2021年7月22日起，UK REACH注册人可通过IT系统“Comply with UK REACH”标记主要注册人身份。

注册人或通过“查询”加入“物质组”（类似于欧盟REACH的SIEF）的潜在注册人，在征得其他成员同意后，可上传主要注册人卷宗并标记主要注册人身份。若您是欧盟REACH下的数据持有人或主要注册人，且有意向成为UK REACH主要注册人的话，建议尽快标记以确保主要注册人的身份。

此外，距离DUIN通报截止期只有不到3个月了，Aplus提醒相关企业，尽快完成DUIN通报以维持英国化学品市场合规贸易。若不符合DUIN通报条件，只要您的物质在欧盟REACH下有被任何一家企业注册过，那么您也可以在UK REACH下享受暂时的“0数据”正式注册通道并获得注册号，然后在相应的截止期内购买数据加入联合提交即可。

更多详情可参见：https://www.hse.gov.uk/reach/lead-registrant.htm

Lead registrants in UK REACH

UK REACH retains the 'one substance, one registration' principle. If there is more than one registrant for a substance, co-registrants should agree between themselves who the 'lead registrant' will be.

Main responsibilities of lead registrants

The lead registrant is the lead contact for substance registration with HSE ('the Agency'). They will 'claim the lead' for the substance and are responsible for submitting a lead joint registration dossier containing the relevant Article 10 information, using the 'Comply with UK REACH' service. They should claim the lead within the service once the dossier is ready to be submitted.

This also applies where an on-site or transported isolated intermediate is manufactured or imported by more than one manufacturer or importer respectively.

The co-registrants should also submit their own company-specific information after the submission of the joint dossier.

The lead registrant is responsible for approving members into the joint registration group in 'Comply with UK REACH'. This links their company-specific dossier to the lead dossier.

Other responsibilities

On request, and where sharing of cost for data has been agreed in a fair, transparent and non-discriminatory way, the lead registrant should also share the data from the joint dossier with potential new registrants. Potential new registrants to the joint submission must make a request for data on animal testing.

Co-registrants may agree that the lead registrant should also submit:

guidance on safe use

the chemical safety report for substances manufactured/imported in quantities of 10 tonnes or more per year

an indication that the relevant information has been reviewed by an assessor chosen by the registrant and with relevant experience

If co-registrants ask for jointly submitted data to be treated as confidential, the lead registrant should request this.

Withdrawal

If the lead registrant wants to withdraw, they should work with the co-registrants to agree a successor. The lead registrant status can be transferred to the successor by the existing lead registrant within the 'Comply with UK REACH' service.

Disputes

There may be a dispute about who should be the lead registrant or co-registrants may feel the lead registrant is not fulfilling their responsibilities. The co-registrants should try to resolve any concerns within their group and with the lead registrant first. The lead registrant can only hold the position with the agreement of their co-registrants.