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UK REACH: Update on Grandfathering Data Requirements

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UK REACH: Update on Grandfathering Data Requirements

What must existing registrants, who have submitted a full registration under EU REACH, submit to claim grandfathering rights under UK REACH?

The following information has to be supplied to HSE (the UK Agency) within 120 days of the end of the transition period:

  • Evidence of the registrant’s ECHA registration (e.g. ECHA registration number and date)

  • Information referred to in Article 10(a) (i), (ii), and (iii), and any relevant indication under Article 10(a) (viii)) i.e.:

  1. identity of manufacturer/importer

  2. substance identity

  3. information on the manufacture and use of the substance data

  4. an indication as to which of the relevant information on manufacture and use has been reviewed by an assessor  

  5. notification of any ECHA decision which relates to the registration

In order to comply with these requirements there may be an option to upload the latest IUCLID dossier file for the substance.

All other information submitted to ECHA in accordance with Article 10 must be submitted to HSE within 300 days of the end of the transition period plus either 2, 4 or 6 years depending on the tonnage and hazard profile of the substance being registered.

This information will include:

  1. the classification and labelling of the substance

  2. guidance on the safe use of the substance

  3. study summaries

  4. robust study summaries, if required

  5. an indication as to which of the above has been reviewed by an assessor

  6. proposals for additional testing 

  7. exposure information for substances in the 1-10 tonnes tonnage band

  8. confidentiality request and justification, if relevant

  9. a chemical safety report when required under Article 14

Please contact Peter Godfrey (peter.godfrey@cea-res.co.uk) or Neil Stearn (neil.stearn@cea-res.co.uk) if you have any questions regarding UK REACH compliance, claiming grandfathering rights or for other UK REACH compliance issues.

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