GGF issues key guidance for chemical importers

As the legislation continues to change following the UK’s exit from the European Union, the Glass and Glazing Federation (GGF) issues key guidance for companies in the glass and glazing industry that import chemicals from the EU. 

In a statement to its Members last week, the GGF highlighted the impact on companies who are importing chemicals over one tonne and purchasing from an EU company (or a company based outside Great Britain). 

John Agnew, GGF Group Managing Director (below), comments: “British companies importing chemicals from outside Great Britain must make themselves aware of the obligations under REACH and the impact of the transition to UK REACH.

“The GGF has been raising awareness regarding UK REACH for a few months now with little feedback however it has come to our attention that there are significant business risks that a lot of companies may not be aware of, therefore we have produced guidance for our Members to review and advise those who are importing to act immediately.”

The EU REACH Regulation was brought into UK law on 1 January 2021 and this regulation is now in operation; it is known as UK REACH.

This was triggered by the European Union (Withdrawal) Act 2018 and the EU legislation has been replicated in the UK with the necessary changes to make it operable in a domestic context.

The key principles of the EU REACH Regulation have been retained. UK REACH maintains EU REACH’s aims and principles. These include:

 – To provide a high level of protection of human health and the environment from the use of chemicals
 – the ‘no data, no market’ principle
 – the ‘last resort’ principle on animal testing
 – access to information for workers
 – the precautionary principle

UK REACH and the EU REACH regulations operate independently from each other. Companies that are supplying and purchasing substances, mixtures, or articles to and from the EU/EEA/Northern Ireland and Great Britain (England, Scotland, and Wales) will need to ensure that the relevant duties are met under both pieces of legislation.

Under the Northern Ireland Protocol the EU REACH Regulation continues to apply to Northern Ireland, while UK REACH provides the regulatory framework for chemicals in Great Britain.

Guidance from the GGF shows which companies are responsible for registering under UK REACH. In addition the GGF has covered the criteria needed for registration and the shown how UK REACH affects downstream companies buying from registered importers. The GGF also has a useful flowchart to make it easier for companies to understand their obligations and pathways to registration.  

James MacPherson, GGF Health, Safety and Environment Manager (below), produced the new guidance

“For companies importing chemicals over one tonne the challenges of this transition have been compared to the UKCA transfer from CE marking,” he comments.

“If you are importing chemicals over one tonne into the UK from the EU or from outside Great Britain, it’s a legal requirement to register that chemical, this will incur costs, time and administration.

“Our advice is, if you are purchasing chemicals from a company that is based outside of Great Britain then you should immediately engage with your provider and ask them what they are doing regarding UK REACH and then check what you have to do ensure you are operating legally.”

To see the full GGF guidance on this subject, visit https://www.ggf.org.uk/important-notice-about-reach-uk/

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t: 0207 939 9101

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