As we continue on the journey through UK REACH CIRS has gained invaluable practical experience. Since the beginning of UK REACH CIRS has become the Only Representative for 600+ clients globally we have also completed 500+ DUIN, assisted UK clients by Grandfathering 70+ registration, and completed the Full registration of 20+ substances on behalf of our clients. Over the last year, this experience coupled with the continuous communication with the HSE has allowed us to remain up to date with all the developments and nuances of the UK REACH requirements. CIRS would like to share the information we have gathered to date as well as the latest information that has come out from the HSE in recent weeks.
Lessons From our Practical Experience
As previously mentioned, CIRS has processed over 500 DUIN applications and completed the full registration of over 20 substances on behalf of our clients. In our experience, any company that has processed or may in the future process a UK REACH registration should consider the following points.
The UK REACH system Revision
As UK REACH is still in its infancy, the UK authorities have been open to feedback from the chemicals industry on the current system and potential improvements that will benefit the UK chemicals industry while maintaining and protecting regulatory standards and the public as a whole. The authorities are only exploring the possibility of revising the system and there is no confirmation that anything will change but CIRS can share some of the details being considered.
In broad terms, the Substance groups would use public data to agree on a hazard profile for a substance. They would submit this to HSE in the form of a Substance Hazard Information Profile (SHIP). The individual Registrants would also provide a registrant-specific risk assessment focusing on GB use and exposure. The HSE and DEFRA are undertaking ‘one-to-one’ interviews with identified stakeholders to discuss this, and more details will be provided should a system revision be announced.
It has been confirmed that an amending regulation will be published to extend the registration timeline regardless of the decision to revise the UK REACH system or not, to allow time for a thorough overview and report to be published. Details of the registration timeline extensions are expected to be published in Autumn 2022 following the Formal ‘short’ public consultation expected in the Summer of 2022.
Summary & Tips
- Be sure to closely record the tonnage of your substance being placed on the UK market as exceeding a specific tonnage band at any point will lock in your full registration date.
- Be aware of the requirements if you are considering changing suppliers.
- Important questions are the supplier EU Registered?
- Have you completed your DUIN or will an NRES be required?
- The DUIN is still available for companies that meet the criteria, CIRS recommends acting sooner rather than later to become compliant and avoid any potential future issues.
- Be aware of the NRES requirements for any ‘New’ substances you wish to place on the UK market.
- Participate in the upcoming UK REACH public consultation to ensure your business is represented in the discussion.
Our UK REACH Service
- Down Stream User Notification (DUIN)
- Only Representative (OR) Service
- Lead Registrant
- Joint Submission
- Chemical Safety Report (CSR) Compilation
- Testing Coordination/Supervision
- Alternative methods (QSAR, Read-Across, In-vitro, Grouping, etc.)
- SIEF Management Service
- Development of Exposure Scenario (ES)
If you have any questions or would like to enquire about any of the services we can offer your business, please feel free to contact us as we would be happy to help.
Senior Regulatory Consultant in CIRS Europe
Tel.: +00 353 (1) 477 3706