The step-by-step obligations for UK-based companies
In order to achieve compliance and continue to market their products and chemicals, UK companies first had to go through the grandfathering stage. The companies concerned were UK-based companies that held an EU REACH registration between 29th March 2017 and the end of the transition period on 31st December 2021. They were given the opportunity until 30th April to transfer these to the UK, under UK REACH.
Secondly, for UK companies that were previously downstream users or distributors under EU REACH and have become importers under UK REACH, it is necessary to complete the DUIN (Downstream User Import Notification) before 28th October 2021.
Finally, British companies must register their substances in accordance with the conditions of UK REACH. As a reminder, UK REACH has retained the objectives and principles of European REACH such as "one substance, one registration" or the precautionary principle. To find out what information is required to complete your registration with peace of mind, we suggest you take a look at our infographic checklist of UK REACH registration essentials.
UK REACH: the next deadlines
It is important to note that companies have different deadlines to complete their registrations:
- 28th October 2023 for substances imported or produced at more than 1000 tonnes per year, as well as CMR (carcinogenic, mutagenic or reprotoxic) substances at more than 1 tonne per year, substances that are extremely toxic to aquatic organisms at more than 100 tonnes per year and substances on the Candidate List for authorisation as of 31st December 2020.
- 28th October 2025: substances imported or produced at more than 100 tonnes per year and substances on the Candidate List for authorisation as of 31st December 2023.
- 28th October 2027: substances imported or produced at more than 1 tonne per year.
Thus, despite the similarity to EU REACH, it is important to be aware of the new obligations that will arise as a result of the various role changes for both UK and European Union-based companies.
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