March 2, 2021 by Becky Marks
Under UK REACH, UK-based companies with existing registrations under EU REACH can benefit from grandfathering these into the UK system. This option applies for any UK-based company that held an EU REACH registration for the substance between 29th March 2017 and 31st December 2020, even if the registration was transferred to an EU-based legal entity before the end of the transition period.
To grandfather a registration, simple information about the legal entity, substance identity and previous EU registration (registration number and date) needs to be submitted through the UK’s REACH IT system, with an IUCLID 6 file including information equivalent to that submitted for a co-registrant dossier under EU REACH. There is no charge for this initial notification and, once submitted, the company can benefit from phased registration deadlines for the full UK REACH submission (either 2, 4 or 6 years from 28th October 2021). The deadline for submitting the initial grandfathering notification is now approaching, and this must be completed before 1 May 2021. If this is not completed, the phased registration timelines will not apply, and a full registration would need to be submitted before manufacture or import into the UK.
Once the initial notification is submitted, you are able to view other companies with an interest in the substance and, after 1 May 2021, can appoint a lead registrant and begin data access negotiations. This next phase in the UK REACH registration process is likely to be challenging, and we would recommend beginning the process of identifying and accessing relevant data for the full registrations as soon as possible.
wca are able to provide advice on your UK REACH obligations, support with submitting notifications through UK REACH IT and help with developing a registration strategy and with joint submission and data access discussions. For further information please contact us.