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UK REACH: what you need to know and what you need to do

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UK REACH: what you need to know and what you need to do

 

At the beginning of September 2020 the government updated the guidance for UK REACH compliance. We’ve summarised the key points here and provide some action points you may wish to consider going forward.

UK downstream users (who do not hold an EU REACH registration) currently importing chemicals from an EU/EEA country need to ensure the substances they purchase are covered by a valid UK REACH registration.

These UK downstream users must notify the HSE of their intention to continue importing substances from the EU/EEA using a Downstream User Import Notification (DUIN) by 27 October 2021.

A new registration must then be submitted to the HSE within 2, 4 or 6 years of 28 October 2021 depending on the tonnage band (see below). Alternatively, UK downstream users can encourage their EU/EEA supplier to appoint a UK-based Only Representative (OR), or change their source to a UK registered supplier.

Under UK REACH, deadlines for the full submission of data to underpin registration dossiers will be staggered over a period of 6 years. These deadlines start from 28 October 2021, the end of the DUIN submission period. The registration deadlines and tonnage bands are:

 

Full registration deadline

      Tonnage

             Hazardous Property

2 years from 28th 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

 No specified hazard property.

 

Comply with UK REACH

The online service ‘Comply with UK REACH’ will go live on 1 January 2021. This is the UK equivalent of ECHA’s REACH-IT. Businesses can use the service to:

  • validate existing UK-held EU registrations (‘Grandfathering’)

  • submit downstream user import notifications (DUIN)

  • submit new substance registrations

  • submit new product and process orientated research and development (PPORD) notifications

What does this mean for me?

Key action points you may wish to consider:

  1. Check if your EU supplier is going to register under UK REACH.

  1. Check if your non-EU supplier who has appointed an OR under EU REACH is going to appoint an OR under UK REACH.

  1. Ensure you complete a DUIN before the deadline. This applies to importers of substances registered under EU REACH.

  1. Look for EU and UK suppliers who will comply with the applicable REACH legislation.

  1. If you are a UK company supplying into the EU and hold an EU REACH registration, make arrangements to transfer the registration to an EU legal entity.

  1. For importers/manufacturers of a new substance or a substance not covered by an EU REACH registration, there will need to be the equivalent of an EU REACH inquiry dossier submitted before your tonnage exceeds 1 tonne per year.

If you wish to discuss any of the points above, or any other aspect of UK REACH compliance, please contact Peter Godfrey (peter.godfrey@cea-res.co.uk) or Neil Stearn (neil.stearn@cea-res.co.uk).

 

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