UK REACH Chemical Regulations

Following the Brexit transition period, the UK Registration, Evaluation, Authorisation & Restriction of Chemicals (REACH) scheme is, as of 1 January 2021, now active.

Currently, whilst the key principles of the EU REACH regulations have been retained, UK REACH and EU REACH operate independently. Companies supplying and purchasing substances, mixtures, or articles to and from the EU, European Economic Area (EEA), Northern Ireland, and Great Britain (England, Scotland, and Wales) will need to ensure that the relevant duties are met under both pieces of legislation.

GB-based holders of previous EU REACH registrations need to complete the “Grandfathering” process by providing basic information to the Health and Safety Executive (HSE) by 30 April 2021 if they wish to continue supplying their substances in GB.

Businesses that relied on a registration held by an EU- or EEA-based company before 1 January 2021 can continue importing substances as they did before by submitting a Downstream User Import Notification (DUIN) by 27 October 2021.

In either case, a UK REACH registration will be needed later.

Registration

Registrants must be UK based, either as manufacturer, importer, or Only Representative.

Registrations of substances grandfathered in or subject to DUIN must be submitted to the HSE within 2, 4, or 6 years of 28 October 2021 (see table below)

For “new” substances, i.e., those that do not fit the criteria for either “Grandfathering” or DUIN, an inquiry dossier must first be submitted to the HSE, and the registration deadline may be deferred to allow time for data sharing.

Registration Deadlines

Date

Substances

Before 28 October 2023

  • 1,000 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 of 31 December 2020)

Before 28 October 2025

  • 100 tonnes or more per year
  • Candidate list substances (as of 27 October 2023)

Before 28 October 2027

  • 1 tonne or more per year

Discuss deadline with HSE after inquiry dossier is submitted

“New” substances, i.e., those that do not fit the criteria for either “grandfathering” or DUIN.

Data sharing

The UK scheme will use a joint submission system and the principle of one substance, one registration will apply (which mirrors EU REACH).

Data requirements per tonnage band are equivalent to EU REACH, and data sharing provisions will also be equivalent. Data already generated for EU purposes can be used, providing that legitimate data access has been arranged.

Our Services

In addition to our comprehensive support for EU REACH, Exponent offers complete and effective services to help companies comply with their responsibilities under the UK REACH scheme at every stage of the process. The varied and in-depth scientific and regulatory experience of our staff means the assistance we can provide includes but is not limited to:

  • Full Only Representative registrant services
  • Provision of regulatory advice, including registration strategy
  • Preparation and submission of basic information on existing EU REACH registrations to the HSE for “Grandfathering”
  • Preparation and submission of DUINs
  • Data gap analysis
  • Study placement and monitoring
  • Preparation and submission of registration dossier(s) and, if necessary, chemical safety report(s)
  • Negotiations on data availability, data quality and value, data sharing, and production of a testing proposal as necessary
  • Arranging letter of access sales and purchases, including financial management
  • Responding to HSE correspondence, including that relating to dossier and substance evaluations.

How can Exponent help you meet the challenges of UK REACH?

With 31 offices and over 1,000 staff worldwide, Exponent is a leading provider of services to the chemical industry. With offices and experts in the UK, EU, US, and Asia, we offer a comprehensive range of technical and regulatory expertise to help companies meet their UK REACH obligations. Exponent’s large REACH team comprises regulatory affairs professionals and project managers together with experts in chemistry, toxicology, ecotoxicology, environmental fate, exposure assessment, risk assessment, and socio-economic analysis. These scientists have backgrounds in industry, government, and contract research, giving us unparalleled expertise in solving complex regulatory problems. Many of our consulting staff have been working in the field of chemical regulation for over 10 years and have considerable experience with the EU REACH scheme, as well as other global chemical registration programmes.

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