On the 31st December 2021 the UK and EU ended the transition period, and many new regulations came into force including the new UK REACH regulations.
UK REACH is made up of five regulations:
- The REACH etc. (Amendment) Regulations 2021 SI No.904 2021
- The REACH etc. (Amendment etc.) (EU Exit) Regulations 2020 SI No. 1577 2020
- The REACH etc. (Amendment etc.) (EU Exit) (No. 3) Regulations 2019 SI No. 1144 2019
- The REACH etc. (Amendment etc.) (EU Exit) (No. 2) Regulations 2019 SI No. 858 2012
- The REACH etc. (Amendment etc.) (EU Exit) Regulations 2019 SI No. 758 2019
There is a consolidated version available here: https://www.legislation.gov.uk/eur/2006/1907/contents
The deadlines have recently been extended and are now as follows;
| Deadline | Tonnage | Hazardous property |
| 1000 tonnes or more per year | Carcinogenic, mutagenic or toxic for reproduction (CMRs) – 1 tonne or more per year Very toxic to aquatic organisms (acute or chronic) – 100 tonnes or more per year Candidate list substances (as of 31 December 2020) | |
| 100 tonnes or more per year | Candidate list substances (as of 27 October 2023) | |
| 1 tonne or more per year |
Under UK REACH many companies who were previously downstream users under UK REACH now find themselves as importers with obligations to register.
Companies could defer their registration deadlines to the dates above by either grandfathering or submitting a Downstream User Import Notification (DUIN). If you have not yet done your DUINs do them as soon as possible.
To be eligible to make a DUIN – If in the 2 years prior to 1 January 2021 you were a downstream user or distributor under EU REACH, or you were regarded as a downstream user by virtue of an Only Representative (OR) agreement, you were able to submit a downstream user import notification (DUIN) before 27 October 2021(300 days from January 2021). By submitting a DUIN you effectively defer your registration obligation for 2, 4 or 6 years, depending on the tonnage band and/or hazard profile, beginning after those 300 days. So, the time period is 1st Jan 2019 to 1st Jan 2021. Note that a sample is considered a previous import.
If you did not import the substance in the two-year window you will need to a New Registration of an Existing Substance (NRES).
Caroline can help you with;
- DUINs
- NRES
- Article 26 Inquiries
- UK REACH registrations
- Training
Caroline can help you meet your UK REACH obligations. Get in touch now!