After the end of the transitional period which ended on 31 December 2020, the United Kingdom had to prepare its own legislation on the placing on the British market of chemicals, the so-called UK-REACH.
The new legislation entered into force on 01 January 2021, and in fact represents a transposition of the EUROPEAN REACH as well as some changes necessary to make it applicable in British territory. The transposition also concerned the Annexes and the Candidate List, which were then reported in the UK system.
The various lists provided for by UK REACH are available at the following links:
LIST OF SUBSTANCES IN AUTHORIZATION
LIST OF SUBSTANCES IN RESTRICTION
SVHC OF CANDIDATE LIST
As is known, in the EU the lists reported in Annex XIV (Authorizations), Annex XVII (Restrictions) and the Candidate List are dynamic and are continuously updated on the basis of new information available or on the basis of proposals received from the Member States or the various stakeholders. This will also be the case in the United Kingdom, but the actors will be different from the current European reality. It is therefore inevitable that after the zero point made on 01 January 2021, in which the two regulations were almost identical, misalignments will be observed over time.
A very limited number of restrictions are currently being evaluated in the UK, for example those for which ECHA has already issued an opinion have been excluded, such as for microplastics or irritants, sensitizers and corrosives in fabrics.
We are therefore faced with a first divergence between the two regulatory regimes, a divergence that will probably be destined to widen over time if a collaboration agreement between the UK and the EU is not reached in this area.
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