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 will maintain the aims and principles of EU REACH. 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.
According to the latest information from the UK government, it intends to extend the deadlines that are currently provided in UK REACH legislation for submitting data. The intended deadlines are specified below.
For more information, please visit the UK government website.
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, via its UK importer or an UK-based OR.
Current UK Downstream Users under EU REACH, will act as importers under UK REACH of non-UK REACH registered substances. These downstream users must notify the HSE of their intention to continue importing substances from the EU by 27 October 2021 through providing a Downstream User Import Notification (DUIN). A full data set for registration must then be submitted within 2, 4 or 6 years of 28 October 2021 depending on the tonnage band and hazard profile of the substance.
|Deadline for registration||Tonnage band||Hazardous property|
|2 years from 28 October 2021||1000 tonnes or more per year||
|4 years from 28 October 2021||100 tonnes or more per year||Candidate list substances (as at 27 October 2023)|
|6 years from 28 October 2021||1 tonne or more per year|
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
- 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 carried across into UK REACH (‘grandfathered’). For the grandfathering process the following applies:
- Basic data about the company and the substance will need to be submitted by April 30, 2021.
- Full information, appropriate to the tonnage band and hazard profile, will need to be submitted according to the registration deadlines set per tonnage band and hazard profile over a period of 2, 4 or 6 year, as the HSE will no longer have direct access to the substance data held by the ECHA.
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 Downstream User Import Notification (DUIN) option. 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: