The Retailer Spring Edition 2021

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Any new chemicals that require notifying after this time will be required to use the new UK portal”. ‘‘

UK REACH If you import a substance, either on its own or in a mixture, above 1 tonne per annum, and place it on the GB market, you must hold a UK REACH registration for that substance. If youwere originally a downstream user of a substance registered under EU REACH, but have become the GB importer, you will be required to take on the role of registration holder in GB, unless your supplier uses a GB-only representative to undertake UK REACH registration requirements on your behalf. To undertake the responsibility yourself you will need to perform a DUIN (Downstream user information notification) within 300 days of 1st January 2021. Once this has been completed you will have 2, 4 or 6 years depending on the substance to complete the registration. Regarding GB safety data sheets, the format implemented is that outlined in the EU 2015/830 REACH Annex II regulation, and not the recently updated EU 878/2020 regulation. There is a requirement for a GB entity to be listed as the supplier on the document. Products moving between NI/EU and GB If you have now become either a NI or EU importer, you will need to abide by all EU requirements from the 1st January 2021 as no transition period has been implemented. If you are importing into the EU there is a registration exemption if it can be proven that the substances involved are chemically unchanged and part of a registered supply chain. In this case they do not need to be re-registered upon re-importation back into the EU market. If you export from NI to GB, your products can have unfettered access to the GB market if they meet the definition of Qualifying Northern Ireland Goods (QNIGs). Whilst any product entering the GB market will still have to be labelled, classified and notified in accordancewith GB CLP, the supplier details can be those of the NI supplier. QNIGs can also be imported into Great Britain without needing a UK REACH registration, as you can use the more simplified Northern Ireland Notification process which has to have been completed within 300 days from 1st January 2021 for substances already being placed on the UK market via this route, or before importation occurs for new substances.

Eleanor Grimes ul.com Eleanor.Grimes@ul.com