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UK REACH: Enterprises may Enjoy a Transition Period for Data Submission

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UK REACH has been implemented for more than 5 months and grandfathering has been closed on 30 Apr. 2021.

Grandfathering only applies to UK companies that have held an EU REACH registration at any time between 29th March 2017 and the end of the transition period on 31st December 2021.

DUIN is for manufacturers, formulators and article producers based outside of GB that have completed EU REACH registration before 31 Dec. 2020. Related enterprises shall notify with HSE before 27 Oct. 2021 to ensure the continuity of trade. Once the notification is completed, the registration obligation is effectively deferred until up to 2, 4 or 6 years plus 300 days (28 Oct. 2021).

For enterprises that do not fulfill the requirements of DUIN, UK REACH registration shall be done. As the LR nomination is not available in the Comply With REACH System at current stage, related enterprises cannot purchase LOA immediately. In order to reduce the delay in registration, HSE has implemented a more flexible registration strategy:

1. For substances that have registered under EU REACH, related enterprises may submit a dossier with no data to complete UK REACH registration. Enterprises may enjoy a transition period of up to 2, 4 or 6 years based on the registration tonnage and the registration data can be provided within the transition period.

2. For substances that have not registered under EU REACH, related enterprises still have to submit corresponding data to obtain a UK REACH registration number.

Details are as follows:

Substance

Scope of  Enterprises

Registration  Process

Substances  that have completed EU REACH registration

GB-based  enterprises that do not fulfill the requirements of DUIN and grandfathering  who intend to export substances in volumes larger than 1t/y to GB. These  include GB-based manufacturers, importers as well as only representatives  (entrusted by manufacturers based outside of GB)

Registrant  applies for inquiry;

Submit  registration dossier (the data exemption declaration included);

Pay the  administrative fee and obtain the UK REACH registration number.

If you have any needs or questions, please contact us at service@cirs-group.com.

Reference:

Introduction to UK REACH

How to comply with UK REACH