UK REACH
UK REACH: Chemical Regulation in the United Kingdom Post-Brexit
Scope and Purpose of UK REACH
Difference from EU REACH and the Role of the Health and Safety Executive (HSE)
UK REACH is the national chemicals regulation of the United Kingdom following Brexit and pursues the same objective as the EU regulation: “Registration, Evaluation, Authorization and Restriction of Chemicals.” While the ECHA is responsible in the EU, the HSE assumes this central role for occupational and health safety in the UK system. The government issues binding requirements and regulations through official governmental bodies.
Scope of Application for Substances, Mixtures, and Chemicals in the United Kingdom
The regulations apply to substances, mixtures, and chemicals that are manufactured, imported, or placed on the market in the United Kingdom. Companies supplying products in the UK are affected. Deliveries from the EU are also subject to UK REACH.
Registration under UK REACH
Registrations, Data Access, and Storage – Deadlines & Validity
Registration is a prerequisite for market access in the United Kingdom. Companies must ensure access to relevant substance data and maintain compliant storage. Meeting deadlines determines the validity of the registration.
DUIN (Downstream User Import Notification): Post-Brexit Notification for Companies
The DUIN is a simplified notification for companies importing substances from the EU into the United Kingdom after Brexit. It allows existing supply relationships to continue temporarily. In the long term, it does not replace full registration.
Only Representative: Responsibilities, Consent, and Notification
Nicht-britische Hersteller können einen Alleinvertreter benennen, der Pflichten unter UK REACH übernimmt. Voraussetzung sind eine formale Zustimmung sowie eine ordnungsgemäße Meldung bei der HSE. Der Alleinvertreter fungiert als Ansprechpartner für die Behörden.
Roles & Responsibilities in the Supply Chain
Manufacturers, Importers, Suppliers – Compliance Requirements
Manufacturers, importers, and suppliers are responsible for ensuring compliance with the regulations. They must verify whether substances or mixtures are subject to registration or notification obligations and, in accordance with UK requirements, carry out registrations and pass on information. A clear understanding of one’s role in the supply chain and adherence to the corresponding obligations is essential for legally secure supply relationships.
Nachgeschaltete Anwender und Lieferbeziehungen zwischen EU und UK
Downstream users on both sides of the Channel must verify whether the intended uses of their products are covered by the data of the respective registrations. Since Brexit, supply relationships between the EU and the UK have structurally changed, creating new notification and verification obligations. In many cases, chemical analysis is required to fulfill these obligations.
Authorities & Institutions
HSE (Health and Safety Executive) vs. ECHA/BAuA – Responsibilities
The HSE is the competent chemicals agency in the UK system. In the EU, responsibilities remain with the ECHA, while in Germany authorities such as the BAuA, regional government offices, or customs oversee and enforce REACH (EU). Between the EU and the UK, however, responsibilities and data access have been strictly separated since Brexit.
UK Government: Guidance, Regulations, and Updates
The United Kingdom government provides guidance and updates through official gov portals. These serve as a binding basis for companies to implement the applicable regulations. Updates are published regularly.
Post-Brexit Transitions
Inventory data, data reuse, access, and consent of the right holders
The reuse of existing REACH data is only possible with regulated access. The consent of the respective right holders is required. Without this consent, a new registration is necessary. It must be assessed whether data gaps exist. In individual cases, economic operators require additional data and, if necessary, chemical analysis.
Effects on UK and EU Businesses
New responsibilities arise for companies in the UK and the EU. Importers and actors with cross-border supply chains are particularly affected. A reassessment of their roles is often required.
Compliance & Documentation
Registration dossiers, device information, and evidence for inspections
Registration documents must be complete and traceable. This includes substance data, device information, and analytical procedures that enable the verification of registered substances and mixtures according to the current state of the art. These must be submitted to the competent authorities upon request or are an essential component of the registration dossiers.
Storage of data for market surveillance purposes and validity
The storage of relevant data serves the purposes of market surveillance and legal certainty. It supports the verification of the ongoing validity of registrations. Proper documentation reduces risks during inspections.
Testing and Verification Reference (our services for affected companies)
Target analyses and substance screenings of chemical products and articles for compliance with UK REACH
As an analytical testing company, we support the assessment of substances within the framework of UK REACH. Our analytics serve to professionally safeguard registrations and notifications. Testing is conducted in a targeted manner and in compliance with regulations.
Design and implementation of analytical procedures for dossier preparation
We support companies in developing valid analytical strategies, which are a prerequisite for REACH registration as part of the registration dossiers. We also conduct control measurements and spot checks on behalf of clients to assist suppliers in fulfilling their due diligence obligations.
Documentation checks, supply chain compliance, and support for DUIN/registration
We review documentation, assist companies with DUIN, notification, and registration, and support the evaluation of suppliers. The goal is a traceable and compliant implementation throughout the entire supply chain.
