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UK REACH
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UK REACH

As the UK coatings industry uses between 4,000 - 6,000 different chemical substances across the entire portfolio of its products, getting chemical legislation right is extremely important to us and our members.

When the UK left the EU on 31st December 2020, it left all its institutions. This meant leaving the European Chemicals Agency (ECHA) and no longer being covered by the various EU Chemicals regulations, including the Registration, Evaluation, and Authorisation of Chemicals (REACH) legislation. REACH, in particular, was an extremely important piece of legislation, setting high standards of public and environmental health and creating the framework for which chemicals could be used across the EU area.

Immediately after Brexit, the UK ‘copied and pasted’ EU REACH into UK law. Defra subsequently put forward proposals which would have required all chemical substances to be used in the UK to be registered, with full data dossiers, into a new standalone UK REACH database of chemicals. This database would be used by UK regulators to enforce legislation and make decisions about future chemicals policy.

However, industry expressed concerns at the cost of this approach. UK businesses had already contributed to the setting up of EU REACH and the Government’s own estimates of the financial impact to UK businesses of replicating datasets stood at between £1 billion to £3 billion. This matters greatly not just in pure monetary terms, but because many non-UK suppliers of chemical substances may deem the cost of registering in the UK to be too great compared to the size of the market and simply not register substances for sale or use in the UK at all. This would, in turn, mean UK companies may not have access to the full range of chemicals as their competitors in Europe, thus severely damaging innovation and capability in the domestic manufacturing sector, including coatings.

In response, after conversation with industry and other stakeholders, the Government agreed to look again for alternative models for the registration phase of REACH. Defra has now launched a consultation on a new Alternative Transitional Registration model (ATRm) and BCF is in the process of engaging with its members to try to measure the impact. From what we have seen so far, we broadly welcome the proposals, although the devil is in the detail. We also welcome the fact Defra has extended the registration deadlines for UK REACH in order to develop this new model. BCF will continue to work with Defra, the HSE, DBT, others in industry, and those with other interests, to find a proportionate and workable solution, one that will see the UK remain at the forefront of high environmental and health protections standards, but also will not unduly damage UK manufacturing.

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