Strategic REACH advice on Brexit impacts:

At REACh ChemConsult GmbH we provide advice and training on UK-REACH and offer the UK Only Representative Service through a company based in Great Britain.

Do you purchase chemicals, whether single substances or mixtures, from the UK or sell them to the UK? If you import from the UK, you are considered an importer of substances from the UK after the transitional period expires on 31.12.2020 and are therefore subject to registration in accordance with EU-REACH. Your customers in the UK will then be regarded as importers under UK-REACH. There are extensive obligations for both EU companies and UK companies.

We will be happy to advise you on how to implement the new obligations arising from the EU-REACH Regulation as well as from UK-REACH for you or your suppliers and customers. We will check which scenarios arise for your raw materials and products in your supply chain. We help you to ensure smooth import from and export to the UK.

For UK-REACH,

Substances, on their own or in mixtures, that are manufactured in or imported into the UK in quantities equal or greater than 1 tonne per year will need to be registered with the UK Health and Safety Executive (UK HSE) unless an exemption applies.

Transitional periods for the transmission of data are currently envisaged from 01.01.2021. For companies based in the UK, EU REACH registration(s) will be legally recognised in the UK REACH system when the transitional period ends (31.12.2020). This recognition is called 'grandfathering'. This means that these companies will continue to have access to the UK market after the end of the transitional period. 'Grandfathering' applies to all existing GB-based EU registrants. However, a notification to the UK authority with relatively manageable data had to be be submitted within 120 days. Technical information required under the UK REACH Regulation for your registration should originally be submitted within 300 days plus either 2, 4 or 6 years after the end of the transitional period. On 28 June 2023, the United Kingdom published the amendment to the REACH Regulation 2023 (No 722), which extends the legal deadlines for registrants to submit information by three years. The deadline depends on the tonnage (>=1000 t/a, >=100 t/a, >=1 t/a) and/or the hazard profile of the substances (CMR, very toxic to aquatic organisms (acute or chronic), substances on the SVHC candidate list).  

Former downstream users in UK:

Anyone purchasing substances and mixtures from EU/EEA or other none UK suppliers, either directly or in articles, would become an importer under the UK REACH Regulation. In order to ensure continued access to the UK market and to maintain supply chains, a notification system was put in place before the full registration obligation is applied. It was required to provide some information within 300 days after the end of the transitional period (October 27, 2021) before the actual registration information must then be provided within 300 days plus either 2, 4 or 6 years after the end of the transitional period.

Fortunately, the DUIN is still possible for companies that missed the deadline. HSE says on its website: "If you did not notify HSE and wish to continue to import EU REACH registered substances into Great Britain at or above one tonne per year, you can still submit a notification, if eligible to do so. You should do this as soon as possible."

UK Only Representative Service

For manufacturers and formulators outside of UK, we offer an exclusive only representative service via our renowned partner in the UK. We have carried out many notifications until October 27^th, 2021. The DUIN is still possible for companies that missed the deadline! However the DUIN should be done as soon as possible, as we don`t know how long HSE allows this.

After the DUIN we will carry out the registrations required thereafter in your name via our OR service within the respective deadline. On 28 June 2023, the United Kingdom published the amendment to the REACH Regulation 2023 (No 722), which extends the legal deadlines for registrants to submit information by three years. The new deadlines (last date for dossier submission) are

• 27 October 2026 for 
  • substances with 1000 tonnes or more per year,
  • substances with carcinogenic, mutagenic or toxic for reproduction (CMRs) hazardous classification - 1 tonne or more per year,
  • substances very toxic to aquatic organisms (acute or chronic) - 100 tonnes or more per year,
  • candidate list substances (as at 31 December 2020)

• 27 October 2028 for 
  • substances with 100 tonnes or more per year,
  • candidate list substances (as at 27 October 2026)

• 27 October 2030 for substances with 1 tonne or more per year .

Please Contact us for UK/EU-REACH-Brexit advice or to make an offer for the Only Representative Service in UK.