UK Chemicals Forum Updates REACH 2018 SME Guidance

The UK Chemicals Stakeholder Forum (UKCSF) has updated its guidance for SMEs and downstreams users on the 2018 REACH registration deadline.

UKCSF is the UK environment department’s stakeholder group on chemicals policy and includes representatives from government, business and civil society groups.

The aim of the update to the guidance, which was published in 2015, is to raise awareness of the deadline and to help companies consider what they have to do, in particular, to prepare and submit dossiers to Echa.

It is also aimed at downstream users, which need to assess the potential for disruption to their supply chains if substances on which they depend are not registered.

The guidance comprises three parts:

a 13-page generic note covering what SMEs need to know about the registration deadline, including information about substance information exchange forums (Siefs), registration costs and alternatives to animal testing;

a 14-page self-assessment guide for SMEs which are downstream users of low-volume chemical substances (as formulators or end users), or distributors. It aims to help companies understand and create their product portfolio; and

a three-page self-assessment questionnaire for SMEs manufacturing or importing articles to help them understand their registration and other obligations.

In the explanatory note to the guidance, the Chemical Industries Association’s (CIA) chief executive Steve Elliott said UKCSF feedback indicates there is still a need to raise awareness on REACH 2018 and its implications for UK business.

"We hope this guidance will help first-time registrants consider what needs to be done to meet the deadline, as well as encourage users of chemicals to assess the impact on their products," he said.

The note was circulated at the forum meeting today. UKCSF members discussed the need for an amendment to provide explicit reference to the legal obligations of UK-based companies, to register their substances under REACH by the deadline. This should be made clear regardless of the UK’s current EU exitnegotiations, they said.

However, after deliberation it was agreed that, if companies are in any doubt, they should contact the UK competent authority’s REACH helpdesk.

The guidance should be available on the UKCSF website soon.