United Kingdom: transitional registration deadlines extended

December 12, 2022

Extension of transitional registration in the UK

Defra (UK Department for Environment, Food and Rural Affairs) has proposed legislation to extend the UK's current REACH (Registration, Evaluation, Authorisation and Restrictions of Chemicals) submission deadlines by 3 years. This legislation applies to all tonnage bands.

This decision is the result of a consultation launched by Defra on the options for extending the current deadlines and revising the dates. Its aim is to encourage the Health and Safety Executive (HSE) to carry out compliance checks on 20% of registration dossiers, as required under Article 41 of UK REACH.

Closed in September, the consultation received 289 responses from the industry. 3 options resulted from this consultation:

- Option 0 (baseline): submission deadlines unchanged

  • October 2023 for all substances manufactured/ imported in quantities of 1000 tons or more per year
  • October 2025 for all substances manufactured/ imported in quantities of 100 tons or more per year
  • October 2027 for all substances manufactured/ imported in quantities of one tonne or more per year

- Option 1: submission deadlines are extended by 3 years

  • October 2026 for 1000 tons or more per year
  • October 2028 for 100 tons or more per year
  • October 2030 for one ton or more per year

- Option 2: Bidding deadlines are extended differently depending on tonnage

  • October 2026 for 1000 tons or more per year
  • October 2027 for 100 tons or more per year
  • October 2028 for one ton or more per year

Defra appears to support option 2, which would provide UK-specific data more quickly.


Why is REACH registration in the UK being extended?

A new registration model is being worked on in the UK. As part of this, the UK government needs more time than anticipated to finalize this work. The extensions would allow additional time to finalize the new REACH registration model.

This new REACH model, should reduce data costs, although there are concerns within the industry about this.

However, some NGOs, including CHEM Trust, are "disappointed that the deadlines keep getting pushed back. This disappointment stems from the various extensions of deadlines and proposals by the legislation. In addition, a UK campaigner for the CHEM Trust, Chloe Alexander, has doubts about the protection this new model will offer the UK compared to the EU.

How to manage your REACH registration files in the UK?

To submit a registration dossier in the United Kingdom being a non UK country, you need to appoint an OR (Only Representative) to carry out your registrations. EcoMundo, a company specialized in REACH regulation since 2007, can act as an OR for your registration dossiers, thanks to its London office.

Our experts will guide you through the process of your UK compliance.

Regulatory context

Following Brexit, the UK REACH regulation came into force in January 2021. Manufacturers, importers and downstream users should comply with the new REACH regulation. In order to place their product in the UK market

Manufacturers, importers and downstream users can submit a DUIN notification to the HSE in order to benefit from 2, 4 or 6 years from 28 October 2021 to make full registrations of their substances.

Want to know more about UK REACH ?

For more information, please don't hesitate to contact us !

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