What Are the Differences Between UK REACH and EU REACH?

The EU reach regulation was incorporated into UK law on January 1, 2021, and has since enteRED into force as uk reach. UK REACH upholds the objectives and principles of EU REACH, yet the two regULations operate independently of each other.

What Is UK REACH?

The EU REACH Regulation was incorporated into UK law on January 1, 2021, and has since entered into force as UK REACH. This initiative was triggered by the European Union (Withdrawal) Act 2018, under which EU legislation was transposed into UK domestic law with necessary amendments to ensure operability in the UK’s national context. The core principles of the EU REACH Regulation have been retained, and UK REACH continues to uphold the objectives and principles of EU REACH.

UK REACH and EU REACH operate independently of each other. Companies supplying or procuring substances, mixtures, or articles to/from the EU/EEA/Northern Ireland and the UK (England, Scotland, and Wales) must ensure compliance with the obligations set out under both regulatory frameworks.

Pursuant to the Northern Ireland Protocol, EU REACH remains applicable to Northern Ireland, while UK REACH provides the regulatory framework for cheMICals within the rest of the UK.

What Is the Scope of Products Covered by REACH?

REACH has a broad scope of application, covering almost all commercial products excluding food, feed, and pharmaceuticals.

The regulated products include:

①　Chemicals, alloys, plastics, semi-finished products, and components

②　Toys, furniture, cosmetics, stationery, pigments, paints, adhesives, and detergents

③　Textiles and apparel, footwear, leather goods and accessories

④　Electrical and electronic products

⑤　Other household, leisure, and sports goods

What Are the Differences Between EU REACH and UK REACH?

①　Overall updates to UK REACH SVHC (Substances of Very High Concern) and Annex XVII lag behind those of EU REACH.

②　The UK SVHC list has only been updated to align with the EU’s 23rd batch, whereas the EU has already released the 27th batch of SVHC.

③　The most significant difference between UK Annex XVII and EU Annex XVII for finished products lies in Clause 68: the UK still retains the regulatory requirements for PFOA, while the EU has replaced PFOA with PFCA (C9-C14).