The UK has left the EU, and the transition period after Brexit comes to an end this year. A set of specific guidance on complying with UK REACH starting on 1 January 2021 was released and can be found on www.gov.uk.
UK REACH will maintain EU REACH’s aims and principles. Under UK REACH, manufacturers and importers have a duty to register chemicals that access the UK market.
Under the Northern Ireland Protocol, the process for Northern Ireland businesses moving goods to and from the European Union under EU REACH will not change from 1 January 2021. Further guidance will be published for NI businesses moving goods into the GB market.
EU REACH registrations held by UK-based companies will carry across directly into UK REACH, legally ‘grandfathering’ the registrations into the new regime.
UK customers from EU companies exporting to UK must notify the HSE using a Downstream User Import Notification (DUIN) of their intention to continue importing substances from the EU/EEA by 27 October 2021. A new registration must then be submitted to the HSE by the UK importer within 2, 4 or 6 years of 28 October 2021 if their EU/EEA supplier would not have registered through an UK-based Only Representative (OR).
The deadlines* are:
|Deadline Post 28 October 2021||Tonnage||Hazardous Property|
|2 years from 28 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|
* These new deadlines still need to be scrutinised by the UK parliament and the devolved administrations. The guidance includes these extension dates rather than those currently provided in UK REACH legislation.
The online service ‘Comply with UK REACH’ will go live on 1 January 2021.
For more information:
- Guidance for the treatment of chemicals during the transition
- Complying with UK REACH starting on 1 January 2021
- The Health and Safety Executive will update their website shortly and when they do a set of guidance will be made available here.
The pages will be updated if anything changes.
More information: Tine Cattoor, head product policy, firstname.lastname@example.org