UK regulatory services

UK REACH

From January 1, 2021 onwards, companies placing chemical substances on their own or in a mixture in quantities above 1000 kg per year on the UK market have to register their chemical substances under the UK REACH regime. This does not apply to Northen Ireland: Companies in NI maintain their EU REACH status and obligations for the duration of the Nothern Ireland Protocol, enabling them to continue placing their products on the EU market, on the one hand, and providing them ongoing UK market access for existing NI-based EU REACH registrations for qualifying NI goods (QNIG), on the other.

UK REACH maintains 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) acts as the lead UK regulatory authority under UK REACH.

The UK government is extending 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 through a legal entity in the UK, via its UK importer or an UK-based OR.

Current UK Downstream Users under EU REACH, 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 from 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     
  • 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 at 31 December 2020)
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, including DUIN and Article 26 inquiry
  • Legal services related to EU REACH Letter of Access (LoA) issues by  SCC Legal logo
  • Developing a regulatory strategy, including a testing strategy for UK registrations
  • Taking care of your communication with potential registrants of substance groups

UK based companies

Under UK REACH, existing EU REACH registrations held by UK-based companies (including registrations held by an existing OR) are 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 are 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:

  • Data transfer to UK HSE for existing registrations
  • DUIN and Article 26 inquiry support
  • Legal services related to EU REACH Letter of Access (LoA) issues by SCC Legal logo
  • Registration support for substances
  • Developing a regulatory strategy, including a testing strategy for UK registrations
  • Taking care of your communication with potential registrants of substance groups

Contact Us

Contact our experts to learn more about our services for UK REACH and how we can help you with make your chemicals fit for the UK market.