EU/EEA-based suppliers to Great Britain under UK REACH
This guidance is for businesses based in the EU or EEA that intend to supply customers in Great Britain (England, Scotland and Wales) after the transition period ends.
Changes to the status of GB-based businesses procuring substances from the EU/EEA
After the transition period ends businesses based in Great Britain (England, Scotland and Wales) that procure substances and mixtures, including in articles, directly from EU/EEA suppliers, will become importers under UK REACH (they were downstream users or distributors under EU REACH).
Those procuring from EU/EEA suppliers will be required to hold a UK REACH registration as importers to keep sourcing from an EU/EEA supplier unless their supplier chooses to appoint a Only Representative (OR) based in Great Britain to register with UK REACH on their behalf.
Ways an EU/EEA-based supplier can register under UK REACH
To continue to supply a business based in Great Britain the registration can be done by the:
- importer based in Great Britain
- you as the exporter via a GB-based OR
UK REACH registration by the importer based in Great Britain
If your customer in Great Britain was sourcing the substance from the EU/EEA at any point between 29th March 2017 and the end of the transition period, they may be able take advantage of the transitional ‘notification’ system. The page on GB-based downstream users or distributors of EU REACH registered chemicals will help you to check if you meet this criteria.
A notification must be completed within 300 days of the end of the transition period. It must then be followed up by a full registration (by a deadline determined by the tonnage and hazard profile of the substance.
UK REACH registration by an OR based in Great Britain
Before the transition period ends
EU/EEA manufacturers, formulators and ORs may transfer their EU REACH registrations to a GB-based OR or an affiliate GB importer (which could then supply your GB customers). Your GB customers would then be downstream users if their proposed use is covered by that registration. Registrations held by GB-based entities prior to the end of the transition period will be recognised by (known as grandfathered into) UK REACH.
Before transferring a registration to a GB entity you should consider how it would affect your operations in the EU/EEA and Northern Ireland and your ability to access those markets.
After the transition period ends
You may register the substance under UK REACH through a GB-based OR or an affiliate GB importer (which could then supply your GB customers). Your GB customers would then be downstream users if their proposed use is covered by that registration.
If your GB-based OR or affiliate registers the substance within the relevant deadline your existing GB customers may not have any UK REACH obligations beyond their duty to notify HSE of the import within 300 days of the end of the transition period. However, this notification of import could also be completed on their behalf. There is more information in GB-based downstream users or distributors of EU REACH registered chemicals.
Page last reviewed: 1 December 2020
Next review due: 31 December 2020