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UK Registration, Evaluation, Authorisation and Restriction of Chemicals (UK REACH)
01 Jan 2025
As part of the UK’s departure from the European Union the UK “lifted and shifted” the EU REACH regulation into UK law. The UK has placed additional emphasis on the core pillars of REACH; to protect human health and the environment from the risks of chemical substances and to avoid testing on vertebrate animals. The regulation applies to substances which are manufactured or imported into Great Britain* at 1 tonne per year or more.
*UK REACH applies to Great Britain (GB) (England, Scotland and Wales). The Northern Ireland Protocol and Windsor Framework allow for Northern Ireland to continue to be subject to EU REACH, not UK REACH.
Maintain regulatory compliance
Working towards a sustainable chemicals industry since 1973, Ricardo has been working with the UK REACH regulations since their adoption during the UK’s departure from the EU and can provide a full range of compliance solutions as a REACHReady approved supplier.
Services
Only Representative Services
Substance or article manufacturers and reformulators of blended mixtures not based in Great Britain can appoint an Only Representative (OR) based in Great Britain as the UK REACH registration holder to act on behalf of all the GB Importers in their supply chains.
*Please note, distributors cannot appoint an OR directly and require the manufacturer or reformulator in their supply chain to provide the appointment letter.
Lead Registration
Ricardo can support companies intending to take on the Lead Registrant role for UK REACH with solutions ranging from testing strategy creation and laboratory monitoring, to contract negotiation and dossier creation. This service is useful for both new substances (substances which have not been registered before) and also substances which were registered before the UK departed the EU and now need to be re-registered under UK REACH. Ricardo provides a full suite of services to support both the EU and UK REACH regulations.
Downstream User Import Notification
Can only be used where the GB based Importer was receiving the substance between 1 January 2019 and 1 January 2021. DUIN can be used as part of an OR agreement but can only cover those GB Importers that were receiving the substance either from the OR supplier or another EU REACH compliant supplier between 1 January 2019 and 1 January 2021.
New Registration of an Existing Substance
Where a GB Importer wishes to begin receiving a substance that was registered in the EU under EU REACH before 1 January 2021 for the first time a Registration under UK REACH will be required. As UK REACH is still in the transitional phase, companies needing to register before the relevant transitional deadline can submit a New Registration of an Existing Substance (NRES). Where an NRES is obtained as part of an OR agreement the non-GB company appointing the OR can supply any GB Importer regardless of whether they have received the substance before or not.
Grandfathering Registration
Where a UK based company held an active EU REACH registration number prior to 1 January 2021, it is possible to claim a free Grandfathered UK REACH registration. Ricardo can create and submit claims on behalf of UK based entities and also companies using UK based OR who wish to transfer their OR representation to Ricardo.
Ever-evolving regulatory landscape
The UK REACH regulations are evolving rapidly. The UK Government is expected to announce changes to the UK REACH regulations in early 2025. In addition the UK Government has proposed a change to the fee structure of UK REACH registration fees. Replacing the current fee ladder structure with a single, relatively low flat fee.
Speak to an expert
By relying on Ricardo’s UK REACH experts, our clients are able to plan for market launches, receive advice on label requirements which helps anticipate market reception, and give their customers piece of mind that regulatory compliance is addressed before they order the product. Contact our experts today for a free, no-obligation discussion of your requirements.
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