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Registration, Evaluation and Authorisation of Chemicals (REACH) from 1 January 2021

Synopsis

Details of the UK-only version of REACH that is expected to operate from 1 January 2021 have been published. UK manufacturers and importers will ultimately be required to register chemicals under UK REACH to continue selling them in the UK.

UK downstream users of chemicals may also assume responsibilities for notification and registration under UK REACH.

 
 
 

Summary

Guidance has been provided on how the Registration, Evaluation and Authorisation of Chemicals (REACH) regime will operate after the end of the post-Brexit transition period. A UK-only version of REACH (UK REACH) is planned to operate from 1 January 2021.

The HSE will operate and enforce the UK REACH regime. UK REACH may have significant impacts on chemical supply chains, as described below.

UK Organisations holding EU REACH Registrations

Where these have not already been transferred to the EU, UK holders of REACH registrations must ensure these are transferred to the EU before 1 January 2021.

Obligations of UK Chemical Manufacturers and Companies importing Chemicals to the UK

EU REACH registrations will temporarily be recognised for UK REACH under the ‘grandfathering process’, before a full UK REACH registration will be required. Great Britain-based holders of EU REACH registrations will be required to:

  1. Provide basic information on all registered chemicals to the HSE by 30 April 2021; and
  2. Resubmit registration dossiers to the HSE by the following deadlines, depending on tonnages or hazard properties for each chemical:

Deadline to Submit Full Registration Dossier

Tonnage

Hazardous Property

 

28 October 2023

All other substances at or above 1,000 tonnes per annum

  • Carcinogenic, mutagenic or toxic for reproduction (CMR) substances at or above 1 tonne per annum;
  • Substances classified as very toxic to aquatic organisms (acute or chronic) at or above 100 tonnes per annum; and
  • Substances on the EU candidate list (substances of very high concern) as of 31 December 2020.

28 October 2025

All other substances at or above 100 tonnes per annum

  • Substances on the UK candidate list (substances of very high concern) as of 27 October 2023

28 October 2027

All other substances at or above 1 tonne per annum

N/A

 

Downstream Users Importing Chemicals

Downstream users of chemicals in the UK will need to determine whether a UK registrant or UK-based only representative is to arrange a UK REACH registration.

Where a UK registration is not underway, a Downstream User Import Notification (DUIN) will need to be submitted to the HSE by 27 October 2021. Unless a UK REACH registration is arranged by another organisation, the downstream user will need to register under UK REACH by the respective deadline on the table above.

Registration Dossiers

In order to continue supplying chemicals to the UK market and to make the registrations required, UK registrants will need to ensure they have adequate access to dossiers previously submitted for registrations under EU REACH.

Northern Ireland

Under the Northern Ireland Protocol, Northern Irish businesses supplying chemicals to the EU will not face new duties regarding existing EU registrations.

 

 

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