REACH REGISTRATION FOR IRON AND IRON SUBSTANCES

Iron Platform and UK REACH

May 20th 2021

The REACH Iron Platform, the REACH consortium for Iron and related substances,  has decided to play a role in the new UK REACH regulatory regime through its legal entity, Iron Platform Services Ltd. This will give a degree of control over the process with respect to iron, etc. and assist stakeholders with access to data as well as transfer of information for UK REACH registrations.  It should also guarantee efficiency, a smooth implementation, and high quality registration dossiers fully consistent with the EU REACH registrations.

The BREXIT transition period ended on 31 December 2020, and the UK and EU relationship is now governed by the newly concluded Free Trade Agreement (“FTA”). Following the end of the transition period, Great Britain (being England, Wales and Scotland) has a new regulatory system for chemicals, so-called UK REACH, which replaces the EU REACH regime in Great Britain. Northern Ireland will instead remain within the scope of EU REACH. UK REACH came into force on 1 January 2021.

UK REACH provides for functions formerly carried out by EU institutions to be carried out by domestic bodies.  The UK government pages giving advice on how to comply with UK REACH are available here, and the UK HSE pages are here. “Comply with UK REACH” is the new name for the UK REACH IT system.

UK REACH is very similar to EU REACH – it operates several principles which are the same, for example “no data, no market”, animal testing as a last resort, and the precautionary principle. Data requirements are the same as EU REACH, as is the “joint submission” approach to registration (“one substance one registration”).

UK-based entities already active in the UK market can maintain access in one of two ways: i) “grandfathering” of a previous EU REACH registration if held (for which the deadline has already passed); or ii) submission of a Downstream User Import Notification (DUIN) for those who were downstream users of a previous EU REACH registration. UK entities who are interested in registration but do not qualify for either grandfathering or submission a DUIN can still indicate an interest by submission of an Article 26 enquiry to UK HSE. Such entities would be considered as “new registrants”.

We will be pleased to answer any queries that actual or potential registrant for Iron Platform substances may have:  email iron.consortium@gmail.com

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