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.

Our UK REACH web pages are updated as new information is released. If you have specific questions on your particular obligations under UK REACH or EU REACH, please contact us.

Links to HSE guidance:

GB-based EU REACH registration holders – Scenario 1

GB-based downstream users or distributors of EU REACH registered chemicals sourced from the EU/EEA or non-qualifying NI good from Northern Ireland who wish to maintain GB market access – Scenario 2

GB-based importers, distributors or formulators of substances sourced from outside the EU/EEA who want to access the EU/EEA market – Scenario 3

GB-based EU REACH authorisation holders – Scenario 4

GB downstream users of EU REACH authorisation held by an EU/EEA or NI-based business – Scenario 5

Exemptions for the purposes of product and process orientated research and development (PPORD) – Scenario 6

Awaiting an EU REACH authorisation or registration decision when the transition period ends – Scenario 7

EU/EEA-based suppliers to Great Britain under UK REACH – Scenario 8

Non-EU/EEA/NI-based exporters to Great Britain under UK REACH – Scenario 9

GB importers or downstream users of qualifying Northern Ireland goods registered under EU REACH by a business in Northern Ireland; Scenario 10 – Scenario 10

Northern Ireland businesses trading Qualifying Northern Ireland Goods (QNIG)– Scenario 11

Further information:

The REACH etc. (Amendment etc.) (EU Exit) Regulations 2020

The Definition of Qualifying Northern Ireland Goods (EU Exit) Regulations 2020