BREXIT Milestones

• 23 June 2016: UK votes to leave the EU
• 29 March 2017: UK’s notification of Article 50 triggers the Brexit process; start of 2 year negotiation period
• 21 March 2019: the EU agreed with BREXIT extensions and provided 2 options
• 10 April 2019: Emergency EU summit decides on a UK flexible extension until 31 October 2019
• 17 October 2019: A new consensus reached between EU and UK
• 28 October 2019: EU agrees to extend UK withdrawal until 31 January 2020
• 12 December 2019: UK calls for an early election
• 29 January 2020: Agreement passed by the EU
• 31 January 2020: Brexit day. Transition period begins
• 2 March 2020: Beginning of negotiations
• 31 December 2020: UK officially left the EU

UK REACH Introduction

UK REACH, the UK’s independent chemicals regulatory framework, starts on 1 January 2021. Anyone making, selling or distributing chemicals in the UK needs to follow UK REACH rules. The overall framework, registration process and requirements of UK REACH will mostly align with the current EU REACH:

• Registration, evaluation, authorization and restriction of chemicals. A manufacturer or importer of a substance, either on its own or in one or more mixture(s), in quantities of one tonne or more per year shall submit a registration to the Agency;
• Online submission system: Comply with UK REACH;
• Inquiry submission rather than pre-registration or late-pre-registration;
• Fees and charges are based on the 2017 ECHA fee standard.

Roles, Options and Action

Transitional Provisions

①UK-based EU REACH registration holder

For UK REACH:

All registrants will be grandfathered into the UK REACH. The registrant must submit the registration information of the EU to the Agency by 30 April 2021. The Agency must assign a registration number to the substance concerned. All of the other information must be submitted to HSE within 300 days of the end of the transition period plus either 2, 4 or 6 years depending on the tonnage and hazard profile of the substance being registered. No fee is payable from HSE.

For EU REACH:

• transfer your registration(s) to an EU-based entity (e.g. affiliate or Only Representative) before transition period ends;
• ensure your EU importers comply with EU REACH.

②EU-based EU REACH registration holder

For UK REACH:

The UK importer or the UK OR will submit a “notification” by 27 October 2021 to the UK Agency. A new registration must then be submitted to the HSE within 2, 4 or 6 years of 28 October 2021.

For EU REACH:

No action needed.

③ Non-EU/EEA (non-UK) manufacturer or formulator, covered by a UK OR

For UK REACH:

All registrants will be grandfathered into the UK REACH

For EU REACH:

Registrations must be transferred to a new EU OR

④ Non-EU/EEA (non-UK) manufacturer or formulator, covered by an EU OR

For UK REACH:

• Appoint a UK OR or;
• Encourage UK importer to take care of UK REACH.

For EU REACH:

No action needed.

⑤ UK-based downstream user or distributor, importing EU REACH registered substances from EU

In case the non-UK manufacturer( or formulator) has not appointed a UK REACH OR, the UK importer will have to comply with UK REACH importer requirements, by submitting a “notification”  by 27 October 2021 to the UK Agency.

⑥EU business relying on REACH registrations from UK suppliers

Will become importers under EU REACH, subject to registration requirements unless they are covered by EU ORs appointed from UK companies.

Registration

If Transitional Provisions do not apply to your company, then a new registration is required.

Step 1: submit an Inquiry dossier

Step 2: prepare a registration dossier

Under UK REACH, as under EU REACH, registrations are to be submitted jointly, the concept of’ one substance, one registration’ has been retained.

• For substances that were previously registered under EU REACH (defined as NRES, a New Registrant of an Existing Substance), you are able to defer the submission of the full information requirement such that you are able to share data with other registrants and grandfathered registrants. It means you are allowed to submit a dossier including a waiver statement to explain why you are currently unable to provide all the relevant test summaries; that you will make every effort to negotiate with the other members of the Substance Group and will subsequently either provide the data yourself as lead registrant or will become a member of the joint registration.

Following this, within 2, 4 or 6 years from 28th October 2021 you will need to submit a registration to the Agency which complies with the full information requirement for your tonnage band if you wish to continue to manufacture/import in/into the UK.

• For substances that have not previously been registered with ECHA under EU REACH (defined as ‘novel’ substance), the information requirements for your tonnage band must be fulfilled in their entirety before your registration is granted, taking into account appropriate data waivers.

Step 3: submit the dossier and pay the fee to HSE

Step 4: UK REACH registration number granted

Deadlines for the Full Submission of Data

Update:

• Feb 22, 2023 – The consultation process for extension is complete, and a three-year extension of current deadlines for each tonnage band is agreed upon. The government is now in the process of introducing legislation to give effect to its proposal. It is anticipated that the legislation on the extended timelines comes into force in the summer of 2023, ahead of the first of current deadlines of 27 October 2023.
• July 5, 2022 – UK Consults on Extending the UK REACH Submission Deadlines

Our Services

• OR transfer service
• UK REACH “DUIN” notification
• UK REACH inquiry
• UK REACH registration
• Technical support

What Makes Us Different

• REACH24H Consulting (UK) Ltd.
• The experience accumulated over the years in the management of thousands of EU REACH registration cases
• Risk assessment experience and ample laboratory resources
• The strong technical team composed of professional-background technicians in chemical engineering, biology, environment, etc.