Recognising your EU REACH registrations under UK REACH (grandfathering)

To help to minimise the impacts of introducing UK REACH and to provide continuity for businesses, the UK Government has implemented transitional provisions for EU REACH registration holders based in Great Britain (England, Scotland and Wales).

Relevant EU REACH registrations have been recognised under UK REACH, this is known as 'grandfathering'.

Grandfathering allows you to continue to access the GB market; however, there are steps you must take using the Comply with UK REACH service.

No registration fee will be levied by HSE for grandfathering your registration.

Who is this guidance for?

If a GB-based legal entity transferred their EU REACH registration to another GB-based legal entity, only the GB-based legal entity to whom the registration was transferred will be entitled to have that registration recognised under UK REACH.

It is not possible for EU-based legal entities to have their EU registrations recognised under UK REACH. UK REACH only applies in the UK, therefore legal entities based in the EU and EEA can have no obligations under this regime.

What you should do to grandfather your registration

In order to grandfather your previous EU REACH registration you need to:

Provide initial information as soon as possible

If you hold a registration that is subject to ‘grandfathering’  and you are continuing to manufacture in Great Britain or import the registered substance into Great Britain at or above one tonne per year you must provide some initial information to HSE.

The deadline for providing this initial information was 30 April 2021 but you can still submit the information.  You should provide the initial information as soon as possible using the Comply with UK REACH service.

You must submit different information if you are a GB-based registrant of intermediates under EU REACH.

You must submit the following initial information:

In addition to the grandfathering information you will be required to submit any relevant information from your EU registration dossier (eg testing proposals) using Comply with UK REACH. If your dossier contains information for which your rights to refer have altered as a result of leaving the EU, you may wish to create a member dossier from your substance dataset. In such a dossier, you should redact the information relating to Annex VII-XI, leaving only the Annex VI information and any attachments.

Note: The Comply with UK REACH service will only accept dossiers compiled using IUCLID 6 and above. If your dossiers are in an older IUCLID format, you will need to convert them as per the guidance on the IUCLID website.

Once you have provided this first batch of information for a substance, you will be able to see all of the other legal entities that have grandfathered their existing EU registration, along with any new registrants that have successfully inquired for that substance. At this point, you will be able to begin engaging in data-sharing negotiations with the other (potential) registrants.

Within 2, 4 or 6 years plus 300 days of the end of the Transition Period (depending on tonnage band and hazard profile of the substance, refer to table below), you must:

comply with the full information requirements for your tonnage band under UK REACH, in accordance with Article 10. The information requirements for registration under UK REACH are identical to the requirements of EU REACH.

News: Extension of transitional registration deadlines

Defra has committed to exploring alternative arrangements for transitional registrations including extending deadlines to provide full registration data.

Defra published a public consultation on extending the current deadlines that closed 1 September 2022.

It is expected that where there are multiple registrants for a substance, this information will be submitted jointly. ECHA's Guidance on data-sharing remains a useful and valid document.

Part of joint registration involves agreement of the identity of the lead registrant. Further details can be found at UK REACH: Lead Registrants in the UK REACH.

What GB registrants of intermediates under EU REACH must submit

If you hold a registration for an intermediate that was subject to ‘grandfathering’ and you are continuing to manufacture in Great Britain or import the registered intermediate substance into Great Britain at or above one tonne per year, you must provide some initial information to HSE.

The deadline for providing the initial information was 30 April 2021 but you can still submit the information. You should provide the initial information as soon as possible using the Comply with UK REACH service.

You must submit the following initial information:

All of the other information submitted to ECHA in accordance with Article 17 or 18 must be submitted to HSE within 300 days of the end of the transition period plus either 2, 4 or 6 years depending on the tonnage and hazard profile (go to table below) of the substance being registered. This is the:

Deadline (last date for dossier submission) Tonnage Hazardous property
27 October 2023 1000 tonnes or more per year
  • Carcinogenic, mutagenic or toxic for reproduction (CMRs) - 1 tonne or more per year
  • Very toxic to aquatic organisms (acute or chronic) - 100 tonnes or more per year
  • Candidate list substances (as at 31 December 2020)
27 October 2025 100 tonnes or more per year Candidate list substances (as at 27 October 2023)
27 October 2027 1 tonne or more per year  
Updated 2022-09-01