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Due to Brexit, the United Kingdom (UK) has enacted several regulations deviating from the European Union. One example is the replacement of EU REACH with UK REACH for products entering the UK.

What is UK REACH ?

What is UK REACH?

REACH SVHC regulates chemicals and applies to most substances, mixtures, and articles (products). There are now two versions of the REACH regulation in the EU and the UK.

As of January 1st, 2021, REACH in the United Kingdom essentially applies to manufacturers and importers of substances and mixtures, and articles.

What Stays the Same Between EU and UK REACH?

The same following REACH principles apply to both markets:

  • Maintaining the precautionary principle, for example when the authorities consider a new declarable substance of very high concern (SVHC);
  • No data on chemicals means no access to the market;
  • Workers using chemicals or articles containing any SVHC must be informed;
  • When analyzing chemicals, animal testing should only be considered as the last resort.

What Changes Between the Two Jurisdictions?

REACh database Registration

In a nutshell, the UK and EU REACH registration and authorization systems are being managed separately. Then the UK and the EU are developing two distinct chemical databases.

As a result, importers will have to specifically disclose the chemicals in both the UK and the EU registration systems

For example, if you import a specific SVHC in your articles, in quantities exceeding 1 ton per year in the UK and the EU, then you will have to register this SVHC in both databases. Nevertheless, this type of registration benefits from a grandfathering process of up to 6 years.

Useful Resources to Understand UK REACH

From the UK

UK REACH Resources

On September 1st, 2020, the UK government updated its UK REACH guidance on How to comply with REACH chemical regulations. The UK government is also launching the online support service Comply with UK REACH, on January 1st, 2021. 

From the European Union

UK REACH european resources

The European Chemicals Agency (ECHA) has also been developing the online UK REACH support tool called ‘How will the UK withdrawal affect you?

First, the tool asks you to select the option that best describes your connection to the EU market and your role in the supply chain. Upon selection, the site leads you to an article that explains how Brexit affects you and the regulations you must follow.

Other Brexit Changes

Another change in environmental compliance since the UK split from the European Union is the replacement of the CE marking with the UKCA mark for articles in the UK. The new label came into effect on January 1st, 2021.

The marking includes EU RoHS and ecodesign requirements for electrical and electronic equipment.

As with REACH, the rules between the UK and EU versions are almost the same, but manufacturers must add both logos to their products if introducing products to both markets.

The UKCA label

Finally, for more detail concerning the UKCA marking, consult our article on the expectations for producers surrounding the new regulation.

Stay with Enviropass, since the UK REACH will likely change within the coming months and years.