Published: 03 September 2020  (Updated: 11 September 2020)

Brexit Updates – UK REACH New Guidance and Timelines

On 2 September 2020, the Department for Environment, Food and Rural Affairs (Defra), published update guidance under  ‘How to comply with REACH chemical regulations’, covering the requirements for the placing of chemicals on the UK market after the 1 January 2021.  Most notably, the new guidance introduces changes to the timeline for completion of the regulatory requirements of notification and registration.

The revised deadlines will give 2, 4 or 6 years to complete the full registration depending on the tonnage bands and risk of the substances being registered, reflecting the phased approach taken under EU REACH.  It is anticipated that most of the ingredients used in cosmetic products will be covered by the third deadline (6 years).  Downstream users, which includes manufacturers or importers, could have new obligations under UK REACH.  Those entities with registration obligations have been given 300 days to complete the Downstream User Import Notification (DUIN), until 28 October 2021, after which the deadlines will apply.

The negotiations surrounding access to the ECHA (European Chemicals Agency) database under EU REACH, which could negate the need for full data submission, will continue, and cooperation with regards to chemicals will still be sought under the future UK-EU relationship.  

More information and an analysis of the guidance will be included in the CTPA Website shortly. 

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