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The British Retail Consortium (BRC), sent the following response to the Environmental Audit Committee: 

We are delighted to provide you with comments directly from retailers. We are willing to work with you, and where necessary attend any sessions, meetings, or round tables on this subject.

Retailers need to know as soon as possible about any extensions to REACH submissions.

 

About the British Retail Consortium

 

As the go-to trade association for UK retail businesses, our purpose is to make a positive difference to the retail industry and the customers it serves, today and in the future.

 

We tell the story of retail, work with our members to drive positive change and use our expertise and influence to create an economic and policy environment that enables retail businesses to thrive and consumers to benefit.

 

We do this in a way that delivers value back to our members, justifying their investment in the BRC. This membership comprises over 200 major retailers - whether operating physical stores, multichannel or pureplay online - plus thousands of smaller, independent retailers through several niche retail Trade Associations that are themselves members of BRC.

 

Within the BRC we host the Buying Community. This community helps retailers sell safe and compliant non-food products. It is the buying community that has put this response together.

 

Retailer 1 Response

 

We wanted to flag our concerns around the lack of clarity from Defra about how the new chemicals registration system will work from a UK cosmetics industry perspective. 

 

We manufacture and distribute cosmetics products in the UK and we have concerns about the potential for significantly increased costs and complexity for industry, especially small businesses.

 

Retailer 2 Response

 

We see UK REACH as being paused, and unactionable at present for a retailer. We completed the Downstream User Import Notification (DUIN) as per the deadline in October last year but have taken no further action as there are no clear requirements for industry to follow.

 

We cannot ask suppliers to prepare for registration requirements when these are not yet clear. Based on conversations / calls with other industry groups the requirements for substance registration are not yet finalised and seem quite a way off due to the need to balance having information available that regulators require, feasibility and protecting the legal status of companies that own the EU REACH data.

 

Deadline for UK REACH to be extended - GOV.UK (www.gov.uk)

 

The only realistic solution to UK REACH seems to be that the UK authorities utilise established data outputs / endpoints from EU REACH registrations (where substances are registered in the EU), as repeating registration activities is not feasible, cost effective or in some cases ethical (animal testing).

 

We are importing finished cosmetic and other chemical products into the UK from the EU and rest of world and would not be able to complete classical REACH registrations as the necessary data is not available.

 

We would therefore not be able to complete registrations for substances / chemicals but would rely on suppliers to complete the registrations on our behalf. As soon as there is some clarity and confidence in the requirements being set (and not likely to change) we would start conversations with suppliers to ensure future compliance with UK REACH. At the moment there is little value in having these conversations as supplier aren’t able to say what they are committing to.