UK REACH Transitional Registration Deadline Consultation

By Susana Planas MunGavin BSc., MSc, senior regulatory specialist, Supply Chain Team, UL Solutions

On July 14, 2025, the Department for Environment, Food and Rural Affairs (DEFRA) launched a public consultation in order to gain stakeholder’s perception and input from industry stakeholders at large on the government’s proposals to extend the UK REACH transitional registration submission deadlines. The public consultation will run until September 8, 2025, any comments must be submitted by this date.  

The existing registration deadlines are currently October 2026, October 2028 and October 2030, each set in accordance with the tonnages and hazard profiles of the substances being placed on the market.

(Image source: Department for Environment & Rural Affairs, Consultation on Extending the UK REACH Transitional Registration Submission Deadlines Publication)

Registrations within Great Britain’s jurisdiction are required under the UK REACH regulatory framework, established under the UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation. UK REACH became effective on January 1, 2021.

All UK REACH registrations are to be submitted to the UK REACH Agency, the Health and Safety Executive (HSE).

Registrations required in Northern Ireland must be submitted to the EU REACH Agency, ECHA, as regulated under the European Union’s Regulation EC/1907/2006 on the registration, evaluation, authorization and restriction of chemicals (EU REACH), the main law protecting human health and the environment from chemical risks at large.

Both UK and EU REACH registrations are mandatory, either with the HSE or ECHA respectively, according to location of the company, for any manufacturer or importer of chemical substances on their own, substances in mixtures and certain cases of substances in articles, which are being placed on the market exceeding the threshold of 1 tonne per year per company.  Only representatives (OR) established in the EU or alternatively, in the UK, and appointed by a manufacturer, formulator, or article producer established within the EU or outside the EU, such as in Great Britain, may also fulfil the registration obligations of importers of substances on their own or in mixtures.

On December 31, 2020, the UK left the European Union, and the UK REACH regulation formally replaced the EU REACH Regulation within Great Britain.  Information on chemicals that were already placed on the GB market at the time when the UK left the EU was not passed on automatically to the HSE.  For this purpose, the UK REACH Alternative Transitional Registration Model (ATRm) was launched to regulate the HSE’s information registration requirements applicable in Great Britain.

UK REACH Regulation exempts chemicals regulated under other specific regulations, such as radioactive substances, medicines, or biocides.

Registration is based on the principle “one substance, one registration.” Thus, allowing for joint registrations to be submitted to the respective authority in the case of manufacturers and importers of the same substance.

This consultation builds on the findings of a previous Government public consultation which was conducted between May 2024 and July 2024, setting out some proposals, which had been developed under the previous government administration, mainly the Department for Food, Environment and Regulatory Affairs (DEFRA), the Health and Safety Executive (HSE) and the Environment Agency (EA).  The public consultation launched on May 1, 2024 is available online at: UK REACH Consultation May 2024 English version.pdf.

The current government, in cooperation with the Devolved governments in Scotland and Wales, is considering the next steps. Given that the detailed design of the ATRm is still under review, the registration information required to be submitted has not yet been specified in time for the first submission deadline in October 2026.

The revised transitional submission deadlines are proposed to provide sufficient time for the government to complete the ATRm registration model and for the industry to comply with the registration information requirements.

The proposed new deadlines under consultation are the following:

• Option 1: October 2029, October 2030, October 2031 for each tonnage band of 1,000 tonnes or more per year, 100 tonnes or more per year or 1 tonne or more per year, respectively.
• Option 2: April 2029, April 2031, April 2033 for each tonnage band of 1,000 tonnes or more per year, 100 tonnes or more per year or 1 tonne or more per year, respectively.
• Option 3: April 2029, April 2030, April 2031 for each tonnage band of 1,000 tonnes or more per year, 100 tonnes or more per year or 1 tonne or more per year, respectively.

Option 1 is the government’s preferred option as it allows time to finalise the design and implementation of the ATRm and provides industry with a transition period of approximately two years.

This consultation also aims to review the government’s proposal to extend the dates for the  HSE to carry out compliance checks on 20 percent of registration dossiers received and submitted by industry, required under Article 41(5) of the UK REACH Regulation.

The full survey of the consultation is available online and responses may be submitted at:

Consultation on Extending the UK REACH Transitional Registration Submission Deadlines - Page 1 of 11 - Defra - Citizen Space

Alternatively, if preferred, comments to the public consultation may be submitted:

By email to: UKREACHextension@defra.gov.uk

Or by post:

UK REACH Legislation and Policy team
Defra Ground Floor, Seacole Building 
2 Marsham Street
London, SW1P 4DF

Recommended action items

• Registration extension deadlines options should be reviewed and relevant feedback and comments submitted to the HSE by September 8, 2025.
• OR should review registration extension deadlines proposed and note the benefit of the extended deadlines to gather registration information from chemical companies concerned.

References

Consultation on Extending the UK REACH Transitional Registration Submission Deadlines - Defra - Citizen Space

UK REACH Consultation on Transitional Registration Deadlines Extension English.pdf

EU REACH Regulation EC/1907/2006