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UK UK REACH buffer period is extended for 3 years, and export enterprises can give priority to completing DUIN notification


Time:

2022-12-16

On November 29, 2022, the UK officially released the results of the public consultation on "Extension of UK-RECH Buffer Period": with the consent of the Scottish and Welsh governments, the deadline for submission of UK-RECH registration was extended for 3 years.

On November 29, 2022, the UK officially released the results of the public consultation on "Extension of UK-REACH Buffer Period": according to the results of the public consultation, with the consent of the Scottish and Welsh governments, the UK Department of Environment, Food and Rural Affairs (Defra) will propose secondary legislation to extend the deadline for submission of UK-REACH registration for 3 years.

According to the different classification and tonnage of substances, the previous buffer periods ended on October 27, 2023, 2025 and 2027. After three years of extension, the new deadlines are October 27, 2026, 2028 and 2030.

Enterprises that have completed DUIN notification or "zero data" formal registration can normally trade chemicals within the buffer period, and only need to submit complete registration data before the new deadline.

 

Tips 

At present, the DUIN window is still open. Enterprises that meet the DUIN application conditions should submit the DUIN notification as soon as possible to obtain a buffer period up to 2030.

Enterprises that do not meet the conditions of DUIN can also enter the British chemical market with low compliance costs through the official registration of "zero data".

The official public consultation report of the United Kingdom shows that the official has received 289 valid replies to the questionnaire, of which 82% chose to extend the buffer period for three years.

Their general view is that this option will provide enterprises with more time to prepare registration materials, which can reduce the burden on enterprises and maximize the opportunities for enterprises to submit high-quality files, while avoiding the interruption of chemical supply in the UK market.

Respondents who supported this option ranged from SMEs to large enterprises, including sole representatives (OR), manufacturers, downstream users, and chemical importers and exporters.

 

It is worth noting that

The British government introduced the new Brexit Freedom Act in September. All the reserved EU laws (including UK-RECH) will be repealed on December 31, 2023. The British ministers have the right to amend, replace or repeal these regulations. This undoubtedly brings risks to the further development and transformation of UK-RECH.

 

 

UK REACH

The European Union REACH regulation was incorporated into English law on January 1, 2021. This regulation has now been implemented and is called UK REACH (UKREACH). This was triggered by the EU (Exit) Act 2018. The EU legislation has been copied in the UK and necessary modifications have been made to make it operational in the domestic environment. The key principles of the EU REACH regulation have been retained. UK REACH upholds the goals and principles of EU REACH.

UK REACH and EU REACH regulations operate independently of each other. Companies that supply and procure substances, mixtures or articles to the EU/EEA/Northern Ireland and the United Kingdom (England, Scotland and Wales) need to ensure that they comply with their obligations under both legislation.

According to the Northern Ireland Protocol, EU REACH regulations continue to apply to Northern Ireland, while UK REACH provides a regulatory framework for UK chemicals.

 

REACH applicable product range
The scope of REACH regulation is broad. It covers almost all non food, feed and drug commercial products.
Including chemicals, alloys, plastics, semi-finished products, accessories, toys, furniture, cosmetics, stationery, pigments, paints, glues and cleaners, textiles and clothing, footwear products, leather products and accessories, electronic and electrical products and other products and other household goods, leisure and sports supplies.
  
 

Differences between EU REACH and UK REACH
1. The UK REACH SVHC and Annex 17 are generally updated more slowly than the EU;
2. The UK SVHC has only been updated to the 23rd batch of EU, and the EU has been updated to the 27th batch;
3. The biggest difference between the UK Annex 17 and the EU is Article 68. The UK still retains the requirements of PFOA, while the EU has replaced PFOA with PFCA (C9-C14).

 

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