UK REACH

Based on current available information, EU legislation will no longer apply in the United Kingdom after Januar 1, 2021. Any UK or EU company placing chemical substances on their own or in mixture on the UK market above 1000 kg per year will have to register their chemical substances under the UK REACH regime.

The UK authorities have announced UK REACH to be a copy of the current EU REACH regulation. Having a legal entity in the UK or Only Representative (OR) is a minimum requirement for a registration. The Health and Safety Executive (HSE) will act as the lead UK regulatory authority under UK REACH; from the day the transitional leave period ends.

EU or non-EU based companies

An EU based or non-EU based company exporting to the UK can register its substances under UK REACH only if it has a legal entity in the UK or via the appointment of an OR. The UK will provide an interim notification period for non-UK registered substances. Basic data on the company, substances and information on safe use need to be submitted before June 30, 2021 (180 days). Full registration is then required before December 31, 2022.

Our UK REACH services for EU and non-EU based companies

For EU and non-EU based companies, we can offer the following chemical regulatory services for the UK market:

  • Only Representative services through our local legal entity in the UK
  • Registration support (from 1 January 2021 on)
  • Support with EU REACH Letter of Access (LoA) issues by SCC Legal
  • Developing a regulatory strategy, including a testing strategy for UK registrations

UK based companies

Under UK REACH, existing EU REACH registrations held by UK-based companies (including registrations held by an existing OR) will be automatically ‘transferred’ and become UK registrations. Meaning there is no need to re-register these substances in the UK. However, as the HSE will no longer have direct access to the substance data held by the ECHA, all applicable transferring UK registrants will need to provide that data over a period of two years:

  • Basic data about the market and the substance will need to be submitted before May 1, 2021.
  • Full information, appropriate to the tonnage band, will need to be submitted before December 31, 2022.

Companies based in the UK and importing non-UK registered chemical substances will be required to register their substances under UK REACH, for which the UK provides the interim notification period. Registration obligations can be avoided, if the EU or non-EU based supplier appoints an OR and takes responsibility for the UK REACH registration obligation.

Our UK REACH services for UK based companies

For UK based companies, we can offer the following chemical regulatory services for the UK market:

  • Support with data transfer to UK HSE for existing registrations
  • Support with EU REACH Letter of Access (LoA) issues by SCC Legal
  • Registration support for substances (from 1 January 2021 on)
  • Developing a regulatory strategy, including a testing strategy for UK registrations