As known, a company that places a substance on the UK market for the first time, placing itself as a new producer/importer, will have to submit, for substances produced/imported > 1 ton/year, an Inquiry to the HSE (Health and Safety Executive), followed by a full registration. Only after successfully registering the substance can be placed on the UK market. Although registration is not required for mixtures, individual substances within a mixture must be registered if, similarly to the above, the volume of any of these reaches or exceeds one ton per year.

It is normally the responsibility of UK based manufacturers/importers to fulfill the REACH obligations. However, a non-UK manufacturer/formulator can appoint a UK-based OR to fulfill these obligations on behalf of his importers. In this case, the OR will send an Article 26 Inquiry and, after obtaining approval, will proceed with the presentation of the registration dossier (including all the information necessary for its tonnage band) and the payment of the related fee.

If you plan to import a substance already registered under EU REACH (NRES) into the UK, (through the ECHA website you can check if the substance has already been registered EU REACH by any company), the HSE could approve the application of a transitional period in order to allow the registrant to participate in the Joint Submission together with other registrants of the same substance. To be fair between registrants subject to grandfathering and downstream users based in the United Kingdom, in fact, even if a registrant will still have to send a dossier, the sending of the complete information required for registration can be extended and therefore subject to a transition period of 2, 4 or 6 years. The deadline will depend on the tonnage band and / or the substance-related risk profile. Note that it is still up to the HSE to decide whether you are eligible for this registration procedure or not.

If you need assistance with both the registration of a new substance and a NRES you can contact TEAM mastery for support.