The recent amendments, contained in Statutory Instrument 2023 No 722 and published on 28 June, include an official extension of the transitional registration deadlines, originally outlined in Article 127P of UK REACH.
The extensions, previously highlighted as ‘Option 1’ during talks with the Department of Environment, Food and Rural Affairs (DEFRA), comes into effect on 19 July, and will see the extension of submission deadlines for each tonnage band by three years to October 2026, October 2028 and October 2030, respectively.
The deadlines for compliance checks, originally shown in Article 41, have also been extended in line with this.
The CBA said the changes send a positive signal to companies across the supply chain and in particular to the CBA and its members, following the association’s involvement in key discussions with government and legislators, including consulting on the initial deadline extension with DEFRA, which concluded on 1 September 2022.
The extension received an optimistic response, it added, including from CBA member companies, who showed “overwhelming support to ‘Option 1’ when presented with the proposed timeline changes during the various UK REACH Online Clinics run by the association throughout 2022.”
The proposed ‘Option 1’, which will commence as of 19 July, was described by DEFRA as having the potential to “lessen burdens on SMEs and downstream users without significantly reducing levels of protection of human health and of the environment”.
The changes, whilst expected to provide significant relief, are only the beginning of amendments needed to make UK REACH a viable model for British industry, said the CBA.
Commenting on the extension announcement, Tim Doggett, CEO of the CBA, said “The latest announcement regarding the extension deadlines is encouraging. They are necessary not only for our members and the wider chemical industry, but for distributors and downstream users across Great Britain, who were also brought into the scope of UK REACH following Brexit.
“The implications of UK REACH are not just the implementation costs, which are estimated by DEFRA to be around £2 billion or even £3.5 billion (€2.3billion or €4 billion), but also the impact on the ability of businesses to compete in a global marketplace. Many businesses also remain reluctant to invest due to all the uncertainty.
“Great Britain’s manufacturers are also disadvantaged, not least as they may not have access to the full range of raw materials available to their EU counterparts, ultimately resulting in a number of products not being available to consumers.
“Whilst this is another step in the right direction, there is still a huge amount of work required to make UK REACH proportionate, effective, and efficient – for industry and regulators alike. The CBA will continue to work incessantly with government, legislators and other associations to this end.”