Introduction of UK REACH Regulation and Response Guidelines

Release time:

2021-03-26 14:23

With Brexit, the UK REACH regulation will come into effect on January 1, 2021. Except for Northern Ireland, which continues to implement the EU REACH regulation, all other UK regions will implement the UK REACH regulation. The overall framework, registration process and requirements of the UK REACH are similar to those of the current EU REACH, enterprises are required to submit registration files to the UK Health and Safety Administration (HSE) through the REACH-IT system for registration before putting more than 1 ton/year of chemicals into the UK market. UK REACH also has no pre-registration or post-pre-registration. How do companies respond to UK REACH regulations at this stage?

Our recommendations are as follows:

01
Through DUIN notification-I .e. downstream user import notification: non-UK enterprises, including Chinese enterprises, that have registered with EU REACH can make DUIN notification through OR in the UK or through UK importers. Chinese enterprises that have successfully registered REACH through EU OR before December 31, 2020 can entrust OR in the UK to complete DUIN notification. DUIN notification must be completed before October 27, 2021. After completion of notification, enterprises can obtain 2 years according to registered tonnage and chemical hazard classification (applicable to substances exported to the UK greater than 1000 tons/year, substances which are carcinogenic, mutagenic or toxic to reproduction and have a registered tonnage of more than 1 tonne/year, substances which are very toxic to aquatic organisms and are exported to the UK of more than 100 tonnes/year, substances on the List of Substances of High Concern by 31 December 2020), 4 years (for substances exported to the UK of 100-1000 tonnes/year, substances listed as substances of high concern before October 27, 2023) or a UK REACH registration buffer period of 6 years (applicable to substances exported to the UK 1-100 tons/year).

02
Official registration through UK REACH: The UK REACH registration process and required information are similar to those of the EU REACH registration. Chinese enterprises can complete the UK REACH registration by entrusting OR in the UK.
03
Through grandfather clause (Grandfather Clause): applicable to registrants of British companies or non-British enterprises who have completed EU REACH registration before December 31, 2020 through British OR. UK REACH regulations require these enterprises to obtain REACH registration numbers by submitting registration number information to HSE before April 30, 2021. After obtaining registration numbers, these registrants will obtain buffer periods of 2 years, 4 years or 6 years respectively according to registered tonnage and material hazard characteristics, it is sufficient to submit the complete registration information within the corresponding buffer period.

About UK REACH, we provide the following services:

Providing UK-REACH sole representative (OR) services for non-UK based businesses, including Chinese businesses

UK-REACH Downstream User Import Notification (DUIN) Service

UK-REACH Official Registration Service

Production service of SDS and ESDS in accordance with UK-REACH regulations

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