Recognising your EU REACH PPORD (Product and Process Orientated Research and Development exemption) under UK REACH
To help to minimise the impacts of introducing UK REACH regime and to provide continuity for businesses, the UK Government has implemented transitional provisions for GB-based EU REACH PPORD holders.
Relevant EU REACH PPORDs have been recognised under UK REACH, this is known as 'grandfathering'.
This only applies if the PPORD holder is based in GB. If your PPORD was for supply to a user in the EU, then the recipient will become an importer and will need to consider whether they need to apply for a PPORD under EU REACH.
What you need to do
Within 120 days of the end of the Transition Period the GB-based holders of an EU REACH PPORD will need to:
- Notify HSE of the relevant information required as per Article 9(2) of the REACH regulation;
- the identity of the manufacturer or importer or producer of articles as specified in section 1 of Annex VI
- the identity of the substance, as specified in section 2 of Annex VI
- the classification of the substance as specified in section 4 of Annex VI if any
- the estimated quantity as specified in section 3.1 of Annex VI
- the list of customers referred to in paragraph 1, including their names and addresses
- Notify HSE of the number and notification date assigned by ECHA
- Supply HSE with copies of any additional necessary information given to ECHA
This can be done by sending the required information to the email address at [email protected]
Grandfathered PPORDs in GB will be subject to the same conditions imposed by ECHA, so you must provide evidence of these.
Grandfathered exemptions will expire on the date that the exemption granted under the EU REACH Regulation would have expired or if an extension had been granted on the expiry date for the extension.
There is no fee for carrying over your EU REACH PPORD exemptions into UK REACH.
If the relevant conditions are met, GB-based holders of grandfathered PPORDs can apply for an extension under UK REACH.