The main difference between EU REACH and UK REACH is that they are two separate regulatory frameworks governing the use and management of chemicals. EU REACH is an EU-wide regulation that regulates the production, importation and use of chemicals across all member states of the European Union. UK REACH is a UK-specific version of the EU REACH regulation, which came into effect on 1 January 2021 when the UK left the EU.

 

Here are some key differences between EU REACH and UK REACH:

 

1. Role of the European Chemicals Agency (ECHA): Under EU REACH, the ECHA serves as the central regulatory agency responsible for managing the registration, evaluation, authorization, and restriction of chemicals. Under UK REACH, the Health and Safety Executive (HSE) has taken on this responsibility for chemical management and regulation in the UK.

 

2. Data sharing: One significant difference is that UK REACH no longer provides automatic access to European databases, which may require companies to submit data separately to the European Chemicals Agency (ECHA) for use under EU REACH.

 

3. Registration requirements: The registration and notification requirements of companies under UK REACH are different from the requirements under the EU-REACH regulation.

 

4. Retention of existing registrations: Existing registrations under EU REACH have been retained for ongoing supply into the European market, however, new registrations are required under UK REACH for those materials supplied into Great Britain.

 

Overall, UK REACH differs from EU REACH in several areas to reflect the specific needs of the UK. While the general principles of REACH remain the same between the two regulations, companies that manufacture or use chemicals in both the UK and EU will need to comply with two different sets of regulations that overlap in many areas but diverge in some critical areas.