The UK-Reach has maintained the same general principles as the European Reach, in particular:
– the concept of “no data – no market”;
– the preference for alternative tests compared to in vivo ones;
– access to information to workers;
– the precautionary principle.
UK COMPANIES WITH EU-REACH REGISTRATION
Registrations made under the European Reach will automatically be transferred to the new UK-Reach through a process called “grandfathering”.
The “grandfathering” process includes two different steps:
• By April 30, 2021 UK companies with a REACH registration will need to provide information to the HSE (Health And Safety Executive), the UK Competent Authority: substance identity, company data, registered quantity and evidence of the EU registration.
• Within a deadline defined by the tonnage band they will have to provide specific information from the registration dossier.
| Scadenze dopo il 28 Ottobre 2021 | Tonnellaggio | Proprietà Pericolose |
|---|---|---|
| 27 Ottobre 2023 | > 1000 tonnellate l'anno | - Cancerogeno, mutageno o tossico per la riproduzione (CMR) > 1 tonnellata l'anno - Altamente tossico per gli organismi acquatici (acuto o cronico) > 100 tonnellate l'anno - Sostanze della Candidate List (al 31 Dicembre 2023) |
| 27 Ottobre 2025 | > 100 tonnellate l'anno | - Sostanze della Candidate List (al 27 Ottobre 2023) |
| 27 Ottobre 2027 | > 1 tonnellate l'anno |
UK COMPANIES BUYING FROM EU SUPPLIERS
From 1 January 2021, UK companies that purchase from EU suppliers must be configured as importers under the UK-Reach and as such they will have to register.
• By October 27, 2021 the UK importer will have to notify the HSE of his willingness to continue with the imports, and the notification is called DUIN (Downstream User Import Notification). Such a notification can only be sent if the substance has already been registered under the EU-Reach.
• The registration dossier must be submitted within a deadline defined by the tonnage band (the same previously reported).
Alternatively such companies may encourage EU suppliers to appoint a UK-OR (Exclusive Representative) appointed under the UK Reach.