact to discuss options specific to your needs.

As part of our preparation, we have confirmed that Ingevity Corporation (U.S.) will be able to act as a nonresident importer declaring goods into the U.K. As of November 12, 2020, Ingevity Corporation received from HMRC a U.K. EORI number (GB0743471120000) and is in process of submitting an application for a U.K. VAT number. We anticipate being able to formally communicate to Ingevity Corporation customers over the next few weeks our new U.K. VAT number.

Ingevity U.K. Ltd has also applied for an EU EORI number (that is in process) and the customs comprehensive guarantee (CCG). The CCG is to cover goods moved by common transit under the common transit convention (CTC). The U.K. has successfully negotiated membership of the CTC. The CTC is a facilitation that may provide benefits to traders by allowing some customs processes to be done away from the border. Ingevity U.K. Ltd is also in process of making several applications in EU member states for new local VAT numbers, which will be communicated to customers when available.

The CTC is a treaty between the countries of the European Union and a number of other countries for common procedures for international transit of goods, thus simplifying or eliminating much of the paperwork normally associated with moving goods across international borders.