UK REACH: I missed the grandfathering deadline: what should I do?

April 5, 2021

No grandfathering? No need to panic

If you missed the deadline to complete grandfathering under UK REACH, all is not lost. Grandfathering was a system made for UK-based companies that previously had a registration under EU REACH. Under this system, these companies had the opportunity to have their registrations recognised under UK REACH, without a fee and with an additional 2, 4 or 6 years to complete their full registrations.

Without grandfathering, UK companies must submit full registrations to the Health and Safety Executive (HSE), To do so, there are several steps.

The steps of a registration under UK REACH

An Article 26 inquiry must first be carried out. An inquiry is made through the IUCLID software and must contain information about the company submitting it and the substance to be imported or produced in the UK.

This inquiry allows potential registrants to get in touch with previous registrants and to share the data needed for the common part of the registration dossier.

Inquiry dossiers can be submitted to the HSE via the Comply with UK REACH IT portal. After this, companies are issued an inquiry number and their information will be shared with other registrants of the same substance. Registrants can also choose to appoint a third party representative, or TPR. The TPR plays a role in the negotiations between (potential) registrants and preserves the anonymity of the company that appointed them, although the latter remains responsible for the registration obligations.

After inquiry, the registrations must be submitted jointly, as under EU REACH. This means that the dossiers consist of a common part with all the information about the substance and the tests performed, and an individual part, which contains information specific to the company's use of the substance as well as tonnage bands, etc.

New registrations must pay a fee to the UK competent authorities to validate their registration.

The next deadlines for UK REACH

Without grandfathering, full registration must be completed before the substance is imported or manufactured in the UK. If grandfathering could have been completed in time, companies would have had 2, 4 or 6 years from the 30th April deadline.

Another case is the Downstream User Import Notification, or DUIN, which concerns companies that were previously considered as downstream users before the implementation of UK REACH, and which now become importers. These companies have until 30th June to make this notification, thus benefiting from an extended period (2, 4 or 6 years more) before making a full registration.

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