REACH Compliance

The regulatory landscape

REACH post-Brexit: two regimes, one supplier

Since the UK left the EU, UK businesses supplying chemicals, mixtures, or articles into the EU face a dual compliance challenge: UK REACH (administered by the Health and Safety Executive) and EU REACH (administered by ECHA).

For EU REACH, when a UK manufacturer or formulator supplies substances or mixtures to an EU importer, the obligation to register those substances under EU REACH falls on the EU importer — unless a non-EU manufacturer appoints an EU Only Representative (EU OR) in an EU member state. By appointing an EU OR, the UK supplier takes on the registration obligation directly and relieves downstream EU importers of that burden.

This is a significant commercial differentiator — EU customers strongly prefer UK suppliers who have an EU OR in place, because it removes the registration complexity and cost from the importer.

Our experience

Our lead consultant has direct, hands-on experience delivering EU Only Representative services — with practical insight into how EU OR arrangements are structured, how ECHA registration dossiers are maintained, and how downstream user obligations are managed across European supply chains.

This is not textbook knowledge — it's experience built from working inside the system that governs how post-Brexit chemical supply into the EU actually works in practice.

Who needs an EU Only Representative?

UK manufacturers, formulators, and producers of articles who supply substances, mixtures, or articles containing substances at or above threshold quantities into the EU — and who want to take on the registration obligation rather than leaving it to each EU importer.

The EU OR must be established in the EU and takes on legal responsibility for the REACH obligations of the non-EU manufacturer.

What are SVHC obligations?

Substances of Very High Concern (SVHCs) on the REACH Candidate List must be communicated to downstream users and consumers when present in articles above 0.1% w/w. This is an ongoing obligation as ECHA adds substances to the Candidate List.

We help you screen your products, set up supply chain communication processes, and stay current with Candidate List updates.

UK REACH vs EU REACH

Following Brexit, UK REACH (administered by HSE) and EU REACH (administered by ECHA) are now distinct regulatory regimes. Registrations under one regime do not automatically satisfy the other. Businesses operating in both markets must manage both sets of obligations.

We help you map your obligations under both regimes and build a compliance approach that is efficient and joined-up.

Authorisation and restriction

Certain substances subject to EU REACH Authorisation (Annex XIV) require an authorisation from ECHA before they can be used or placed on the EU market. Others are subject to restrictions (Annex XVII) limiting or prohibiting their use.

We help you identify whether any substances in your products or processes are subject to authorisation or restriction requirements.