UK REACH Registration

The UK REACH Registration process

UK REACH is the framework that regulates most chemical substances manufactured in or imported into Great Britain (England, Scotland and Wales). Under UK REACH, GB manufacturers or importers of substances and, certain producers or importers of articles intending to manufacture or import a substance into Great Britain at or above one tonne per year must submit a registration for that substance to the Health and Safety Executive (HSE).

Registration under UK REACH covers substances on their own, substances in mixtures and, in limited cases, substances in articles.

Similarly to EU REACH ,the information required for a UK REACH registration depends on the registrant’s tonnage band, with higher tonnage bands requiring more extensive information. There are four tonnage bands:

–             1 to 10 tonnes per year (REACH Annex VII);

–             10 to 100 tonnes per year (REACH Annex VIII);

–             100 to 1,000 tonnes per year (REACH Annex IX); and

–             1,000 tonnes or more per year (REACH Annex X).

Registrants must collect information on the properties and uses of their substance, assess hazards and potential risks from identified uses, and submit the resulting registration dossier to HSE.  Registration dossiers must be kept up to date when new information on the substance becomes available, or changes arise in tonnage, use or classification.

UK REACH Registration Pathways – Transitional Arrangements

Following Brexit (31 Dec 2020) and the introduction of UK REACH, substances imported or manufactured in the GB territory must be registered under UK REACH regulation. As GB was previously subject to EU REACH, measures were put in place to facilitate registration under the new regime, particularly for substances already registered under EU REACH before Brexit.

As a result, several registration pathways exist under UK REACH, depending on the regulatory status of the substance:

  • DUIN applies to GB‑based companies that were downstream users or distributors under EU REACH, and became importers following Brexit. DUINs must be notified to the HSE and allows to defer full registration duties.
  • Grandfathering applies to GB-based legal entities who held an EU REACH registration before 31 December 2020, allowing substances to be automatically carried across into UK REACH, subject to notification and later data submission.
  • NRES applies where a GB-based entity started importing or manufacturing a substance, already registered under EU REACH, after Brexit and cannot therefore rely on DUIN or grandfathering.

In each case, initial notifications preserve market access, but registrants must still submit full technical information to HSE by specific transitional submission deadlines based on tonnage and hazard profile.

Not sure what your registration responsibilities in GB are? Follow this flow chart:

Further information available on registering under UK REACH

For substances already registered under EU REACH, more information on DUIN and grandfathering can be found here: UK REACH: Downstream User Import Notification and Grandfathering

For new registrations under UK REACH, see here: UK REACH information for new registrant

Information on the costs of registering can be found here: Costs of Registration

Whether you are registering for the first time, or need assistance navigating changing regulation, RPA can support your business with the preparation, revision and/or submission of a registration dossier for your substance. If you are seeking registration support, please do not hesitate to reach out to our Chemicals Team with your query: post@rpaltd.co.uk