12 April 2021
GB-based holders of existing EU REACH registrations need to complete the ‘grandfathering’ process by providing basic information to the Health and Safety Executive (HSE) by 30 April 2021. You need to submit this information using the UK REACH IT system, ‘Comply with UK REACH’.
Read the HSE guidance to find out how to complete the grandfathering process.
BASA has lots of guidance for its members available on the Health and Safety working group page: https://www.basa.uk.com/WorkingGroups/Group/3 with a BASA Guide to UK REACH available here: https://www.basa.uk.com/WorkingGroups/ArticleDetails?articleId=1197
If you were previously a downstream user or distributor, providing you have notified substances that you wish to continue importing into the GB from the EU by 27th October 2021 you are not obliged to register. Article 127E of the statutory instrument (SI) implementing REACH in the UK provides the transitional provision for these GB-based legal entities. Once the notification is completed, your registration obligation is effectively deferred until up to 6 years plus 300 days after the end of the transition period. If you opt not to submit a notification, then either a full registration would be due for any substances imported at or above 1 tonne per year, or that import must cease. GB-based importers that were regarded as downstream users due to the appointment of an EU-based OR (under EU REACH) are also able to notify under Article 127E. A newly appointed GB-based OR can also make this notification on their behalf
Written by: Lorna Williams