Denehurst Chemical Safety Ltd - UK-REACH

UK REACH / GHS

At this time of writing, there is still uncertainty whether the UK will remain as part of the EU-REACH / CLP framework, together with biocidal products, plant protection, cosmetics etc.

Until there is a clear indication that the UK will not remain part of these EU processes, it is advised to do nothing other than make some simple preparations to be ready for a split in the regulatory regimes.

This guidance is deliberately brief and will be expanded if it is necessary to make the changes to accommodate separate UK and EU-27 systems.

The main points to consider are:

• The UK will retain the regulations, but as UK Statutory Instruments and not EU Regulations. Drafts have been prepared that are virtually identical to the Regulations in terms of technical content. Therefore, expect continuity in terms of a REACH process, includes SDS formatting and content and also continuity in Classification and Labelling requirements

• The UK has not provided a lot of detail; this is deliberate to avoid unnecessary work and effort in case it is not required.

• The UK will have its own REACH-IT portal for submissions; this is ready to be switched on.

•  Expect a period of time in the UK to meet Registration requirements for substances currently supplied from the EU; this will be a form of pre-registration with full registration at some point after (likely at least 2 years)

•  EU-27 organisations importing from the UK will need to Register to allow continued supply, although UK manufacturers and processors will be able to appoint an Only Representative

For further advice, contact Denehurst.