UK REACH is the new regulatory system for managing manufacture and supply of industrial chemicals in the United Kingdom, following its withdrawal from the EU. PFA can support you with compliance in the UK, building on more than ten years of experience of technical services to REACH registrants in the EU.
Changes to chemical compliance in the UK
The UK left the EU in 2020 and the ‘transition period’ ended on 31 December 2020. Since 1 January 2021, new rules are now in force for companies manufacturing, importing and supplying chemicals in Great Britain (Northern Ireland continues to operate EU REACH). To access the GB market, manufacturers (those making chemicals) and importers (those bringing in chemicals to GB from outside GB) have a duty to register chemicals.
In UK REACH, SVHCs that had gone through the full authorisation process by 31 December 2021 are recognised by UK REACH, but these existing granted authorisations, and those depending on them in the supply chain, must notify the HSE by 1st March 2021. New authorisation applications, and authorisations waiting for EC/ECHA approval, must now be submitted to UK REACH. Authorisations granted under EU REACH for GB-based companies will need to be re-applied for in UK REACH 18 months prior to the end of the review date.
Phase-in procedures and Registration
In the short term, affected companies must take action according to their role in the supply chain.
GB based manufacturers / importers who already had active REACH EU registrations by the end of the Transition Period, must make a submission via the Comply with UK REACH portal in order to validate their existing registrations and ‘grandfather’ them into the new system. Companies manufacturing or importing a substance into GB for the first time must complete an Inquiry via the Comply with UK REACH portal, before they register.
GB-based importers from an EU-based supplier were previously downstream users without registration responsibilities of their own. Under UK REACH they Notify via the Comply with UK REACH portal to obtain a DUIN, and prepare to take on registration responsibilities for the first time (unless their EU-based supplier undertakes this on their behalf).
Thereafter, registration dossiers must be prepared and submitted for each substance. For phase-in registrations these must be completed within 2, 4 or 6 years of 28 October 2021, depending on substance tonnage band and hazard class. For substances previously registered under REACH in EU, the information needs will be very similar.
Restrictions that are currently in place under EU REACH will remain under UK REACH.
Why choose PFA for UK REACH consultancy?
Building upon our experience of developing and providing ongoing post-registration maintenance support for more than 200 substances under EU REACH, our team offers similar technical services under UK REACH.
The withdrawal of the UK from the EU system means many GB-based businesses buying from an EU-based supplier must now take on a Registrant role for the first time. PFA is well placed to support new registrants and understand their role and comply responsibly, with good knowledge of what complying with UK REACH means for them.
As well as extensive work on REACH registration dossiers, we have twenty years’ experience in developing regulatory data packages for other purposes. PFA knows how to apply the best scientific knowledge to develop robust and complete dossiers, which is essential for both regulatory acceptance and cost savings.
Our understanding of scientific techniques and practical context enables us to make the best use of existing information, and to ensure that testing programmes are appropriate.
We have expert knowledge on the fate and effects chemicals, including analytical and environmental chemistry, toxicology and ecotoxicology. Our technical team are experienced with developing justifications to support alternative approaches when data gaps exist.
Our exposure modelling experience allows us to develop fit-for-purpose Exposure Scenarios for UK uses, complete with realistic operational conditions and proportionate risk-management measures.