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 Northern Ireland (NI): Companies in NI maintain their EU REACH status and obligations for the duration of the Northern 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 has extended the deadlines currently provided in UK REACH legislation for submitting data for certain use cases. The 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. To continue importing substances from the EU to the UK,  downstream users were asked to identify their intention to register by submitting a Downstream User Import Notification (DUIN)  before October 27, 2021. Downstream users who have submitted a DUIN have been  automatically granted  additional 2 to 6 years to prepare a full data set for substance registrations depending on the tonnage band and hazard profile of the substance.

Even though the official DUIN deadline expired in late October 2021, HSE is still accepting notifications. With a new deadline haven't been set, HSE recommends to submit a notification as soon as possible.

Deadline for registration Tonnage band Hazardous property
27 October 2023    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)
27 October 2025 100 tonnes or more per year Candidate list substances (as at 27 October 2023) 
27 October 2027 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 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) have been automatically carried across into UK REACH (‘grandfathered’). The deadline for the submission of basic data about the company and the substance ended 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. 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:

  • Registration support for substances
  • Developing a regulatory strategy, including a testing strategy for UK registrations
  • DUIN notification and Article 26 inquiry support
  • Legal services related to EU REACH Letter of Access (LoA) issues by SCC Legal logo
  • 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 make your chemicals fit for the UK market.