The UK has left the European Union, and the transition period ended on 31st December 2020. UK REACH is now in force, and this affects both UK-based companies and companies with customers in the UK, who may wish to assign an Only Representative to fulfil UK REACH obligations.
In the short-term, action needs to be taken to notify substances under UK REACH, for example by grandfathering substances with existing EU REACH registrations or submitting Downstream User Import Notifications (DUIN) for those companies that were previously considered as downstream users under EU REACH. These measures allow companies to benefit from extended timelines for submitting full dossiers (either 2, 4 or 6 years from 28th October 2021).
Full registrations under UK REACH, whether benefiting from the extended registration timelines or submitted as new registrations straight away, will initially require similar information to that required under EU REACH, and registration dossiers will be submitted in IUCLID format. At wca, we have many years of experience with EU REACH and therefore understand the information required and how to prepare different types of IUCLID dossiers. As data already exists for these notified substances under EU REACH, negotiating access to existing data and data sharing between registrants will be important for UK REACH registrations. wca have negotiated data access on behalf of single and groups of companies and our consortia management work has provided us with knowledge and experience of data sharing between different types of companies, which will also be valuable for UK REACH.
wca can support you with:
- Providing UK Only Representative services for non-UK companies.
- Clarifying your regulatory obligations under both UK and EU REACH.
- Grandfathering substances, where existing EU REACH registrations are available, into UK REACH.
- Submitting new registration dossiers under UK REACH.
- Submitting Downstream User Import Notifications under UK REACH.
- Conducting data access and cost sharing negotiations.
- Preparation of dossiers in IUCLID format.
Where new data, exposure or risk assessments are required under UK REACH we can also help with developing testing strategies, derivation of no effect levels and occupational and environmental exposure modelling.
Initially, UK REACH requirements will be similar to those for EU REACH, and the amount of potential divergence from EU REACH will not become clear for some time. wca keep up to date with regulatory changes and can advise you as an when further action is needed.
If you would like support in any of these areas, or have other questions relating to the implications from the UK leaving the European Union, please contact us.