The United Kingdom government has provided new guidance on the UK-Reach., which will come into force following Brexit, and the end of the interim period bythe end of 2020.
The key points for importers from the EU to the UK are that:
• EU/EEA based companies who import chemicals into the UK under UK REACH must ensure that they are covered by a valid UK REACH registration.
• These companies can register the substance under UK REACH through a UK-based OR or an affiliate UK importer.
• If the EU/EEA company takes on registration obligations through a UK-based entity, their UK customers will retain their downstream user status.
It seems that the UK will not have a deal immediately with EU, and that the “UK-Reach” Regulation is likely to go ahead.
What has changed is a postponement of when the “pre-registrations” will need to be done, i.e. 30 April 2021, or for some substances at 31st October 2021, rather than end December 2020 as in draft Regulation. There is no process or guidance for this yet, but it is said that DEFRA will make announcement later this year on process.
1. Importing in UK where you have EU registration
Where and if a company holds the EU Reach registration in EU, one needs to appoint an OR between Jan 1 and April 30 2021 then do the UK “pre-registrations”.
2. Importing into UK from another EU registered supplier
This is where it may be worth checking what suppliers are doing on UK registration.
If the suppliers are not planning to register in UK, it may be necessary to think about changing suppliers for UK.
Linmark Consulting Ltd UK, offers services as “Only Representative” under UK-Reach.