UK REACH for Importers and Manufacturers: An Essential Guide

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UK REACH Guide

Do you intend to manufacture or sell products in the UK? If so, REACH compliance is likely required. In practice, REACH requires that your products don’t contain restricted chemicals, heavy metals, and other substances above the set limits. Examples include lead, cadmium, and various phthalates.

In this guide, we list some product categories covered by the UK REACH regulation in the United Kingdom and provide information on the differences between the pre-Brexit and post-Brexit REACH limits.

Note that this article does not apply to Northern Ireland as Northern Ireland still follows EU REACH.

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What is UK REACH?

The UK REACH regulations regulate chemicals and heavy metals, in both their raw material and finished product form, found in most consumer products manufactured or sold in the UK. UK REACH also promotes alternate methods of assessment of possibly hazardous substances. The regulation affect importers, manufacturers, and distributors of consumer products.

The European Union (Withdrawal) Act 2018 allows EU-derived domestic legislation to continue to function as intended but as UK law. In the UK, the competent authority in this matter is the UK’s national regulator, the Health and Safety Executive (HSE).

Product scope

The UK REACH regulations cover most chemical substances and heavy metals in their standalone form, in mixtures, and in their form as an article (i.e. consumer products).

Examples of such consumer products include:

Does UK REACH differ from EU REACH?

As previously mentioned, the UK REACH regulations replicate the EU REACH regulations, and that includes adopting its key principles (e.g. the “one substance, one registration” principle remains the same).

For instance, the UK’s REACH enforcement Regulations (2008) (as amended) is derived from the EU’s REACH regulation. Although subject to future amendments, it still refers to the latter’s content.

Thus, the UK has its own UK REACH regulations that are similar to its EU counterpart, and importers and manufacturers looking to engage in both markets ought to comply with both systems of regulations.

However, one ought to be vigilant in these matters as it is likely that the UK’s current REACH system will go through more legislative updates that may or might not differ from its EU counterpart.

Substance restrictions

The UK has a list of restricted substances that is similar to its EU counterpart, however, differences may exist. Thus, importers and manufacturers should look out for any updates on the list published on the HSE’s site.

Substances registration

Similar to the pre-Brexit context, importers and manufacturers of covered substances at one tonne or above per year must register their substances. Note that substances in their standalone form, in mixtures, and (in some cases) in a finished product should be registered.

Registrants are legally obligated to:

a. Collect information on the properties and use of their manufactured or imported substances that reaches one tonne a year, and

b. Assess the risks posed by the substance and its associated use

From 2021 onwards, said substances should be registered through the “Comply with UK REACH” service.

It should be noted that the UK REACH recognizes the EU REACH registrations. Thus, importers and manufacturers can refer to these grandfathered registrations to comply with the UK REACH requirements.

Additionally, EU REACH registrants that intend to manufacture or import their substances into the UK market for the first time have to submit a registration.

UK REACH substances restrictions

As previously mentioned, the UK REACH has its own database of restricted substances. Although largely identical, differences may exist and future updates can be expected. Thus, importers and manufacturers ought to be on the lookout for updates to the list.

Below is a table containing some of the listed substances by name and their UK and EU limits. This list is non-exhaustive.

Substance name UK substance limits (Source) EU substance limits (the source is different for each substance)
DEHP, DBP, BBP, DIBP phthalates Limited to concentrations under 0.1% by weight in toys, childcare items, and plasticised materials

Other conditions might apply

Limited to quantities under 0.1% by weight in toys, childcare items, and plasticised materials

Other conditions might apply

(Source)

Benzene Limited to concentrations under 0.1% by weight for substances (inclusive of mixtures and articles), and limited to concentrations of its free state under 0.5% by weight in toys or its parts.

Other conditions might apply

Limited to concentrations under 0.1% by weight for substances (inclusive of mixtures and articles), and limited to concentrations of its free state under 0.5% by weight in toys or its parts.

Other conditions might apply

(Source)

Lead and its compounds Limited to concentrations under 0.05% by weight in jewelry articles.

Other conditions might apply

Limited to concentrations under 0.05% by weight in jewelry articles.

Other conditions might apply

(Source)

Chromium VI compounds Limited to concentrations equal to or below 0.0002% of the total dry weight of cement and cement-containing mixtures.

Other conditions might apply

Limited to concentrations equal to or below 0.0002% of the total dry weight of cement and cement-containing mixtures.

Other conditions might apply

(Source)

Cadmium and its compounds Limited to concentrations under 0.01% by weight in articles and mixtures produced from synthetic organic polymers (i.e. plastic materials) like:

  • High-impact polystyrene
  • Polymers or copolymers of vinyl chloride (PVC)
  • Polypropylene (PP)

Other conditions might apply

Limited to concentrations under 0.01% by weight in articles and mixtures produced from synthetic organic polymers (i.e. plastic materials) like:

  • High-impact polystyrene
  • Polymers or copolymers of vinyl chloride (PVC)
  • Polypropylene (PP)

Other conditions might apply

(Source)

Toluene Limited to concentrations under 0.1 % by weight where its substance or mixture is employed in adhesives

or spray paints and is intended for the general public.

Limited to concentrations under 0.1 % by weight where its substance or mixture is employed in adhesives

or spray paints and is intended for the general public. (Source)

Substances in tattoo inks and permanent make up Unavailable Starting from 4 January 2022, limited concentrations are introduced for substances in tattoo inks and permanent make-up including:

  • Azodyes and carcinogenic aromatic amines
  • Polycyclic aromatic hydrocarbons (PAHs)
  • Metals
  • Methanol

(Source)

Substances of Very High Concerns (SVHC)

UK REACH imposes special requirements for products with “substances of very high concern” (SVHCs). These are substances that have hazards with serious consequences (e.g. cancer-causing, harming fertility, or having other hazardous properties).

SVHC examples

The following substances might be seen as SVHCs:

a. Substances classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) category 1A or 1B

b. Substances that are persistent, bio-accumulative, and toxic (PBT)

c. Substances that are very persistent and very bio-accumulative (vPvB)

SVHC substances can be found in consumer products, including the following:

  • Toys
  • Paints
  • Hair spray
  • Household detergents

Importers and manufacturers duties

Importers and manufacturers should note the obligations that follow when their article contains substances from the Candidate List.

Such obligations arise when a substance from the Candidate List is present in such articles in quantities totaling over 1 tonne annually per producer or importer or is present in such articles above concentration levels of 0.1 % w/w.

Supplier duties for substances included in the Candidate List are:

a. The duty to communicate information on listed substances contained in supplied articles

b. If produced or imported, the duty to notify HSE of listed substances in supplied articles

c. The duty to communicate information via provision of a safety data sheet for listed substance(s) and substance(s) in mixtures to consumers

Supplier duties for substances included in the Authorization List must look to the authorisation provisions of UK REACH to determine whether they can continue to use the substance or apply for a UK REACH authorisation.

Post-Brexit, the UK REACH Candidate List adopted SVHCs contained in the EU REACH Candidate List. However, over time, differences may be evident. Thus, manufacturers, importers, and suppliers ought to be on the lookout for changes.

UK REACH lab testing companies

Lab testing is generally necessary for ensuring compliance with the UK REACH regulation. A lab test report helps to ascertain if a material contains banned or restricted substances.

The following are lab testing companies that offer tests against UK REACH:

  • Labcorp
  • Intertek
  • DEKRA UK

You will obtain a UK REACH test report upon completion. This document lists the applied tests and the test result for each. As such, a UK REACH test report can be used to demonstrate that your product is compliant – which can be requested by HM Revenue & Customs, Amazon UK, or other entities.

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    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
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