
With the UK leaving the EU US companies with UK clients and/or EU clients will need to review import tonnage and split between UK and EU27/EEA to check if substances need to be registered under UK REACH and/or EU REACH. Any substance imported into the territory above 1 tonne must be registered via an Only Representative (OR) established in that territory. CSI has offices located in Edinburgh, Scotland for UK REACH and Dublin, Ireland for EU REACH.
Comply with UK REACH
From the 1st January 2021, the UK government division - The Department for Environment, Food and Rural Affairs (DEFRA) will release its UK REACH submission platform called “Comply with UK REACH” (similar to ECHA’s REACH-IT tool) to allow companies to submit data of the chemicals manufactured and/or imported into the UK above 1 tonne per annum. To maintain access to the UK market, many companies including UK, EU and US companies will need to prepare for these changes.
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UK Company
with NO EU REACH registrations
UK Companies with NO EU REACH registrations but which have an existing EU supply chain will need to register for Downstream User Import Notification (DUIN) via the UK REACH submission platform. DUINs must be carried out by 28th October 2021. CSI can support you with notifications and/or correspond with EU suppliers as they’re able to submit DUINs via a UK based Only Representative (OR). Once the DUINs are submitted, full registrations will be required to be submitted to UK REACH submission platform by the corresponding deadline mentioned below.
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UK Company
with EU REACH registrations
UK companies with EU REACH registrations will need to transfer their registrations to an EU-27 based Only Representative (such as our Dublin, Ireland office) to maintain imports to EU27/EEA. UK companies will also need to set up these registrations under the new UK REACH submission platform by a process called “Grandfathering”. CSI can help submit the requested dossiers. Initial information must be submitted by 30th April 2021 and subsequently completed by the corresponding deadline mentioned below.
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EU Company
exporting to UK clients
EU companies exporting to UK clients may wish to register the substances under UK REACH on behalf of their customers which prevent potentially proprietary data from being passed on to clients. EU companies can carry out the registrations via UK based Only Representative (such as CSI). DUINs must be submitted on behalf of your UK clients by 28th October 2021 and then subsequently registered fully by the corresponding deadline mentioned below.
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US Company
with UK clients and/or EU clients
US companies with UK clients and/or EU clients will need to review import tonnage and split between UK and EU27/EEA to check if substances need to be registered under UK REACH and/or EU REACH. Any substance imported into the territory above 1 tonne must be registered via an Only Representative (OR) established in that territory. CSI has offices located in Edinburgh, Scotland for UK REACH and Dublin, Ireland for EU REACH.
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