When the UK left the EU, one of the less-publicised consequences was the creation of an entirely separate chemical regulatory regime. Companies that previously relied on a single EU REACH registration now face a dual compliance landscape — and many still haven't fully adapted.
Having served as Director of an entity acting as EU Only Representative for chemical registrations under REACH, I've seen both sides of this transition firsthand. Here's what UK companies need to understand.
What changed
Before Brexit, the UK was part of EU REACH. A company registered with the European Chemicals Agency (ECHA) in Helsinki could manufacture, import, or sell chemicals anywhere in the EU and UK under a single registration.
After Brexit, two things happened:
- UK REACH was created, administered by the Health and Safety Executive (HSE) rather than ECHA. Companies manufacturing or importing chemicals in the UK now need a UK REACH registration.
- EU REACH still applies for selling chemicals into the EU. But UK-based companies are now considered "non-EU" — which means they can no longer hold EU REACH registrations directly.
The EU Only Representative requirement
If you're a UK manufacturer or formulator exporting chemicals to the EU, your EU-based importers need access to an EU REACH registration. You have two options:
- Each of your EU importers registers individually — expensive, duplicative, and commercially awkward (you're asking your customers to take on a regulatory burden)
- You appoint an EU Only Representative (OR) — a legal entity based in the EU/EEA that holds the registration on your behalf and fulfils the regulatory obligations under REACH
The Only Representative route is almost always the better option. It centralises the regulatory responsibility, simplifies your supply chain, and protects your EU market access.
What an Only Representative actually does
The OR is not just a postbox. They are legally responsible for:
- Holding and maintaining your EU REACH registration(s)
- Keeping the technical dossier up to date
- Responding to ECHA requests for information
- Ensuring compliance with restrictions, authorisations, and substance evaluation decisions
- Managing downstream user communications (safety data sheets, exposure scenarios)
This requires genuine technical and regulatory competence — not just an address in the EU. When selecting an Only Representative, look for real experience in chemical regulation, not a corporate services firm offering it as an add-on.
UK REACH: the other half of the equation
UK REACH requires companies importing chemicals into the UK (from the EU or elsewhere) to register with HSE. The UK government initially set a transition deadline that has been extended multiple times, but the obligation remains.
If your business imports chemicals into the UK, you need to understand your registration obligations under UK REACH. The requirements are broadly similar to EU REACH but administered separately, with separate fees and separate data requirements.
The practical impact
For UK chemical companies, the post-Brexit reality is dual compliance: UK REACH for the domestic market and EU REACH (via an Only Representative) for the European market. The administrative and financial burden is real, and it disproportionately affects smaller companies.
The companies that navigate this well are the ones that get expert guidance early, rather than waiting for enforcement action. EHS Protect provides REACH compliance services drawing on direct operational experience in EU Only Representative arrangements.
Richard Levack
Managing Director, EHS Protect. IRCA EMS Lead Auditor · NEBOSH · COSHH Assessor