EU market access for UK business – real case study

Lately I get lots of emails from UK companies having difficulties doing business with EU based companies.   

Here’s one common case we see daily. If you’re in that position, then this blog post might be right for you.  

A UK based company contacted us because they wanted to supply their products to a German company who will sell them under their own name.  

The German company then asked the UK company about REACH registration of substances in their products. As in many cases the UK company found this guidance form the UK government but didn’t know what to do next.  

They asked us for helping them. I’m sharing what we wrote to them to resolve this situation:  

"There are 2 possibilities regarding the EU REACH Regulation.  

1. If you import raw materials that you use in your products, from EU to UK and the substances in these raw materials are allready registered according to EU REACH, then you essentially re reimport allready registered substances (provided that these substances did not change during formulation of your products) and no registration is required for these substances.
   
   
2. However, in thecase of substances (or substances in mixtures) that are not registered under EU REACH, the importer importing individual substances (as substances, substances in mixtures or as substances in articles released under normal use) in an amount of at least 1 tonne per year, must register these substances.

In the case of substances in mixtures it means that the amount of an individual substance must be 1 tonne per year.   

For example, you import a product in an amount of 2 tonnes per year in the EU market. This product contains 3 different substances (A 60 % B 25 % and C 15 %). Taking into account the concentration of individual substances (and for simplicity’s sake the relative density of all the substances is 1) than the amount of individual substances is as follows: Substance A (60 %) 1,2 t; Substance B (25 %) 0,5 t; substance C (15 %) 0,3 t. So in this case only the substance A is imported in an amount of >1 t and only this substance has to be registered.  

In short, please check with your suppliers of raw materials whether their substances are (still) registered under EU REACH and/or if the amount of individual substances you intend to import into EU is 1 tonne per year or more." 

We can help you with Only Representative services for EU REACH Registration in case you scarce of time and need a bit of support in this area.