REACH Registration
The duty that sits behind every REACH conversation.
Two documents, and a lot of underlying data.
Producing a dossier is fundamentally a data exercise: sourcing, evidencing and writing up the information REACH requires for a given substance and tonnage band, in a form ECHA or HSE will accept.
You rarely register a substance alone.
Registrants of the same substance are required to submit certain data jointly, through one lead registrant, rather than each generating and submitting it separately. That shared data is usually managed through a consortium of the substance’s registrants, or accessed individually through a Letter of Access.
Buying a Letter of Access lets you reference the lead registrant’s data without joining the consortium or gaining ownership of it, and is typically the lower-cost route. Full consortium membership costs more but usually gives a greater say in how the substance’s data and testing strategy are managed going forward.
Registering with ECHA does not register you with HSE, or the other way round.
This trips up more organisations than almost anything else in REACH: an existing EU registration gives no standing under UK REACH, and vice versa. If you place a substance on both markets, you need a registration position in both, on each regime’s own terms and timetable.
“Someone else handles that” is the most expensive assumption in REACH.
“We just buy it in — our supplier handles REACH.” That assumption is one of the most common and most costly mistakes we see. If your supplier is based outside the UK or EU market you are selling into, REACH treats you, not them, as the importer, with the same registration duty as if you had manufactured the substance yourself.
Who counts as the importer is not always obvious either: it typically comes down to who places the order, who takes ownership of the goods, and who is named on the customs declaration, rather than who happens to be paying the invoice. A non-UK or non-EU manufacturer can appoint an Only Representative established in the relevant market to register on their behalf — and where that happens, their customers are treated as downstream users instead of importers. Without that arrangement in place, the registration duty defaults to whoever is doing the importing.
Neither the dates nor the costs are the same across regimes.
Both deadlines and fee schedules move independently in each regime, so a position that was current for one recently can be out of date for the other.
Turning a registration duty into a managed, funded programme.
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