ILMA Compoundings - November/December 2020 - 29

Registrations must be validated with basic information filed
by April 30. Then, starting Oct. 28, companies will have
to re-register under U.K. REACH within two, four or six
years, depending on tonnage and classification.
Downstream users who import chemicals from EU
countries must also be sure that the materials are registered
for U.K. REACH purposes or supplied by EU companies
that have appointed an Only Representative.
Chemical firms dominate discussions over the future of
REACH, so lubricant companies - especially the indepenCurrently, the solution that is gaining
ground creates a dual standard within
Northern Ireland concerning product
standards. The proposed plan is to
require products positioned within
Northern Ireland (wherever they are
made) to comply with EU product
standards as a condition to crossing
the border into the Republic of
Ireland. Those products that are not
intended to cross that border may
meet whatever different standard that
is required by the U.K.
On its face, that might seem simple
enough. And, compared to the other
issues, it is. But the plan requires the
creation of a meaningful infrastructure
within Northern Ireland to handle the
differences in products, enforce the
export standards to the Republic of
Ireland and deal with the accumulation and management of the divergent
cargo that might be so similar as to
be indistinguishable. Granted, the
differences could be (and will be)
identified differently (at least by SKU,
for instance), but the opportunity for
noncompliant products to enter the
EU market is considerable.
FISHING RIGHTS
Control of fishing rights within U.K.
territorial waters evokes more significant hurdles. The EU currently insists
that it have equal right to continue fishing these waters unabated by the U.K.
Naturally, the U.K. remains entirely

dents - should turn to their associations to amplify their
voices and translate policy implications into terms relevant
to lubricants, said Jarquin.

Partnerships and Opportunities
Some companies see opportunities in the circumstances. The
lubricants sector can cite a history of partnerships that keep
independent companies afloat, such as toll manufacturing
performed for major players.

unwilling to yield - at all. Complicating the matter is the fact that many
U.K. fishing companies have subcontracted to, or even sold their rights to,
EU fishing companies. These foreign
companies will become barred from
their activities beginning Jan. 1, unless
the U.K. and EU reach agreement.
As an overarching sentiment, the
U.K. objects to the EU (or any nonU.K. country) from co-owning the
right to control activity in U.K. territorial waters. Not that it wouldn't permit
U.K. fishing companies the ability
to apply (and pay) for that privilege.
And therein is the crux of the irreconcilable position. The EU is equally
unwilling to subject its sizeable and
essential fishing industry to the need
to pay for the privilege - usually a
fee that is based on volume and nature
of the catch - as well as the need to
comply with specific limits that control
methods, quantities by variety, vessel
standards and seasons of operation. The
EU sees U.K. control of these waters
as a meaningful threat to its industry.
The U.K. sees retaining control of this
subject as essential to protecting its own
industry and its ability to profit from
the controlled activity of others.
ENFORCEMENT
These related subjects are the greatest
barrier of all to reaching agreement by
the deadline - or ever. The EU insists
that enforcement be exclusively within

the jurisdiction of the European Court
of Justice, without alternative. The
U.K. emphatically refuses to consider
that, preferring its own judicial system
to govern conduct that affects its
exercise of sovereignty. The U.K. bases
its insistence on the notion that it is
entitled to control its own matters
within its territory and on the fact that
there are already other venues in which
the parties could seek redress. Underlying this is a deep sense of distrust by
the U.K. concerning the objectivity of
the European Court of Justice under
any foreseeable circumstance.
Reinforcing the U.K.'s stance, its
requirement is consistent with those
of other nations. If judgments become
impossible to enforce, the aggrieved
parties can seek third-party arbitration
or possibly seek determination by the
United Nations World Court. The EU
offers little justification for its posture,
other than concern that the U.K. is
positioning for too much control.
Negotiators simply insist on the measure to be included in the deal.
The remaining issues between the
U.K. and the EU reflect sentiments
that run deep on both sides. As the
calendar edges forward, only the
Northern Ireland topic shows prospects for resolution. The sovereignty
ramifications that permeate control
of fishing rights and enforcement are
serious obstacles that, so far, appear to
be insurmountable.

29



ILMA Compoundings - November/December 2020

Table of Contents for the Digital Edition of ILMA Compoundings - November/December 2020

ILMA Compoundings - November/December 2020 - Cover1
ILMA Compoundings - November/December 2020 - Cover2
ILMA Compoundings - November/December 2020 - 1
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