‘Grandfathering’ list emerges for UK REACH

A list of substances registered under EU REACH by UK companies, which will be carried across as UK REACH registrations, has been published by DEFRA.

UK chemical manufacturers and importers have 'grandfathered' into UK REACH only a small proportion of the thousands registered. Photograph: David Goddard / Getty Images

A total of 4,042 substances are listed, compared to the 22,683 substances currently registered under EU REACH (12,739 of them in full, 9,525 as intermediates), according to data from the European Chemicals Agency.

Holders of existing EU REACH registrations within Great Britain were supposed to complete the so-called ‘grandfathering’ process by providing basic information to the Health and Safety Executive (HSE) by 30 April, using the ‘Comply with UK REACH’ online platform. This is set out in regulation 127B(4)(a) of the UK REACH Regulations. EU REACH still applies in Northern Ireland.

An HSE circular warned that the accuracy of the list “is not guaranteed”. If no transitional data has been submitted for a substance, or if that data was declared to be confidential, it will not be present.

Depending on tonnage band and hazard profile of the substance, full information must be provided within two, four or six years after 28 October this year. Registrants of the same substance should now begin negotiating access to data in order to submit a joint registration dossier – in much the same manner as the EU regime.

Assuming that rights to the necessary data have already been maintained, the process should be painless. However, this will not be so in all cases, meaning that some registrants may have to be forced to conduct their own studies – an expensive and time-consuming prospect that explains the allowance for the long lead-in periods.

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Downstream users of chemicals registered by EU or EEA-based entities can use the list in deciding if they will need to make their own registration under UK REACH. Intentions to continue importing such substances will need to be declared to the HSE by 27 October, with the same two, four or six year full registration deadlines following.

Alternatively, downstream users could request that their suppliers register through an ‘only representative’, or change to a supplier based in Great Britain.