Non-EU/EEA/NI-based exporters to Great Britain under UK REACH
This guidance is for businesses that are based outside of the EU/EEA/Northern Ireland and want to export chemical substances to Great Britain (England, Scotland and Wales) after the end of the transition period.
Substances exported to Great Britain from countries outside of the EU/EEA must be registered under UK REACH.
UK REACH registration can be done either by you as the exporter via a GB-based affiliate or Only Representative (OR), or by the importer.
There are separate arrangements for Northern Ireland. Substances exported to Northern Ireland after the transition period ends must comply with EU REACH.
If you currently access the GB market via an OR or importer based in Great Britain
Your OR or importer’s registration(s) will be transferred into UK REACH at the end of the transition period (this is called ‘grandfathering’). Details of this process is available in the separate guidance for GB-based EU REACH registrants who want to maintain access to the market in Great Britain after the end of the transition period.
If you currently access the GB market via an OR or importer based in an EU/EEA country or Northern Ireland
To continue to supply a business based in Great Britain a UK REACH registration will be required.
Before the transition period ends
ORs based in the EU/EEA or Northern Ireland can transfer their EU REACH registrations to a GB-based OR.
Registrations held by GB-based entities prior to the end of the transition period will be grandfathered into UK REACH. Before transferring a registration to a Great Britain-based entity you should consider how this would affect your operations in the EU/EEA and Northern Ireland, and your ability to access the EU/EEA and Northern Ireland 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 or be the GB customer themselves). If the registration is carried out by an OR or affiliate, your GB customer would then be a downstream user if their proposed use is covered by that registration.
If you are a GB-based entity your existing GB customers may simply have to notify HSE of the import within 300 days of the end of the transition period.
Registrations made by GB entities after 31 December 2020 will be classed as a new substance registration (full registration duties would apply including the submission of a full data package and the payment of the relevant fee).
Your existing GB-based customers may be able to take advantage of the transitional ‘notification’ provision described in GB-based downstream users or distributors of EU REACH registered chemicals.
Page last reviewed: 1 December 2020
Next review due: 31 December 2020