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.
Tonnage Band Thresholds
Many of the UK REACH regulations were taken directly from the EU REACH regulations that were in force at the end of the Brexit transition period this includes the Per Calander Year Tonnage Band requirement. Effectively from the 1st of January if a company places a particular substance on the market in the UK above the tonnage band limit in a calendar year, this will indicate the tonnage band they should register in. There was also an additional sentence added to the UK REACH regulations which state “at least once after IP completion day”. Therefore, if you have imported more than the requisite tonnage detailed in the specific tonnage bands (1-10, 10-100, 100-1000, or 1000+ tonnes per year), after 1st January 2021, then your registration date is fixed by exceeding the tonnage band limit.
For example, if in 2021 your company placed 990 tonnes of a substance on the GB market, for 2021 they would be in the 100-1000 tonnage band benefiting from the grace period related to 100 tonnes or more per year and would only need to complete the full registration by the 27 October 2025 However if in 2022 the same company placed 1001 tonnes of the same substance on the UK market they would fall into the 1000+ tonnage band and because of the “once after IP completion day” regulation would be required to complete the full registration by the 27 October 2023 even if they dropped to below 1000 tonnes the following year. This is an important part of the regulations that many companies may not be aware of which could lead to non-compliance in the future and must be monitored carefully.
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.
The Latest UK REACH Update - DUIN Update and the NRES Process
The Latest UK REACH Update - Supplier Requirements
The Latest UK REACH Update - The UK REACH System Revision
Dean Winder, Senior Regulatory Consultant in CIRS Europe
Chemical Inspection & Regulation Service Limited
Tel.: +00 353 1 477 3706