Introduction to UK REACH presented at the International Aerospace and Environmental Group (IAEG), Working Group 1, Spring Virtual meeting, held on Wednesday 6th April 2022

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Introduction to UK REACH
Emerging Differences with EU REACH
Presented at: IAEG Spring Conference 2022,
WG1
Presented by: Raj Takhar, Assent

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Today’s presenter
Raj Takhar
Senior Subject Matter Expert on
Materials Reporting (Europe)
Assent
● Supported IAEG WG1 in the development of
IPC-1754 (Rolls-Royce).
● Phd ‘The impact of chemical regulations on the AD
sector’.
● IET - Technical Advisory Panel Aerospace.
● Standards Development Committees: IPC, BSi,
ASD, ISO/IEC.
○ Represent IET in BSi aerospace committees.
○ Represent BSi in ISO/IEC aerospace
committees.
● Stakeholder Groups: SCIP IT User Group, UK
REACH IT Stakeholders group.
● 2021 UK Parliamentary Office of Science and
Technology study on regulating product
sustainability.
● Email: Raj.Takhar@Assent.com
● LinkedIN

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Agenda
1. UK REACH vs EU REACH.
▸ Candidate List
▸ Authorisation List
▸ Restricted List
▸ Summary of Obligations
▸ Divergences known (today)
2. Q&A.

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UK REACH vs
EU REACH
Similar in nature … but divergence
is emerging.

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UK REACH
Independent chemicals regulatory framework
● Applicable since 1st January 2021.
● UK has put in place its own
independent chemicals regulatory
framework.
● UK Defra has overall policy oversight.
● UK HSE is UK Agency for UK REACH.
○ Mirrors EU REACH as far as
possible.
○ Minimises disruption to supply
chains for chemicals though our
transitional measures.
● Both UK and EU operate REACH
independently of each other.
● UK REACH obligations cover GB
(England, Scotland and Wales).
● Northern Ireland Protocol requires
companies to comply with EU REACH,
but no SCIP obligations.
● Businesses will need to take steps to
ensure regulatory requirements are
fulfilled in both the UK and EU in
order to maintain continuity of supply
chains.
● UK government position paper on UK
REACH 2021.

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UK REACH vs EU REACH
Access to systems.
● IUCLID based.
● Comply with UK REACH
○ Create Defra gov.uk account.
○ Only legal entities which are UK
based can register and transmit
data.
○ Third Party Representative
(TPR).
● IUCLID based.
● EU REACH-IT
○ Create EU REACH-IT account.
○ Multiple subsystems report data
differently for REACH, CLP, BPR
and SCIP.
○ Non-EU locations can register
themselves as actors.
○ Only EU based legal entities / Only
Representative (OR) can transmit
data.

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UK REACH vs EU REACH
Candidate List of Substances of Very High Concern
● Not Yet Updated!
● Aligns to 16th July 2019 version of EU
REACH Candidate List. 201 entries
(373 substances) - available as xlsx
file.
● Additional 10 substances on
HSE/DEFRA roadmap - all except for
Resorcinol; 1,3-benzenediol [CAS:
108-46-3].
● Article 7(2) transposed (>1 tn use).
● Article 33 (currently under review).
● Updates twice a year.
● January 2022, 223 entries (444
substances).
● Resorcinol; 1,3-benzenediol [CAS:
108-46-3]. is on the Registry of
Intentions to be included on to the
REACH Candidate List.
● EU WFD 2018/851 introduced
additional SVHC reporting obligations
for articles with SVHCs onto the
ECHA SCIP Database.

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UK REACH vs EU REACH
Annex XIV: Authorisation List of Substances
● 54 Entries (98 Substances)
● UK list has for some substances a longer
sunset date.
● Data must be registered and recorded
into the Comply with UK REACH
system by a UK legal entity or UK based
Authorised Representative (data silo
from EU REACH-IT).
● List of Substances proposed for inclusion
UK Annex XIV (DCHP + Disodium
octaborate)
● List of UK Authorisations being
processed and grandfathered
● 54 Entries (120 substances).
● EU REACH-IT, registrations via EU-27
legal entities or an EU-27 located
Authorised Representative.
● Current Consultations (ending May
2022) include the addition of Lead (Pb)
onto the Authorisation list + 7 other
substances.

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UK REACH vs EU REACH
Annex XVII: Restricted List of Substances
● 74 Entries (1082 substances displayed in
appendix tables).
● Registry of intentions - 2 substances
Lead (Pb) and Substances in Tattoos
(already restricted under EU REACH.
● Evolving process (RMOA)
● 76 Entries (>2100 substances)
● Established process
● Includes updates via REACH
consultations & updates via EU CLP
Delegated Acts.

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UK REACH vs EU REACH
Summary of Obligations
● Candidate List:
○ Article 7(2) reporting.
○ Article 33 (being developed)
○ Contains all substances on EU
REACH Candidate List (except for
Resorcinol which has not yet
been added).
● Authorisation List:
○ Apply for authorisation where
identified.
● Restricted List:
○ Identify use and understand terms
of restriction.
● Candidate List:
○ Article 7(2) reporting.
○ Article 33 reporting.
○ EU WfD SCIP Database reporting.
● Authorisation List:
○ Apply for authorisation where
identified.
● Restricted List:
○ Identify use and understand terms
of restriction.

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UK REACH vs EU REACH
Future Misalignment Ahead!!
● Evolving process.
● Regulatory Management Options
Analysis (RMOA announced similar to
EU REACH announced.
● Following Brexit, Comply with UK
REACH system has similarities with the
EU system, but will be UK specific.
● Register on UK HSE Bulletin site.
● EU Green Deal established EU Chemical
Sustainability Strategy (EU CSS)
● EU CSS proposed overhaul of EU REACH, which
is expected to be released as a public draft in
Q4, 2022:
○ Wider scope of criteria for SVHCs.
○ PFAS restriction proposal (No Essential
Use)
○ New criteria likely to indirectly impact AD
sector.
■ EU General Risk Assessment (GRA)
■ EU Criteria for Essential Use
[Delayed]
○ EU Safe and Sustainable by Design (SSbD)
○ EU Criteria for Safe Use (2023).
○ New EU Chemical Audit Agency.
○ Professional uses.
○ ‘one substance, one assessment’
○ More SCIP Data fields!!
UK government policy is looking at
reforming sectors and reducing burden of
reporting. EU More Reporting More Circularity

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Q&A

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Useful Links
▸ UK HSE - Notifying substances in articles.
▸ EU worker safety regulation update.
▸ EU REACH clarification consultation on Chemical Safety Regulation.

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