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, 2021TonnageDangerous Properties
2 years to 28 October 2021> 1000 tons per yearCarcinogenic, 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 yearSubstances 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.