Downstream users and UK REACH: how are they impacted?

9/11/2020

For downstream users based in the United Kingdom

The role of downstream users based in the United Kingdom supplying from companies manufacturing substances registered in the EU-27 will change. These companies will no longer be covered by EU REACH registration and will have to ensure that their substances are registered under UK REACH. There are three possibilities for this:

  • Either their supplier can appoint an only representative, or OR and take care of the UK REACH registration which is the simplest solution for downstream users;
  • Either they will be obliged to register these substances themselves under UK REACH as an importer;
  • Or they will have to find a supplier based in the UK, who will naturally take care of the UK REACH registration.

In order to avoid potential revenue leakage to the UK due to the 3rd solution, we invite our customers and all companies with downstream users under UK REACH to register their substances themselves in the UK, via an OR.

EcoMundo can assist you in your UK REACH registration process. Thanks to our London office, we can also take on the role of OR for your UK REACH dossiers. The EU REACH and REACH-like expertise of our consultants allows us to master the future UK REACH regulation despite the uncertainties that may persist regarding its application.

For downstream users based in the EU-27

Downstream users purchasing from UK-based companies also become importers under EU REACH. To avoid this, we recommend that UK suppliers appoint an only representative in the EU-27 now to avoid losing their downstream users.

UK REACH: what are the key points for compliance?

With the entry into force of UK REACH and the end of the transition period on 1st January 2021, it is now necessary to anticipate compliance. A few key points for this:

  • Check your obligations now: to do so, you can consult our dedicated article.
  • If necessary, appoint an only representative, or OR if you are obliged to do so.
  • Find out about the intentions of each stakeholder in your supply chain, as well as those of your customers. This can give you guidance on how to proceed.

Finally, if you have any doubts, do not hesitate to watch the replay of our webinar dedicated to UK REACH. By downloading it, you will also be subscribed to updates on our future UK REACH webinars.

For downstream users based in the United Kingdom

The role of downstream users based in the United Kingdom supplying from companies manufacturing substances registered in the EU-27 will change. These companies will no longer be covered by EU REACH registration and will have to ensure that their substances are registered under UK REACH. There are three possibilities for this:

  • Either their supplier can appoint an only representative, or OR and take care of the UK REACH registration which is the simplest solution for downstream users;
  • Either they will be obliged to register these substances themselves under UK REACH as an importer;
  • Or they will have to find a supplier based in the UK, who will naturally take care of the UK REACH registration.

In order to avoid potential revenue leakage to the UK due to the 3rd solution, we invite our customers and all companies with downstream users under UK REACH to register their substances themselves in the UK, via an OR.

EcoMundo can assist you in your UK REACH registration process. Thanks to our London office, we can also take on the role of OR for your UK REACH dossiers. The EU REACH and REACH-like expertise of our consultants allows us to master the future UK REACH regulation despite the uncertainties that may persist regarding its application.

For downstream users based in the EU-27

Downstream users purchasing from UK-based companies also become importers under EU REACH. To avoid this, we recommend that UK suppliers appoint an only representative in the EU-27 now to avoid losing their downstream users.

UK REACH: what are the key points for compliance?

With the entry into force of UK REACH and the end of the transition period on 1st January 2021, it is now necessary to anticipate compliance. A few key points for this:

  • Check your obligations now: to do so, you can consult our dedicated article.
  • If necessary, appoint an only representative, or OR if you are obliged to do so.
  • Find out about the intentions of each stakeholder in your supply chain, as well as those of your customers. This can give you guidance on how to proceed.

Finally, if you have any doubts, do not hesitate to watch the replay of our webinar dedicated to UK REACH. By downloading it, you will also be subscribed to updates on our future UK REACH webinars.