The UK brought the European Union (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation into law on 1 January 2021, as UK REACH. UK REACH places equivalent responsibilities and standards on GB companies as they had under EU REACH.
Existing EU authorisation has been carried over into UK REACH – this is referred to as ‘grandfathering’.
Upcoming key dates
Notifications to the HSE: 30 April 2021 is the deadline for GB holders of existing EU REACH registrations to provide basic information to HSE: For UK companies wishing to benefit from the system of recognition of their EU REACH registration, or grandfathering: notification must be made within 120 days of the end of the transition period (30 April 2021). This allows registrations that have been held by a UK entity between 29 March 2017 and the end of the transition period to be recognised by UK REACH.
For UK companies wishing to register substances that they source from European companies covered by EU REACH, that is, as an importer; and also for European and non-European manufacturers with an EU REACH registration wishing to appoint a UK-based Only Representative (OR): notification must be made within 300 days of the end of the transition period (28 October 2021).
Following these notifications, companies have new deadlines to complete their UK REACH registrations according to their tonnage band. The first stage will only contain basic information on substances. The full registration must be submitted by these deadlines from 28 October 2021:
2 years to register:
- Substances imported or produced at 1000 tonnes or more per year.
- CMR substances (carcinogenic, mutagenic, toxic to reproduction) at 1 tonne or more.
- Substances that are extremely toxic to aquatic organisms at 100 tonnes or more; and substances on the Candidate List for authorisation (as of 31 December 2020).
4 years to register:
- Substances of 100 tonnes or more per year.
- The substances on the Candidate List (as of 27 October 2023).
6 years to register:
- Substances imported or produced at more than 1 tonne per year.
- Restrictions under new chemical regime announced for first time
On 23 March, the Government laid out plans for restrictions to be initiated under the new chemical regulation system, UK REACH, to tackle risks posed by chemicals. The launch of the UK REACH programme includes plans to initiate the restriction process on lead ammunition which is used widely in the shooting
industry and causes harm to the environment, wildlife and people.
Certain harmful substances that can be found in tattoo inks and permanent make-up could also be restricted. The ink in tattoos can sometimes contain substances that can cause health effects, most commonly skin reactions, such as irritation or sensitisation. The substances this restriction proposal will consider includes, but is not limited to, substances that can cause cancer, are dangerous to reproduction, skin sensitisers and irritants. A restriction will be introduced if evidence shows an unacceptable risk to human health and the environment, and after a public consultation. The review of the evidence will be conducted by the Health and Safety Executive (HSE), with support from the Environment Agency (EA). They will investigate the risk of per- and polyfluoroalkyl substances (PFAS) and consider how best to manage any identified risks. PFAS are a group of over 9,000 different chemicals, some of which are already banned or highly restricted. In industry, these substances are used as stain repellents, coatings and fire-fighting foams. The chemicals in PFAS are extremely persistent in the environment; the substances can accumulate in animals and can also be toxic; this means PFAS are of growing concern for both human health and environmental reasons.