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UK-based REACH registrant

  • Your registration(s) will be legally recognised in the UK REACH system at the point that the UK leaves the EU. This recognition is called ‘grandfathering’.
  • This will provide continued access to the UK market after the UK leaves the EU.
  • You will then need to confirm your existing registration and provide supporting information to the UK Agency (the HSE).You will need to:
    1. Open an account on the new UK REACH IT system, which will be launched by the point that the UK leaves the EU.
    2. Provide some basic information on your existing registration within 120 days of the UK leaving the EU. Full details of the information required can be found in Appendices A and B.
    3. Provide the technical information required under UK REACH for your tonnage band within 2 years of the UK leaving the EU. The information requirements for UK REACH will remain the same as they currently are for EU REACH. This timescale will be kept under review. Full details can also be found in Appendices A and B.
  • Grandfathering will apply to all registrations (including intermediates) held by UK-based entities, including importers and UK-based Only Representatives (ORs), and to sole, lead or joint registrants.
  • Grandfathering will apply to all UK-based registrations that exist at the time of exit, and all registrations held by UK entities at any point within the two years prior to the UK leaving the EU. This means that if a UK registration was transferred to an EU/EEA-based entity in the run-up to the UK leaving the EU, it will still be carried over into the UK system.
  • Grandfathering will not apply to registrations held by entities established outside of the UK, regardless of whether they are part of a group of companies which also has a presence in the UK. Those registrations will not be grandfathered, unless they have been transferred to a UK-based entity before the UK leaves the EU. Before transferring any registrations, you will need to consider how this would affect your operations in the EU/EEA and your ability to access the EU/EEA market.
  • Any ECHA decisions relevant to the registration will remain valid.
  • Grandfathering will not incur any fees from the UK Agency (the HSE) for registrants: it will happen at the point that the UK leaves the EU, providing unbroken legal validity.
  • Your UK REACH registration number will be issued upon submission of the initial information required within 120 days of the UK leaving the EU.
  • Access to the technical information used for the ECHA registration may require renegotiating commercial contracts/letters of access which were originally put in place for EU REACH under a Substance Information Exchange Forum (SIEF). You may wish to instigate contact with SIEF members as part of your contingency planning; this may help provide an early indication of the terms that would be attached to renegotiating access to the data for UK REACH purposes.
  • You may wish to contact the other UK registrants in your SIEF to prepare a joint UK REACH registration.
  • Under UK REACH in a ‘no deal’ scenario, UK companies will not be required to form a Substance Information Exchange Forum (SIEF) to submit registration data, including under the grandfathering provisions. UK REACH will include a similar pre-registration substance inquiry system to EU REACH to facilitate the principle of ‘One Substance, One Registration’ set out in Regulation 2016/9, which will be retained under UK REACH.
You want to You need to By when

access the UK market

1. Open an account on UK REACH IT

2. Enter basic info on UK REACH IT

3.Provide technical information required under UK REACH

 

120 days post-exit day 

2 years post-exit day

access the EU/EEA market

EITHER Transfer your registration(s) to an EEA-based entity (e.g. affiliate or Only Representative)

OR support your EEA-based importers to comply with EU REACH.

Exit day (see ECHA guidance for details)

Exit day (see ECHA guidance for details)

Updated: 2020-01-15