UK REACH Regulation Services
The United Kingdom’s independent chemicals regulatory framework UK-REACH began on 1 January 2021. Anyone making, using, selling or distributing chemicals in Great Britain and the EU/EEA needs to follow both UK-REACH and EU-REACH rules.
What is UK-REACH?
UK-REACH took effect on 1st January 2021. From this date any companies making, using, selling or distributing chemicals in Great Britain must comply with the specific requirements of this UK law rather than EU-REACH. Northern Ireland, whilst part of the United Kingdom, remains subject to EU-REACH although there may be some particular requirements for any NI<->GB trade to consider.
The UK government has made clear that UK-REACH will maintain the original aims and principles of REACH, including:
the “no data, no market” principle
the “last resort” principle on animal testing
access to information on chemicals for workers and consumers
the precautionary principle
What needs to be done to comply with UK-REACH?
UK-REACH introduces many new ‘transitional provisions’ to allow companies additional time to adapt to their new roles and responsibilities. GB companies with existing EU-REACH Registrations and Authorisations had the ability to “grandfather” those into the UK system from 1st January 2021, such that they are legally recognised. Although the deadlines have now passed, this was a simple process involving the submission of an IUCLID dossier and no Registration fees were payable. Ultimately, a full Lead Registration dossier needs to be submitted by one company, containing all of the relevant endpoint data, uses, hazard classification, PBT assessment, guidance on safe use, and Chemical Safety Report as necessary.
GB-based Downstream users and Distributors who rely on their supplier's EU-REACH Registrations may find their role in the supply chain has shifted to Importer. They may submit a basic Downstream User Import Notification (DUIN) for their substances, allowing for the Registrations to be deferred until a later date.
EU companies that need to maintain access to the GB market must do so via a GB subsidiary or appoint an Only Representative. Grandfathering will not be an option here, so to comply with UK-REACH they may need to submit a DUIN or potentially use the New Registration of Existing Substance (NRES) option, depending on their circumstances.
Approaching Registration deadlines for UK-REACH
The deadlines for Registration are based on the tonnage band and/or hazard classification of the substance that is manufactured or placed on the GB market, with the highest tonnages and most severely hazardous substance to be registered first. Substances below 1 tonne/year, either on their own, within mixtures or released from articles are not subject to Registration. The table below details the deadlines.
Exemptions from Registration, such as those meeting Annex IV or Annex V criteria will continue to apply under UK-REACH.
Substances used for product and process-orientated research and development (PPORD) purposes at ≥1 tonne/year may also be exempt from Registration, provided a PPORD Notification covers them.
Yordas’ Experience
Yordas’ extensive experience of over 10 years in providing regulatory, technical and scientific support to hundreds of importing and exporting organisations to achieve compliance with European and global chemical regulations puts us in good stead to support your company with UK-REACH. Our regulatory consultants can help you navigate the complexities of UK-REACH and devise a strategy to obtain and maintain long-term compliance and provide supply chain security for the future. Contact us today to learn more about how we can support your business.
