Published: 04 May 2021  (Updated: 04 May 2021)

IMPORTANT – post-Brexit Compliance with UK REACH

All chemicals manufactured or imported into the GB market above 1 tonne/year per legal entity must comply with the UK Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation.  For more information, please visit the section of ‘UK preparedness actions’ of the CTPA Brexit public advice and the recording of the latest CTPA webinar on the UK Regulations for Cosmetics.

The Health and Safety Executive (HSE) is responsible for implementing UK REACH and has extensive guidance on how to comply with the requirements of this Regulation.

Actions for GB-based companies selling chemicals (on their own or within mixtures) to GB which are already registered under EU REACH

  • If you are a GB-based downstream user of chemicals importing from the EU/EEA/NI, you may become an importer.  This implies a change in your role and obligations.
  • It is important for GB-based companies importing chemicals from the EU/EEA/NI to map their supply chain and understand which chemicals are impacted, considering the 1 tonne/year per legal entity threshold for applicability of REACH; and for companies to communicate with their EU/EEA/NI suppliers of the impacted chemicals.
    • Have the suppliers grandfathered their EU REACH registration to UK REACH? 
      • If yes, a downstream user may maintain their role and have no further action in the short term.
      • If not, a downstream user must submit a Downstream User Import Notification (DUIN) to the HSE via the UK REACH-IT system.  More details are available at the above linked resource.
    • Have the suppliers committed to comply with the UK REACH requirements of submitting the full registration within the 2/4/6 years deadline?
      • If yes, a downstream user may maintain their role and have no further action in the short term.
      • If not, a downstream user can choose to either
        • fulfil the registration obligations under UK REACH, or
        • change supply chain to source a chemical already complying with UK REACH and therefore maintain their role.
      • Overall, it may be worth for downstream users considering submitting DUINs for all or most of the chemicals they import into the GB market.  This is to comply with the UK REACH requirements from a downstream user perspective, and ensure continuity of supply until the full registration deadlines.  The DUINs may be done also for substances imported below 1 tonne per year, to cover for any possible future increase of import quantities. 
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