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 produced or imported into Great Britain (England, Scotland, and Wales).
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 produced or imported into Great Britain (England, Scotland, and Wales).
REACH SVHC 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, mixtures, and articles. Businesses planning to manufacture, market, or import chemical products into Great Britain (GB) must adhere to the UK REACH regulation. Notably, the EU REACH regulation still applies to Northern Ireland.
Under UK REACH, substances of very high concern, commonly called SVHCs, may trigger specific communication, notification, and risk management obligations. These requirements can apply to substances on their own, substances in mixtures, and substances present in articles, depending on the use, concentration, quantity, and role of the company in the supply chain.
For companies placing products on the Great Britain market, UK REACH should be assessed separately from EU REACH. Since Brexit, the United Kingdom and the European Union have maintained separate chemical regulatory systems. As a result, companies may need to verify both UK REACH and EU REACH requirements when products are sold in both markets.
The same following REACH principles apply to both markets:
In a nutshell, the UK and EU REACH registration and authorization systems are being managed separately. Therefore, 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 instance, if you import a specific SVHC in your articles in quantities exceeding 1 ton per year in the UK and the EU, you must register this SVHC in both databases. Nevertheless, this type of registration benefits from a grandfathering process of up to 6 years.
Manufacturers and importers in Great Britain must complete the registration process. Like EU REACH, as a registrant under the UK version, you must gather information on the chemicals you manufacture or import into Great Britain in quantities exceeding one tonne per year. The following substances are subject to registration:
Like the SCIP database for EU REACH, producers and importers must register the substances through an IT system called Comply with UK REACH. Companies outside Great Britain should delegate the registration to a GB-based Only Representative (OR). Registration is per substance and per legal entity. Additionally, if there are multiple registrants for a substance, co-registrants should select a lead registrant to submit the information on their behalf.
The advantages of joint registration are:
On September 1st, 2020, the UK government updated its guidance on how to comply with REACH chemical regulations. The UK government is also launching the online support service Comply with UK REACH (explained above) on January 1st, 2021.
Moreover, the European Chemicals Agency (ECHA) has been developing the online UK REACH support tool “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.
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. However, the CE mark remains a valid equivalent of UKCA.
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.
Finally, for more detail concerning the UKCA marking, consult our article on the expectations for producers surrounding the new regulation.
UK REACH is the United Kingdom’s chemical regulatory framework that replaced EU REACH in Great Britain after Brexit. It applies to substances, mixtures, and articles manufactured, imported, or placed on the market in Great Britain, which includes England, Scotland, and Wales. Northern Ireland remains subject to different rules because EU REACH continues to apply there in many situations.
Yes. UK REACH can apply to electronic products when they contain substances regulated under UK REACH, including substances of very high concern. Electronic products may contain regulated substances in plastics, coatings, adhesives, cables, solders, batteries, flame retardants, or other components.
Companies selling electronic products in Great Britain should assess whether UK REACH obligations apply to their articles, especially when SVHCs are present above applicable thresholds.
SVHCs, or substances of very high concern, are chemicals identified because of serious potential impacts on human health or the environment. These may include substances that are carcinogenic, mutagenic, toxic to reproduction, persistent, bioaccumulative, toxic, or of equivalent concern.
Under UK REACH, SVHCs may create communication, documentation, and notification obligations for suppliers, importers, and manufacturers.
No. UK REACH and EU REACH are similar, but they are now separate regulatory systems. Since Brexit, Great Britain manages its own UK REACH system, while the European Union continues to manage EU REACH. This means that companies selling in both markets may need to assess and document compliance under both regimes.
In many cases, yes. EU REACH continues to be relevant in Northern Ireland, while UK REACH applies to Great Britain, meaning England, Scotland, and Wales. Companies selling products across the UK and EU should carefully verify which REACH regime applies to each market.
UK REACH compliance documentation may include supplier declarations, Safety Data Sheets, full material declarations, substance test reports, SVHC assessments, article composition data, and regulatory applicability analyses. The exact documentation depends on the product type, materials, supply chain, and substances present.
Enviropass can help companies assess UK REACH requirements, review supplier documentation, identify potential SVHC risks, prepare compliance evidence, and compare UK REACH obligations with EU REACH requirements. Enviropass can also support broader product environmental compliance programs for companies selling in Great Britain, Northern Ireland, the European Union, and other global markets.
Contact Enviropass if you need to know more about REACH and how to comply with it.
