REACH stands for Registration, Evaluation, Authorisation and Restriction of CHemicals. UK REACH applies to the territory of Great Britain (England, Scotland and Wales) and shifts the responsibility from authorities to industry with regards to assessing and managing the risks posed by chemicals and providing appropriate safety information for their users. It impacts on a wide range of companies across many sectors beyond the chemical industry. More information about UK REACH: https://www.hse.gov.uk/reach/about.htm
In order to help minimising the impacts of introducing UK REACH and providing continuity for GB businesses, the UK Government has implemented transitional provisions for GB-based EU REACH registration holders. As UK REACH only applies in Great Britain, legal entities based in the EU and EEA do not have obligations under this regime.
Any GB-based legal entity intending to manufacture ozone for non-biocidal applications into Great Britain (England, Scotland and Wales) at or above 1 tonne per year is required to submit a registration to HSE for ozone. Registration is required per legal entity. A complete registration is required prior to the manufacture of ozone in GB reaching 1 tonne per year. No transitional provisions apply.
Examples are running an ozone generator for bleaching of paper, oxidizing production waste water, etc.
The first step of any new registration is to submit an Article 26 Inquiry.
There are no provisions for pre-registration under UK REACH and pre-registrations previously submitted to ECHA are no longer valid in GB.
An inquiry dossier is compiled using the freely-available IUCLID software package and contains information about your company and the specific substance you intend to manufacture/import in GB.
The process for compiling an inquiry dossier is analogous to the process under EU REACH and the requirements are the same. Therefore, ECHA's manual How to prepare an inquiry dossier remains a valid guide. There is also a helpful video to guide you through the process of creating an inquiry dossier.
Inquiry dossiers can be submitted to HSE via the Comply with UK REACH service on GOV.UK.
Once you have successfully inquired about a substance and received your inquiry number, your contact details (as input during the 'account creation' process), or the contact details of your appointed Third Party Representative (TPR) will be shared with existing registrants, grandfathered registrants and other successful inquirers regarding ozone. This will enable you to engage in the data sharing process.
Under UK REACH, as under EU REACH, registrations are to be submitted jointly, the concept of 'one substance, one registration' has been retained. Each legal entity must still submit their own registration dossier. New registrations must be accompanied by the appropriate registration fee.
Once you have received your inquiry number you will be able to submit your registration dossier via the Comply with UK REACH service on GOV.UK.
Registration dossiers are compiled using the IUCLID software package. As with inquiry dossiers, the process and requirements for registration dossiers under UK REACH are the same as under EU REACH, therefore ECHA's manual How to prepare registration and PPORD dossiers (PDF) can be used to help create your registration dossier.
It is the understanding of EurO3zon that this is not possible. The fast majority of the ozone uses will be understood by HSE as the manufacturing of ozone. Therefore, the substance is subject to registration under UK REACH if produced in quantity exceeding 1 t/y. Nevertheless, if you consider that the ozone resulting from your activities fall within one of the registration exemptions under UK REACH, we advise to have that checked with HSE to ensure that you not end up in breach of the requirements under UK REACH.
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