October 27, 2020
The Health and Safety Executive (HSE) has published 11 webpages with detailed guidance to comply with UK REACH. More information has been provided on some key issues below.
Data requirements: All the dossier sections required under EU REACH (Article 10) will be required under UK REACH. Information on the substance identity, manufacture and use, evidence of EU REACH registration and notifications of any ECHA decision related to the substance registration will need to be submitted within 120 days of the end of the transition period to “grandfather” a substance. The remaining data requirements (e.g. classification and labelling, guidance on safe use, study summaries, testing proposals, confidentiality requests, chemical safety report) will then need to be submitted in a phased manner, depending on the substance tonnage band and hazards. There is no mention of changes to the required endpoints in the HSE guidance.
Data access and substance information exchange fora (SIEFs): Companies registering under UK REACH will not be required to form SIEFs to submit substance registrations, however the principle of “One Substance, One Registration” will still apply. The HSE suggests that SIEF members negotiate collectively to obtain data access from data owners for UK REACH submissions.
Northern Ireland (NI): A notification system (“Northern Ireland Notifications”) will be established for the import of “qualifying Northern Ireland goods” (QNIGs) to Great Britain (GB, covering England, Scotland and Wales). QNIGs must have a relevant connection to Northern Ireland (e.g. substances, mixtures or articles that have been manufactured, formulated or produced in Northern Ireland) and the notification system can only be used by companies with an existing NI-based EU REACH registration. The notification can be submitted by either the GB importer or NI supplier, for substances imported into GB at ≥1 tonne per annum. There are no fees for the submission of a NI notification.
Links to HSE guidance:
GB-based EU REACH registration holders – Scenario 1
GB-based EU REACH authorisation holders – Scenario 4