Grandfathering under UK-REACH
GB-based registrants of ethanol, fusel oil or vinasses that intend to grandfather a substance registration under UK-REACH need to submit data to HSE (using “Comply with UK-REACH”) about the substance they intend to register. No hazard data is required to be submitted at this point, as the arrangements for use of data for registration in the UK post-Brexit are still pending.
The information required is as follows:
- 1.1 (Substance ID, Contact information, Legal Entity)
- 1.2 (Composition/substance ID)
- 1.3 (registration number)
- 1.4 (analytical – Article 10 (a) (ii))
- 3.2 (estimated quantities)
- 3.5 (manufacture and uses) delete information regarding any uses not applicable to the UK REACH registrant
A good approach to submit this information to HSE is to prepare a new dossier in IUCLID6 using the co-registrant template (REACH Member of a Joint Submission General Case); do not add the CSR, and tick the boxes indicating that the CSR and guidance on safe use are provided by the lead registrant.
The IUCLID templates for co-registration are available in the following links (available to registered members only; if you have difficulty logging in please contact the secretariat):
* The updated dossier for Vinasses B1 is available upon request from the secretariat