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UK-based downstream user or a distributor of an EU REACH registered chemical

  • If the UK leaves the EU without a deal, EU/EEA countries will be in the same situation as non-EEA countries for the purposes of the UK REACH Regulation. This means that companies procuring substances and mixtures from EU/EEA suppliers either directly or in articles would become importers under UK REACH. These companies will then have an obligation to hold a UK registration as importers. However, in order to ensure continued access to the UK market and to maintain supply chains, we propose to implement a ‘notification’ system before full registration obligations are applied.
  • If you are a downstream user or distributor of EU/EEA-imported substances, you will need to complete a ‘notification’ by:
    1. Opening an account on the new UK REACH IT system.
    2. Providing some information within 180 days of the UK leaving the EU. Full details of the information required can be found in Appendix C.
  • Notification will not incur any fee from the UK Agency (the HSE).
  • The notification does not tie you to your existing EU/EEA supply chain: you may switch suppliers temporarily or permanently, and inform the UK Agency (the HSE) of any relevant changes.
  • If you are importing mixtures, you will only need to supply details of the substances which you can find out are contained in the mixture (where you import 1 tonne or more of the substance per year, taking account of all the mixtures where the substance is present).
  • You will need to register the substances with the UK Agency (the HSE) by providing the technical dossier appropriate to your tonnage to support your registration within two years of the UK leaving the EU, if you wish to continue importing these chemicals. This timescale will be kept under review. These will be classed as new registrations and will therefore be subject to fees payable to the Agency (the HSE).
  • EU/EEA manufacturers exporting to the UK may choose to appoint a UK-based OR to take on UK REACH obligations. This would be classed as a new substance registration: full registration duties (e.g. full data package submitted on registration) would apply, and the appropriate registration fee would be charged. If the EU/EEA manufacturer’s UK-based OR registers within 2 years of the UK leaving the EU, UK importers from the EU/EEA would regain the status of downstream user within UK REACH, and would therefore not need to become registrants themselves. If the OR completes their registration within 180 days of the UK leaving the EU, this would relieve their UK downstream users of the duty to notify the HSE within 180 days. UK downstream users may make use of the notification provision in the first instance, and consider further steps depending on their suppliers’ intentions in relation to the UK market.
  • Further information on what the new UK REACH will look like
You want to You need to By when

procure substances or mixtures (directly or in articles) from a UK-based entity

take no further action



procure substances or mixtures (directly or in articles) from an EU/EEA-based entity

EITHER notify HSE by:

1. Opening an account on UK REACH IT

2. Entering basic info on UK REACH IT

3. Registering the substances with the HSE by providing the technical information required under UK REACH

OR encourage the EU/EEA supplier to appoint a UK-based Only Representative

OR change source to a UK registered supplier

 

 

180 days post-exit day

2 years post-exit day

Updated: 2019-04-05