Britain officially left the EU on January 31, 2020. The Brexit transition period was closed on December 31, 2020, and UK REACH was implemented on January 1, 2021. Enterprises that intend to manufacture, sell or import chemical products in England, Wales, and Scotland (hereinafter referred to as GB) should comply with UK REACH from then on. Under the Northern Ireland Protocol, the EU REACH Regulation continues to apply to Northern Ireland.
Who must complete UK REACH registration?
Manufacturers in GB;
Importers in GB;
Enterprises based outside of GB should entrust a GB-based only representative (OR) to complete UK REACH registration.
How do you comply with UK REACH?
(1) Grandfathering (GB-based enterprises that have completed EU REACH registration):
Create a new account with the ‘Comply with UK REACH’ service;
Provide basic information on the existing EU REACH registration between January 1, 2021, and April 30, 2021, and obtain the UK REACH registration number;
Supplement all the required information within two, four, or six years from October 28, 2021, depending on the tonnage band and the hazards;
Note: Grandfathering is applicable to all GB-based enterprises that have completed EU REACH between March 29, 2017, and December 31, 2020.
(2) Submit DUIN (enterprises based outside of GB that have completed EU REACH registration and the downstream users are located in GB)
The downstream users should create a new account with the ‘Comply with UK REACH’ service;
Submit a notification to HSE before October 27, 2021;
A new registration must be submitted within two, four, or six years from October 28, 2021;
If the downstream users are not willing to do so, then the enterprise can entrust a GB-based OR. That is to say, the OR can also submit DUIN to HSE before October 27, 2021. A new registration must be submitted within two, four, or six years from October 28, 2021.
(3) Directly submit UK REACH Registration
If the foreign enterprises and their GB importers have not completed EU REACH Registration, then after UK REACH takes effect, the foreign enterprises or the importers need to complete UK REACH before exporting to the UK.
It is worth mentioning that the EU REACH regulation will still apply in Northern Ireland after January 1, 2021. That is to say, business between Northern Ireland and the EU will remain unaffected.
Registration Transitional Period
The submission deadlines for substances of different tonnage bands and hazards are as follows:
Deadline Post October 28, 2021
Within two years from October 28, 2021.
October 27, 2026
Carcinogenic, mutagenic or toxic for reproduction (CMRs) - 1 tonne or more per year;
Very toxic to aquatic organisms (acute or chronic) - 100 tonnes or more per year;
Candidate list substances (as December 31, 2020);
Four years from October 28, 2021.
October 27, 2028
Candidate list substances (as of October 27, 2023);
Six years from October 28, 2021.
October 27, 2030
From July 19, 2023, the REACH (Amendment) Regulations entered into force, which extended the time required to submit information by a further 3 years, from October 27 2023, October 27 2025 and October 27 2027 to October 27 2026, October 27 2028, and October 27 2030 respectively.
- Downstream User Import Notification/Full Registration (DUIN)
- Only Representation for non-GB based companies
- Set up UK REACH-IT account
- File & Submit the dossier to the HSE
- Update dossier with new information
- Preparation for inspection by HSE
- Communication within Substance Group
- Review/Prepare Substance Identity Report
- Prepare & Submit Inquiry Dossier to the HSE
- Classification, Authoring/Review SDS & Labels for UK CLP