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What is UK REACH?
After Brexit, UK REACH was introduced as the United Kingdom’s adaptation of REACH. As in the REACH Regulation, UK REACH aims to ensure the safe manufacture, import or use of chemicals on the border of Great Britain. It applies to many substances, such as a substance on its own; a substance in a mixture; or a substance in an article.
Business that wishes to take place in the market of England, Scotland and Wales, are expected to assure compliance with UK REACH.
What is the difference between EU REACH and UK REACH?
As stated below, UK REACH was brought into UK law after Brexit, on 1 January 2021. Although the key principles of EU REACH were left untouched, UK REACH is a version of REACH that has a more domestic context. As they are separate regulations, companies must comply with both if required.
Key differences between EU REACH and UK REACH are listed below:
- Pre-registration is no longer possible for both. However, DUIN is applicable for Great Britain-based importers of EU REACH-registered substances.
- In the transition process, grandfathering was possible for UK REACH until 30.4.2021.
- As there has been a process of transition from EU REACH to UK REACH, the registration deadlines for UK REACH are set depending on their existence in the UK market in 2019 and/or 2020, their hazards and their tonnage per year.
- In UK REACH, data requirements may show differences for some substances of lesser concern.
Main Requirements of UK REACH
- Registration
Substances manufactured or imported into the borders of Great Britain must be registered under UK REACH. This is a requirement that applies to substances at an annual volume starting from 1 t/a. Deadlines for the registration requirements are given here. - Authorisation
Companies must apply for authorisation for use of substances. These substances under the authorisation requirement are included in Annex XIV which is known as Authorisation List. - Restriction
For full compliance, companies must pay regard to Annex XVII which includes restriction requirements. - Usage in Compliance
Companies must use their substances or mixtures following their e-SDSs which give information on the safe use of the related substance. This way, the safety of workers and users is ensured. - Communication
As in every aspect of life, communication is key in ensuring protection against harmful chemicals. Companies must be sure that they communicate every needed information on SVHC in articles and take actions bearing in mind that information.
How to Register Under UK REACH?
The basics of UK REACH registration are the same as EU REACH registration. According to both regulations, substances manufactured or imported as such or as part of mixtures at 1 t/a or more are required to be registered. Also in both regulations, the registration tonnage bands are 1-10 t/a, 10-100 t/a, 100-1000 t/a and >= 1000 t/a. Registration types and joint submission are common points of these regulations.
UK REACH Registration HSE Fees
The quantity of UK REACH registration fees depends on the company size and tonnage band. The article that the substance is registered under also affects the fees.
You can view UK REACH fees and charges from this page.
UK REACH and DUIN
What is DUIN?
DUIN is the acronym for “Downstream User Import Notification”. DUIN is a requirement applicable to downstream users that import substances into the United Kingdom. These users are required to register their substances and make a notification to the HSE regarding their uses. However, it must be noted that DUIN is not equivalent to pre-registration and it does not provide access to the substance group which is the equivalent of SIEFs in the context of EU REACH.
UK REACH Registration and DUIN
According to UK REACH, DUIN permits UK market access after the notification. This permission was defined to last 2, 4, or 6 years after the DUIN deadline which is on 27 October 2021. HSE states that downstream users that notified their substances under DUIN, are not obligated to register them unless they wish to import the notified substance after UK REACH Registration deadlines. If they wish to register, they must submit an Article 26 inquiry.
UK REACH and NRES
What is NRES?
NRES refers to “Non-Resident Establishments”. These are companies or organizations based outside the United Kingdom. However, they do have a presence within the UK. If these companies or organizations take place in the import, export or manufacture of chemicals, they are subject to some legal requirements set by UK REACH.
Aim of this application is to ensure chemical safety regardless of where the company is headquartered.
UK REACH Registration and NRES
According to UK REACH, companies which do not apply to Grandfathering or DUIN regarding substances defined as “Existing Supply”, must complete registration to enter into the Great Britain market. This applies to substances in the quantity of 1 tonne or more.
In the case where the substance is already has been registered under the EU REACH by the company themselves or someone else, the company may be applicable for joint registration under NRES. After the required inquiry dossier is submitted, HSE informs companies whether they are applicable for NRES. You can benefit from our support in this process.
Deadlines for UK REACH Registration
Deadlines for UK REACH transitional (Grandfathering, DUIN and NRES) registration are as in the table below:
| • 1000 tonnes or more per year • Very toxic to aquatic organisms: 100 tonnes or more per year • Substances on UK Candidate List as of 31 December 2020: 1 tonne or more per year | 27 October 2023/2026 (extended) |
| • Substances at 100 – 10000 tonnes per year • Substances on UK Candidate List as of 27 October 2026: 1 tonne or more per year | 27 October 2025/2028 (extended) |
| • Substances at 1 tonne or more per year | 27 October 2027/2030 (extended) |
UK REACH Registration Services
Complying with UK REACH is crucial for any business involved in the chemical industry in the UK. By registering your substances and ensuring ongoing compliance, you can avoid penalties and ensure your products remain on the market.
You can benefit from our expert consultancy services to help your company navigate UK REACH requirements.
If you have any questions regarding UK REACH, don’t hesitate to get in touch with us.
Frequently Asked Questions
According to HSE, deadlines of UK REACH have been extended to 27 October 2026, 27 October 2028 and 27 October 2030 depending on tonnage and toxicity. You can find the details here.
No, pre-registration is not a concept included in UK REACH.
No. Grandfathering has not been possible for UK REACH since 30 April 2021.
NRES stands for “Non-Resident Establishments” which are not based in the UK but do have a presence in. If these companies/organizations take place in importing, exporting or manufacturing chemicals, they are subject to UK REACH.
DUIN refers to “Downstream User Import Notification” which applies to downstream users importing substances into the UK.