UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulates the manufacture, import, and use of chemical substances in Great Britain (England, Scotland, Wales). It is administered by the Health and Safety Executive (HSE). Businesses handling chemicals in the composites supply chain including resins, curing agents, catalysts, fibres, and surface treatments must ensure compliance – this is a LEGAL REQUIREMENT.
1. Determine Your Role Under UK REACH
Your obligations depend on your position in the supply chain:
• Manufacturer – Produces substances in Great Britain.
• Importer – Brings substances, mixtures, or articles containing substances into GB from outside.
• Downstream User – Uses chemicals supplied under REACH (e.g., formulators, composite manufacturers).
• Distributor – Stores and sells chemicals without modification.
2. Registration Requirements
• Registration is required for substances manufactured or imported at ≥1 tonne per year.
• Substances in resins, hardeners, adhesives, and additives must be registered unless exempt (e.g. polymers, certain naturally occurring materials).
• Only GB-based entities can register; EU or non-GB suppliers cannot.
• Importers must ensure own registrations or work through an Only Representative.
How this applies to fibres
a) Fibres as “substances”
• Fibres are made of substances (e.g. glass, carbon, aramid, or natural polymers).
• The chemical manufacturer or importer of the fibre material (e.g. glass composition, carbon precursor) may need to register those base substances under REACH if they meet the tonnage thresholds.
b) Fibres as “articles”
• Once a fibre becomes an article (e.g. chopped strand, woven fabric, or composite prepreg), it is usually considered a solid article with a defined shape and surface.
• Articles are not subject to registration unless they intentionally release substances under normal use (which most fibres do not).
c) Exceptions and obligations
• SVHCs (Substances of Very High Concern): If a fibre or composite contains SVHCs above 0.1% w/w, suppliers must communicate this down the supply chain and (if applicable) notify ECHA.
• Resin systems or sizing agents applied to fibres are chemical mixtures and are covered by REACH registration obligations.
• Recycled fibres: The “recovered substance” exemption may apply, but only if the substance is already registered and the recycler has information on its safe use.
3. Downstream User Obligations
• Verify your substances are registered for your intended use by your supplier – request documentation as part of your procurement process. There is no public register that links each chemical substance to the UK-based company that has registered it. Grandfathered chemicals can be checked here. If in any doubt contact HSE directly.
• Follow and implement exposure scenarios provided in Safety Data Sheets (SDS).
• Notify HSE if you use a substance in a way not covered by your supplier’s registration.
• Maintain records of safe handling and employee protection measures.
4. Authorisation & Restrictions
• Certain substances of very high concern (SVHCs) may require authorisation for specific uses.
• Check the UK REACH Candidate List and Authorisation List (Annex 14) regularly.
• Observe restrictions (Annex 17) on use of substances such as styrene, cobalt salts, or certain flame retardants.
5. Data Sharing & Transitional Arrangements
• For legacy EU REACH registrations transferred under Downstream User Import Notification (DUIN), full data submission deadlines apply by October 2027–2028, depending on tonnage and hazard.
• Engage in data-sharing consortia early to manage costs and avoid duplication.
6. Practical Steps for Composites Businesses
- Inventory all substances used in resins, catalysts, fibres, coatings, and releases.
- Confirm UK REACH registration status for each supplier and material.
- Establish supplier declarations and SDS review routines.
- Monitor HSE updates and maintain compliance documentation.
- Train staff on safe use, storage, and reporting obligations.
Further Guidance
• HSE UK REACH Hub: https://www.hse.gov.uk/reach/index.htm
• Composites UK Guidance: https://compositesuk.co.uk/member-resources/business-development/uk-reach/
• REACH Helpdesk: ukreach.clp@hse.gov.uk
• Enforcement of UK REACH: CRDEnforcement@hse.gov.uk