The United Kingdom from January 31, 2020 is no longer a member state of the European Union.
UK-REACH has been in force since 1 January 2021.
The UK-Reach has maintained the same general principles as the European Reach, in particular:
- The concept of “no data – no market”.
- The preference for alternative tests over in vivo ones.
- Access to information for workers.
- The precautionary principle.
UK COMPANIES WITH EU-REACH REGISTRATION
Registrations made under the European Reach will automatically be transferred to the new UK-Reach through a process called “grandfathering”.
The “grandfathering” process includes two different steps:
• By 30 April 2021, UK companies in possession of a Reach registration will have to provide information to the HSE (Health And Safety Executive), the British competent authority: substance identity, company data, registered quantity and evidence of the EU registration.
• Instead, within a deadline defined by the tonnage band they will have to provide specific information from the registration dossier.
Deadlines after October 28, 2021 | Tonnage | Dangerous Properties |
---|---|---|
2 years to 28 October 2021 | > 1000 tons per year | Carcinogenic, mutagenic or toxic for reproduction (CMR)> 1 ton per year Highly toxic to aquatic organisms (acute or chronic)> 100 tons per year Substances of the Candidate List (as act 27 October 2023) |
4 years from 28 October 2021 | > 100 tons per year | Substances of the Candidate List (as act 27 October 2023) |
6 years from 28 October 2021 | > 1 tons per year |
UK COMPANIES BUYING FROM EU SUPPLIERS
From 1 January 2021, UK companies that purchase from EU suppliers must be configured as importers under the UK-Reach and as such they will have to register.
• By October 27, 2021, the UK importer must notify the HSE of its intention to continue with the imports, and the notification is called DUIN (Downstream User Import Notification). Such a notification can only be sent if the substance has already been registered under the EU-Reach.
• The registration dossier must be submitted within a deadline defined by the tonnage band (the same previously reported).
Alternatively such companies may encourage EU suppliers to appoint a UK-OR (Exclusive Representative) appointed under the UK Reach.