New timetable published for UK REACH
New timetable published for UK REACH British government announced the extension of the registration deadlines under the future UK REACH up to 6 years, with a close deadline for submitting the first notification.
The UK REACH regulation, which is based on its European equivalent, will regulate the import, manufacture and use of chemical substances in the United Kingdom from the end of the transition period following Brexit, i.e. 1st January 2021. Companies that had a European REACH registration (which will therefore no longer be valid under UK REACH) will have it recognised in the UK provided that a first registration is submitted by 30th April 2021.
This registration will initially contain only basic information on the substances. The complete data were initially due within 2 years but the deadlines have been extended. From 28th October 2021, you will therefore have:
- 2 years to register substances imported or produced at 1,000 tonnes or more per year; as well as CMR substances (carcinogenic, mutagenic, toxic for reproduction) at 1 tonne or more; substances that are extremely toxic to aquatic organisms at 100 tonnes or more; and substances listed on the Candidate List for authorisation (as of 31st December 2020).
- 4 years for substances of 100 tonnes or more per year; as well as substances on the Candidate List (as of 27th October 2023).
- 6 years for substances imported or produced at more than 1 tonne per year.
UK downstream users who do not have a European registration become importers of substances to the UK. They will therefore have to submit a registration under the same deadlines as those who previously held a registration, but have 300 days from 1st January 2021 to submit a first notification (compared to 180 previously).
UK REACH: what will be the obligations for European companies?
For European companies, the process is more complex. Some had European registration (in the EU-27), but wish to continue to bear the burden of UK registration to lighten the load of their UK downstream users. This is not necessarily straightforward as only manufacturers or formulators outside the UK can appoint an Only Representative (OR).
Suppliers with a centralised Europe-wide distribution chain where an EU-27 company has multiple registrations to cover many downstream users may find it difficult to take on this role, often not being a manufacturer or formulator.
For companies that can appoint a representative, EcoMundo can act as OR through its London office for all your UK registrations.
Wish to know more about UK REACH Registration dossiers?
For more information, do not hesitate to contact Renaud Germain-Thomas or one of our experts via our contact form, indicating the purpose of your inquiry.
