UK REACH: am I affected by the January 2021 deadline?

2/11/2020

Whether you are based in the UK or in the EU-27, if your market includes the UK, your requirements will change on 1st January 2021. The EU REACH regulation (or European REACH) will cease to apply to the United Kingdom, the UK will lose its membership to ECHA and the British counterpart of the regulation, UK REACH, will come into force.

The new UK REACH obligations may affect several actors:

  1. British companies,
  2. European companies exporting to the UK,
  3. Non-European companies exporting to the UK

In all three cases, EcoMundo assists you in understanding and meeting all your obligations to the UK authorities under UK REACH and its implementation from January 2021. Our London office allows us to support your UK REACH registrations as your Only Representative (OR).

UK REACH: British companies' obligations for January 2021

UK holders of an EU REACH registration will have to register their substances in the UK under UK REACH. Their registrations will be legally recognised by the UK REACH system at the end of the transition period. It is called grandfathering. This recognition process means that UK companies already holding a REACH registration will have 120 days from the end of the transition period to submit information on their substances to the Health and Safety Executive, or HSE. This process applies to all REACH registrations that have been held by a UK entity at any time between 29th March 2017 and the end of the transition period.

UK downstream users and distributors of substances from European suppliers will become importers under UK REACH. They can therefore:

  • Register these substances themselves;
  • Ask their European suppliers to handle UK REACH registration via a UK-based OR (Only Representative).

In all cases, the registration of a substance first requires a notification on the new UK REACH IT system - named �Comply with UK REACH� - within 300 days after the end of the transition period, followed by a full registration within the next 2, 4 or 6 years.

What are the requirements in 2021 for European companies exporting to the UK?

European companies that want to continue supplying the UK market will have to either:

  • Register their substances as exporters under UK REACH via an OR (see above)
  • Rely on their customers who would then become importers under UK REACH and take over the registration process.

UK REACH: compliance for non-European companies exporting to the United Kingdom

For non-EU companies exporting to the UK, in case their registration is already supported by a UK OR it will be transposed according to the grandfathering process into UK REACH at the end of the transition period.

On the other hand, if their registration has been made by an EU-27-based OR, they will have to designate a UK-based OR to carry out their UK REACH registration at the end of the transition period.

In conclusion, it is essential to anticipate the end of the transition period in order to fully understand the extent of your obligations under UK REACH and to take the necessary steps if necessary.

Wish to know more about UK REACH Registration dossiers?

For more information, do not hesitate to contact Saad Shehadeh or one of our experts via our contact form, indicating the purpose of your inquiry.

Whether you are based in the UK or in the EU-27, if your market includes the UK, your requirements will change on 1st January 2021. The EU REACH regulation (or European REACH) will cease to apply to the United Kingdom, the UK will lose its membership to ECHA and the British counterpart of the regulation, UK REACH, will come into force.

The new UK REACH obligations may affect several actors:

  1. British companies,
  2. European companies exporting to the UK,
  3. Non-European companies exporting to the UK

In all three cases, EcoMundo assists you in understanding and meeting all your obligations to the UK authorities under UK REACH and its implementation from January 2021. Our London office allows us to support your UK REACH registrations as your Only Representative (OR).

UK REACH: British companies' obligations for January 2021

UK holders of an EU REACH registration will have to register their substances in the UK under UK REACH. Their registrations will be legally recognised by the UK REACH system at the end of the transition period. It is called grandfathering. This recognition process means that UK companies already holding a REACH registration will have 120 days from the end of the transition period to submit information on their substances to the Health and Safety Executive, or HSE. This process applies to all REACH registrations that have been held by a UK entity at any time between 29th March 2017 and the end of the transition period.

UK downstream users and distributors of substances from European suppliers will become importers under UK REACH. They can therefore:

  • Register these substances themselves;
  • Ask their European suppliers to handle UK REACH registration via a UK-based OR (Only Representative).

In all cases, the registration of a substance first requires a notification on the new UK REACH IT system - named �Comply with UK REACH� - within 300 days after the end of the transition period, followed by a full registration within the next 2, 4 or 6 years.

What are the requirements in 2021 for European companies exporting to the UK?

European companies that want to continue supplying the UK market will have to either:

  • Register their substances as exporters under UK REACH via an OR (see above)
  • Rely on their customers who would then become importers under UK REACH and take over the registration process.

UK REACH: compliance for non-European companies exporting to the United Kingdom

For non-EU companies exporting to the UK, in case their registration is already supported by a UK OR it will be transposed according to the grandfathering process into UK REACH at the end of the transition period.

On the other hand, if their registration has been made by an EU-27-based OR, they will have to designate a UK-based OR to carry out their UK REACH registration at the end of the transition period.

In conclusion, it is essential to anticipate the end of the transition period in order to fully understand the extent of your obligations under UK REACH and to take the necessary steps if necessary.

Wish to know more about UK REACH Registration dossiers?

For more information, do not hesitate to contact Saad Shehadeh or one of our experts via our contact form, indicating the purpose of your inquiry.