UK REACH: Approaching Deadlines

Separate UK REACH regulations entered into force in Great Britain on 1st January this year. The new regulations include transitional provisions to reduce the impacts on some businesses resulting from the introduction of a duplicate REACH regime. These included provisions for:

  • existing EU authorisations to be carried over (‘grandfathered’) into UK REACH;
  • ‘grandfathering’ existing EU REACH registrations (held by GB-based legal entities) into UK REACH; and
  • Submitting simple ‘downstream user import notifications’ (DUINs) for EU REACH registered substances imported into Great Britain by downstream users.

The deadline for notifying the UK Authorities of existing authorisations was 1st March, and has now passed.

The deadline for submitting the required information to ‘grandfather’ existing EU REACH registrations into UK REACH is 30th April 2021. If you are eligible to ‘grandfather’ existing registrations in this way, it is important to ensure that you do not miss this deadline. There is no registration fee for grandfathered registrations. Once the required ‘grandfather’ information has been submitted, full registration of the grandfathered substance/s will only be required within 2,4 or 6 years, depending on the tonnage and hazard profile of the substance/s. However, if you miss the 30th April deadline, then it will be necessary to submit the full registrations for any substances imported into, or manufactured in Great Britain in volumes of more than 1 tonne per year. The 2, 4 and 6 year deadlines offered through the grandfathering process will not be available.

The deadline for submitting DUINs is 28th October 2021 this year. Submitting the basic information required in a downstream user import notification also enables imports to continue for a period of 2, 4 or 6 years, depending on the tonnage and hazard profile of the substances. But as with grandfathering, you will not be able to benefit from these extended deadlines for registration if the October deadline is missed.

It is vital therefore to ensure that you take action quickly to ensure ongoing compliance with UK REACH. For advice and support with UK REACH, please contact our jhodgson@staphyt.com