UK REACH: grandfathering process and major compliance steps
The entry into force of the UK REACH regulation has brought with it new obligations. In particular UK companies which held EU REACH registrations before the end of the transition period have the option of transferring them to the UK, under UK REACH.
The deadline for this grandfathering process is 30th April. This means that UK companies have one more week to transfer their registrations under UK REACH without having to re-register from scratch.
Who is affected by grandfathering?
This includes UK companies that have held an EU REACH registration at any time between 29th March 2017 and the end of the transition period on 31st December 2021.
What are the necessary steps in the grandfathering process?
- Open an account on the UK Comply with UK REACH IT platform
- Submit initial information related to the registration in question (proof of existing EU REACH registration, identities of the substance and registrant, information on manufacture and uses of the substance, etc.)
- You will be given a registration number
- You will then have access to information on entities that have completed the grandfathering process or new registrants of the same substance and can begin to negotiate data-sharing
- Finally, you will need to submit all the information required for full registration within 2, 4 or 6 years of 28th October 2021, depending on your tonnage band.
UK REACH: the next deadlines
Apart from the 30th April 2021 deadline, there are other dates to remember for UK REACH:
- 28th October 2021: deadline for DUIN (Downstream User Import Notification). This is for UK companies that were previously downstream users or distributors of registrants under EU REACH and have, at the end of the transition period, become importers under UK REACH. These companies, if they wish to continue to import these substances into the UK, will have to submit their DUIN on the Comply with UK REACH platform by October this year.
Companies that have started a DUIN or grandfathering process must subsequently complete their full registration by the following deadlines:
- 28th October 2023 for substances imported or produced in excess of 1000 tonnes per year, as well as CMR substances (carcinogenic, mutagenic or reprotoxic) in excess of 1 tonne per year, substances that are extremely toxic to aquatic organisms in excess of 100 tonnes per year and substances on the Candidate List for authorisation as of 31st December 2020.
- 28th October 2025: substances imported or produced in quantities of more than 100 tonnes per year and substances on the Candidate List for authorisation as of 31st December 2023.
- 28th October 2027: substances imported or produced in excess of 1 tonne per year.
Wish to know more about UK REACH Registration dossiers?
For more information, do not hesitate to contact Saad Shehadeh or one of our experts via our contact form, indicating the purpose of your inquiry.
