How to Comply with UK REACH

Britain has officially left EU on 31 Jan. 2020. The Brexit transition period was closed on 31 Dec. 2020 and UK REACH has been implemented from 1 Jan. 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 Shall 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 to Comply with UK REACH

(1) Grandfathering (GB-based enterprises that have completed EU REACH registration):

• Create a new account in UK REACH IT system;
• Provide basic information of the existing EU REACH registration between 1 Jan. 2021 and 30 Apr. 2021, and obtain the UK REACH registration number;
• Supplement all the required information within 2, 4, or 6 years from 28 Oct. 2021, depending on the tonnage band and the hazards;

Note: Grandfathering is applicable to all GB-based enterprises that have completed EU REACH between 29 Mar. 2017 and 31 Dec. 2020.

(2) Submit DUIN (enterprises based outside of GB that have completed EU REACH registration: The downstream users are located in GB)

• The downstream users should create a new account in the UK REACH-IT system;
• Submit notification to HSE before 27 Oct. 2021;
• A new registration must be submitted within 2, 4 or 6 years from 28 Oct. 2021;

If the downstream users are not willing to do so, then the enterprise can entrust an GB-based OR. That is to say, the OR can also submit DUIN to HSE before 27 Oct. 2021. A new registration must be submitted within 2, 4 or 6 years from 28 Oct. 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 UK.

It is worth mentioning that EU REACH regulation will still apply in Northern Ireland after 1 Jan. 2021. That is to say, business between Northern Ireland and UN will remain unaffected.

Registration Transitional Period

The submission deadlines for substances of different tonnage band and hazards are as follows:

Deadline Post 28 Oct. 2021	Tonnage Band	Hazards
Within 2 years from 28 Oct. 2021	>=1000 tpa	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 Oct. 2021	>=100tpa	Candidate list substances (as at 27 October 2023);
6 years from 28 Oct. 2021	>=1 tpa

Our Services

• OR service
• Grandfathering Consulting Service
• UK REACH Registration
• DUIN Notification
  
• Other Consulting Services

If you have any needs or questions, please contact us at service@cirs-group.com.