Streamlined UK
REACH Compliance

Yes, although the deadlines have passed, it is still possible to make use of the transitional provisions under UK REACH if you are eligible to do so. The provisions are Grandfathering and the Downstream User Import Notification (DUIN). Grandfathering is for Great Britain (GB) based legal entities that held an EU REACH registration at any point between 29 March 2017 and 31 December 2020. Then, the DUIN is for GB based legal entities that were previously downstream users or distributors under EU REACH and became importers when UK REACH came into force. Making use of the provisions enables you to defer or suspend your registration duty until the relevant registration deadline, which will be dependent on the tonnage band and/or hazard class of your substance.

H2 Compliance has a team of UK experts who previously worked for the Agency for UK REACH; therefore, we are well equipped to help you complete the submissions and ensure you are compliant with UK REACH. Contact us at info@h2compliance.com.

Yes, you have a registration duty under UK REACH if you manufacture or import a substance in GB at or above 1 tonne per calendar year and the substance is not exempt. Therefore, you must ensure you have a registration in place before you breach the 1 tonne threshold.

However, if you are registering a substance that was registered under EU REACH before 1 January 2021 by any legal entity, you will be a New Registrant of an Existing Substance (NRES). This means you can defer the full information requirements in the registration dossier until the relevant deadline depending on the tonnage band and/or hazard class. Consequently, you will have the same deadline as grandfathered registrants and company’s that have submitted a DUIN.

To submit a registration as a NRES, you still need to submit an Article 26 Inquiry and registration dossier, and pay the UK REACH Agency fees, but the Letter of Access (LoA) does not need to be paid until the relevant deadline. Instead, a waiver is included in the dossier that explains why you are currently not able to get the information (due to the transitional provisions), that you will make every effort to negotiate with the other members of the substance group and will either provide the data yourself as lead registrant or will become a member of the joint registration at the relevant deadline.

As of January 2025, the most recent update with UK REACH is the release of the public consultation on the Alternative Transitional Registration model (ATRm). This is an alternative registration model for substances that were registered under EU REACH at the time the UK left the European Union i.e., substances registered under EU REACH before 1 January 2021. H2 Compliance has completed a full analysis of the public consultation, which can be found here: Unlocking UK REACH: Understanding the ATRm Public Consultation and its Future – H2 Compliance and any further updates will be posted on our news page here: News – H2 Compliance.

Defra, the policy lead for UK REACH, were expected to publish the results of the public consultation in 2024.  However, due to the large number of responses (241), they are currently still considering their approach to UK REACH and will provide a summary of responses in 2025.