18 Mar 2021


UK implemented EU REACH on January 01, 2021, known as UK REACH. If your business is supplying/purchasing products from any of the below locations, you need to fulfil duties under both EU and UK REACH.

  • the European Union (EU)
  • Northern Ireland (NI)
  • Great Britain (GB) (England, Scotland and Wales)
  • the European Economic Area (EEA)

Now, companies need to ensure if duties are met. The details are as under:

1. Grandfathering

Great Britain entities that are transferred to EU based entity, after March 29, 2017 and before December 31, 2021 are subjected for Grandfathering. To Obtain UK registration number, these entities should submit Substance, enterprises information and EU REACH registration number before April 30, 2021 to HSE. Administrative fee is exempt for Grandfathering entities.

2. Downstream User Notification – DUIN

Great Britain entities that imported substances/mixtures/articles to Great Britain from March 20, 2017 to December 31, 2021, need to complete DUIN. Once the notification is completed, the registration obligation is effectively deferred until up to 2, 4 or 6 years plus 300 days.

The DUIN and transition Period for Grandfathering is applicable as mentioned here:

Deadline post October 28, 2021 Tonnage Hazardous property
+2 years 1000 tonnes or more per year
  • Carcinogenic, mutagenic or toxic for reproduction (CMRs) – 1 tonne or more per year
  • Very toxic to aquatic organisms (acute or chronic) – 100 tonnes or more per year
  • Candidate list substances (as at December 31, 2020)
+4 years 100 tonnes or more per year
  • Candidate list substances (as at October 27, 2023)
+6 years 1 ton or more per year

3. New Registrations

When a complete registration is required prior to the manufacture or import into Great Britain, no transitional provisions will apply.
The first step of new registration is to submit an Article 26 Inquiry. Once related enterprises have received the inquiry number, they are able to contact existing registrants, grandfathered registrants and other successful inquirers.

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