UK REACH has the potential to significantly impact the long term attractiveness of the UK chemical industry and its downstream sectors and users, large and small. This in turn will impact the UK as a destination for Foreign Direct Investment (FDI).
Therefore, each business needs to be aware of not just the short term implications and obligations (e.g. the first deadline to grandfather runs for 120 days after the end of the transition period which was 1 Jan 2021) but also the long term strategic implications;
- In the long term is the UK the right location for all your current activities or will a shift be triggered?
- What will the impact be on the balance of power in chemical markets?
- Will consolidation be triggered?
Managing the UK REACH landscape means costs, complexity and having the capabilities to successfully and competitively re-register substances.
UK REACH burdens UK chemical users and stakeholders with the costs of re-registering chemical substances that were already registered under EU REACH. These costs can be significant and depend on the number of substances a company has to re-register. Beyond the question of cost is the question of whether companies will have access to the data held by companies or consortia in the EU, as access to REACH dossiers via the ECHA database will be lost.
Achieving access and the cost associated with data access will cast a shadow over the long term availability of many substances in the UK moving forward. Although the deadlines are years away (the latest being 6 years from 28 October 2020) the chemical industry and downstream sectors are ones that have multi-year planning cycles and more importantly R&D and product development cycles.
As with many of the ramifications of Brexit one has to identify the strategic long term impact at the same time as managing the short term actions required to comply.
For example, for UK-based enterprises that have completed EU REACH registration (Grandfathering) there are two steps. Holders of EU REACH registrations should;
- Submit the basic information to the Health and Safety Executive (HSE) before 30th April 2021
- Supplement all the related information within 2, 4, or 6 years from 28 October 2020, depending on the tonnage band and the hazards.