The transition period of the UK’s withdrawal from the European Union ends on 1 January 2021, which marks the beginning of UK REACh – the UK’s independent chemicals regulatory framework. As a company that distributes chemicals both in the UK and the EU, we will ensure that we follow the rules of both UK and EU REACh.
We have already transferred our existing registrations to Phoenix Aromas GmbH, based in Frankfurt, Germany to guarantee that material bought will be available for the EU market. For those chemicals which are registered by a non-EU based manufacturer via an EU based Only Representative, we have ensured that the OR appointed is located outside of the UK.
From 1 January 2021 and the opening of the UK REACh IT system, ‘Comply with UK REACh’, we will be able to carry across our registrations directly into UK REACh, known as ‘grandfathering’. To ensure that imported chemicals where we are a downstream user comply with UK REACh, we will begin submitting Downstream User Import Notifications (DUINs) of our intention to continue importing substances from the EU/EEA once the system opens. We will then submit, or encourage our supplier to submit, a new registration to the HSE within 2, 4 or 6 years of 28 October 2021, depending on the tonnage or hazardous property of the imported chemical.
The timeline of our actions to comply with the new regulations coming into force is as follows:
- 1 January 2021 – Opening of REACh IT system, ‘Comply with UK REACh’, beginning of Grandfathering and DUINs
- 30 April 2021 – Grandfathering of previously UK-based registrations deadline
- 27 October 2021 – Downstream User Import Notification (DUIN) deadline
- 28 October 2023 – >1000T/y, CMRs <1T/year, H410 / H400 >100T
- 28 October 2025 – >100T/year
- 28 October 2027 – >1T/year
We understand that the new year will bring plenty of challenges for all parties involved in the supply and use of chemicals in the fragrance and cosmetic industry. We at Phoenix are committed to ensure that we continue to offer our full range of products in compliance with all new regulatory framework coming into force, and that we remain open and faithful to our customers throughout.
We look forward to working with you in 2021 and the years to come. Download our REACh Statement: REACH Update December 2020