“Comply with UK REACH”: Important updates on Lead registration and tonnage update processes
Date: 15 June 2021
On 1st January 2021 the UK REACH regulation became effective. To re-cap, the two key deadlines in 2021 are the Grandfathering deadline on 30th April and the DUIN deadline on 27th October.
According to British authorities it should be possible to claim the Lead registration of a substance directly after the recently passed Grandfathering deadline. Against their initial plan the function has not been activated yet because of the feedback from stakeholders. The HSE is now considering the most suitable time to make the Lead functions available in the UK REACH tool in order to best manage this crucial and complex stage of forming groups and making joint submissions.
Although the lead function is not yet available, we recommend submitting an Article 26 inquiry as soon as you know that you will have to register a certain substance. Then the access to the substance group will immediately give you the possibility to begin discussions about data sharing and agreeing the contents of the joint submission.
If you intend to update the tonnage band of a grandfathered substance you can currently use the ‘update’ button in the “Comply with UK REACH” service. To stay compliant it is important to also request an invoice and pay the respective fee. The deadline for the full information requirements will then automatically become relevant for the new tonnage band.
Very encouraging: While UK REACH is still in its infancy, the British authorities are open to feedback and do their best to support stakeholders.