The UK leaves the EU on the 1st January 2021 and at this point it is anticipated that the UK REACH submission portal will go live. This portal is called "Comply with UK REACH" (CWUR).
It's not totally clear what every aspect of UK REACH will look like, and that's giving industry somewhat of a headache, but we do know the first two key aspects.
IF YOU HAVE AN EU REGISTRATION
If you already have a UK Legal Entity EU REACH registration, which you may have transferred to an EU Legal Entity from a UK Legal Entity, then you need to submit some basic information into CWUR by 30 April 2021 to ensure your EU registration will be honoured by the UK. This honouring is called "Grandfathering". It would do no harm at all to download your current EU REACH data to make sure it is still accessible after 1 January 2021, particularly if this data is still held under a UK legal entity.
IF YOU USE CHEMICALS YOU KNOW HAVE NOT ORIGINATED FROM THE UK
You should complete a Downstream User Import Notification (DUIN) for any substance which you use if you are at all unsure about the UK REACH Status. It's a good idea to do this to be kept abreast of future registration activities. DUIN's need to be submitted by 27 October 2021. In theory, at least, you should be able to confirm whether a substance has been Grandfathered by 30 April 2021, so you have six months to complete your DUIN's after this date but in reality, getting this information from suppliers might not be so easy so you may choose to submit DUIN's in any event.
WHAT ABOUT NORTHERN IRELAND?
The Northern Ireland Protocol and how this will be applied to UK REACH has not yet been fully published. If your intention is to supply to Northern Ireland, or route shipments through Northern Ireland, it may be prudent to maintain an EU REACH registration alongside a UK REACH registration, at least until more information is released.
WHAT THEN?
Following these preliminary stages, the first UK REACH registration deadline will be in 2023 and will apply to the highest tonnage band and highest risk (health and environment) substances. So if you have substances over 1000 tonnes per annum (manufacture or import), have CMR's, aquatic toxicity or have substances on the EU candidate list, expect to begin registration activities all over again in the very near future.
