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Advice for GB-based manufacturers who held EU REACH registrations on maintaining access to the GB and EU markets.

Maintaining access to GB market 

All REACH registrations held by GB manufacturers on the withdrawal date and those that were in place at any point since 29th March 2017 were eligible for grandfathering in the UK.

To ensure that your registration was grandfathered, you should have submitted a dossier to the HSE via the UK REACH IT tool within 120 days from the end of the transition (30 April 2021). If you have missed the deadline, please consult the HSE website for more information.  

The submission had to include data on the substance including registration numbers and substance identity, see Table 1 & 2, and any ECHA decisions regarding the registration. 

 

Table 1: Data required for the 120 day submission Legal reference Article 10 (a)(i), (ii), (iii), (viii)  

Tes pic 2

Table 2: Data required for the 120-day submission (Intermediate registration)  Legal reference Article 17, Article 18 

Test pic

 

After grandfathering, a full registration dossier is required within a phased registration timeframe based on tonnage and hazard properties in order to maintain access to GB market (deadlines: 27 October 2026; 27 October 2028; 27 October 2030).  

The grandfathering and submission of registration dossier doesn’t incur any HSE fees.

REACHReady recommends companies to review the conditions under which existing studies can be used for UK REACH purposes. See CIA/Cefic joint guidance for further details (Note: The joint guidance, prepared to support companies for the end of the Brexit transition period, does not reflect subsequent extensions of the UK REACH registration deadlines).  

GB manufacturers had the opportunity to transfer their REACH registrations to an EU-27/EEA based company or Only Representative that manufacture or import the substance into the EU following the UK withdrawal. The process of transferring registration is closed.

GB companies no longer have full access to their REACH IT accounts. They however maintained access to their message boxes.

GB based companies can continue to supply the EU following the transfer of their own registration. If the transfer didn’t take place, EU/EEA/ Northern Ireland based customers may need to register the substances themselves if importing at 1 tonne or more per year or use alternative suppliers who may have registered.