Jul-14-2025
The UK Government has launched a public consultation on proposals to extend the transitional registration submission deadlines under UK REACH further. Published on 14 July 2025 by the Department for Environment, Food & Rural Affairs (Defra), he consultation is open for comments until 8 September 2025.
The current phased deadlines - October 2026, October 2028, and October 2030 - apply to transitional registrations based on the tonnage and hazard profile of the substances. These obligations affect companies placing chemical substances on the market in Great Britain (England, Scotland, and Wales) that were previously registered under EU REACH, but which must now be registered under UK REACH.
Current UK REACH Transitional Registration Deadlines:
Tonnage Band / Substance Type |
Current Deadline |
≥ 1,000 tonnes/year and Carcinogenic, mutagenic or reprotoxic substances (CMRs) ≥ 1 tonne/year Toxic effects to aquatic organisms (acute or chronic) ≥ 100 tonnes/year Candidate list of substances of very high concern (as of 31 December 2023) |
27 October 2026 |
≥ 100 tonnes/year and Candidate list of substances of very high concern (substances added between 1 January 2024 and 27 October 2026) |
27 October 2028 |
≥ 1 tonne/year |
27 October 2030 |
Not the First Extension
This is not the first time that the transitional registration deadlines have been extended. The original deadlines were set for 27 October 2023, 2025, and 2027. However, following stakeholder concerns about the feasibility of timely compliance, the government consulted on postponement options in early 2023. As a result, the deadlines were formally extended by three years via Statutory Instrument 2023/722, which was adopted in July 2023.
More details on that decision are available here and here.
Proposals for Further Delay
As the Alternative Transitional Registration model (ATRm) is still under development, the government is now proposing a second round of deadline extensions. The ATRm is expected to define revised, more proportionate data requirements for transitional registrations. However, the current administration has not yet finalised its implementation, and it is unlikely to be ready in time for the first deadline in 2026.
The consultation presents three options:
Option |
Proposed New Deadlines |
Comment |
Option 1 |
October 2029, October 2030, October 2031 |
Government's preferred option: allows two-year transition after ATRm finalisation |
Option 2 |
April 2029, April 2031, April 2033 |
Longer overall delay, but wider spacing between deadlines |
Option 3 |
April 2029, April 2030, April 2031 |
Shortest total duration; one-year spacing between phases |
Compliance Check Timing Also Under Review
The consultation also seeks views on aligning the HSE’s duty to conduct compliance checks (on 20% of dossiers, as per Article 41(5) of UK REACH) with any revised submission deadlines. This ensures that regulatory oversight keeps pace with the updated registration timeline.
Consultation Access
Stakeholders are encouraged to submit their feedback before 8 September 2025. The consultation can be accessed here.
Jul-11-2025
On 10 July 2025, the UK government published its final decision to restrict the use and placing on the market of lead in ammunition under UK REACH. Adopted by the Department for Environment, Food and Rural Affairs (DEFRA) on 27 June 2025, the restriction aims to address the significant risks posed by lead ammunition to wildlife, the environment, and human health.
Following the restriction dossier prepared by the Health and Safety Executive (HSE) and the Environment Agency, the decision introduces a phased approach to limit the use of lead shot, bullets, and airgun pellets for hunting, sports shooting, and outdoor target shooting.
Scope and Application of the Restriction
The restriction applies to:
Lead shot used in hunting and sports shooting with shotguns.
Lead bullets used for rifle hunting and outdoor target shooting.
Lead used in airgun pellets.
The measures specifically target shooting activities conducted outside licensed ranges. However, certain uses, such as those by the military, the police, and licensed indoor shooting ranges, are exempted from the restriction.
Phased Implementation with Transition Periods
The restriction will be introduced in phases to allow industry and shooters time to adapt:
Lead shot: The ban will take effect after a three-year transition period for most uses.
Lead bullets: The ban comes into force after 5 years for hunting and sports shooting.
Airgun pellets: An 18-year transition period is provided to allow for technical developments.
Derogations are provided in cases where non-lead alternatives are not yet available or practical.
Key Reasons Behind the Restriction
The decision is driven by the well-documented risks associated with lead in ammunition.
Wildlife Impact: Lead poisoning from ammunition affects millions of birds each year, including waterfowl and raptors.
Human Health Risks: Consuming wild game containing lead fragments can expose humans to lead, with vulnerable groups such as children being particularly at risk.
Environmental Harm: Lead residues persist in soils and waterways, causing long-term ecological damage.
The restriction is expected to bring significant health and environmental benefits while balancing the socio-economic impacts on shooting sports and ammunition manufacturers.
Background: UK’s Ongoing Efforts to Address Lead in Ammunition
The adoption of the restriction follows the restriction dossier published in May 2023, which proposed the control of lead in ammunition under UK REACH. This initial proposal set out the scientific and socio-economic assessments that paved the way for this final decision. Further details can be found here.
This reflects the UK’s commitment to environmental protection and the responsible management of hazardous substances.
UK REACH Restriction Now in Force
With the final decision now published, the restriction on lead in ammunition under UK REACH is now legally binding. The phased transition periods allow time for adaptation, but the UK has taken a decisive step to protect public health, wildlife, and the environment from the well-established dangers of lead exposure.
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