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On June 28, 2023, the REACH (Amendment) Regulations 2023 (hereinafter referred to as the Amendment) was made public, adopting the three-year extension of submission deadlines for full registration data under UK REACH. New deadlines will be in force on July 19, 2023.
In order to explore and develop an alternative model for transitional registrations, the Department of Environment, Food and Rural Affairs (Defra) performed a consultation in late 2022 on extending submission deadlines by three years under UK REACH. A corresponding draft instrument was sent before Parliament in April 2023. Recently, the UK Defra released the Amendment and announced the extension of submission deadlines.
The table below shows the updated dossier submission deadlines (marked in red) for dossier submission for different tonnage bands and hazardous properties.
Deadline for dossier submission | Tonnage | Hazardous property |
27 October 2023 27 October 2026 | ≥ 1000 t/y |
|
27 October 2025 27 October 2028 | ≥ 100 t/y |
|
27 October 2027 27 October 2030 | ≥ 1 t/y | / |
As per the Amendment, the statutory dates for the Health and Safety Executive (HSE) to carry out the compliance checking on certain types of registration dossiers under UK REACH are extended accordingly.
" The registration dossiers selected by the Agency for compliance checking must include:
until 27 October 2027, not less than 20% of the registration dossiers received by the Agency for substances referred to in Article 127P(4B)(a);
until 27 October 2030, not less than 20% of the registration dossiers received by the Agency for substances referred to in Article 127P(4B)(b);
until 27 October 2035, not less than 20% of the registration dossiers received by the Agency for substances referred to in Article 127P(4B)(c). "
The Amendment is available here.
Alternative Transitional Registration Model
Compared to the EU REACH regulation that applies to all EU member states, UK REACH only applies to England, Scotland, and Wales, with a significantly smaller market for chemical products under its management. However, considering the close chemical trade relationship between the UK and the EU, many chemical companies in the UK and oversea companies with business in both the EU and the UK need to comply with both EU REACH and UK REACH regulations. If UK REACH were to completely replicate the EU REACH regulation, some companies may face double compliance costs, which is not conducive to the development of small and medium-sized enterprises in the UK. To address the significant potential cost of obtaining or accessing the full hazard information required to meet UK REACH registration requirements, in late 2022, the UK Defra proposed the work to explore an alternative transitional registration model for UK REACH. The work is ongoing. The UK Defra is currently engaging with stakeholders, including NGOs, to develop an alternative transitional registration model for UK REACH that will help reduce the costs associated with obtaining hazard information, including from expensive EU REACH data packages, while still ensuring that industry remains responsible for the safe use of chemicals throughout the supply chain. |
