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What Stays the Same Between UK and EU REACH
The same following REACH principles apply to both markets:
- Maintaining the precautionary principle, for example when the authorities consider a new declarable substance of very high concern (SVHC);
- No data on chemicals means no access to the market;
- Workers using chemicals or articles containing any SVHC must be informed;
- When analyzing chemicals, animal testing should only be considered at the last resort.
What Changes with the UK REACH
In a nutshell, the EU and UK REACH registration and authorization systems are being managed separately. Then the UK and the EU are developing two distinct chemical databases.
As a result, importers will have specifically disclosed the chemicals in both the UK and the EU registration systems.
For example, if you import a specific SVHC in your articles, in quantities exceeding 1 ton per year in the UK and the EU, then you will have to register this SVHC in both databases. Nevertheless, this type of registration benefits from a grandfathering process of up to 6 years.
Useful Resources to Understand UK REACH
From the UK
On September 1st, 2020, the UK government has updated its UK REACH guidance on 'How to comply with REACH chemical regulations'. The UK government is also launching an online support service 'Comply with UK REACH', on January 1st, 2021.
From the European Union
The European Chemicals Agency (ECHA) has also been developing a useful online UK REACH support tool called 'How will the UK withdrawal affect you?'