Background of UK REACH

The UK Registration, Evaluation, Authorisation and Restriction of Chemicals (UK REACH) Regulation came into effect on 1 January 2021 following the end of the Brexit transition period. UK REACH was created by retaining the EU REACH Regulation in UK law, with amendments to make it operable in Great Britain. UK REACH regulates chemicals placed on the market in Great Britain (i.e. England, Scotland, and Wales), while EU REACH continues to apply in Northern Ireland under the terms of the Northern Ireland Protocol. It includes transitional arrangements for companies that previously relied on EU REACH registrations to access the GB market.  

UK-REACH applies to the majority of chemical substances manufactured in or imported into Great Britain. This includes substances on their own, substances in mixtures or substances contained in articles. Manufacturer and importers are generally required to register substances manufactured or imported in quantities of 1 tonne or more per year. Companies are responsible for identifying and managing the risks associated with the substances they manufacture, import or use and for communicating information on safe use through the supply chain.

Authority

The Health and Safety Executive (HSE) acts as the Agency for UK REACH and carries out the main technical and regulatory functions under the Regulation, including managing registrations and other regulatory processes. The Department for Environment, Food and Rural Affairs (Defra) is the lead UK government department responsible for UK REACH policy.

How does UK REACH work?

UK REACH is based on four main regulatory processes:

• Registration: Manufacturers and importers must generally register substances manufactured or imported at 1 tonne or more per year and provide information on their properties, uses and safe handling.
• Evaluation: HSE may evaluate registration dossiers and substances to assess whether further information is required and whether risks are adequately controlled.
• Authorisation: Certain substances of very high concern (SVHCs) may be included in the UK REACH Authorisation List. Once a substance is subject to authorisation, it generally cannot be used or placed on the market for a use after the applicable sunset date unless that use has been authorised or an exemption applies.
• Restriction: UK REACH can restrict or prohibit the manufacture, placing on the market or use of substances where an unacceptable risk to human health or the environment needs to be addressed.

Who Must Register?

Compliance obligations under UK REACH depend on a company’s role in the supply chain.

Manufacturers and Importers: UK REACH registration obligations generally apply to GB manufacturers and importers of substances on their own or in mixtures in quantities of 1 tonne or more per year. Registration may also be required for substances in articles where the substance is present in quantities totalling more than one tonne per producer or importer per year and is intended to be released under normal or reasonably foreseeable conditions of use. Importers include companies bringing substances into Great Britain from the EU, EEA, Northern Ireland or the rest of the world.

Only Representative: A manufacturer, formulator or article producer established outside Great Britain may appoint an Only Representative (OR) established in Great Britain to fulfil the obligations of importers under UK REACH. In this case, the GB importers covered by the OR are regarded as downstream users and do not need to register the imports covered by the OR. The OR must have sufficient background in the practical handling of substances and the information related to them. A company that purchases a substance directly from a supplier outside Great Britain is considered an importer rather than a downstream user.

Downstream Users: A downstream user is a company or individual established in Great Britain that uses a substance, either on its own or in a mixture, in the course of its industrial or professional activities but is not the manufacturer or importer of that substance. Downstream users do not generally have registration obligations but must comply with other applicable UK REACH requirements.

Exemptions under UK REACH

Certain substances and uses are specifically excluded from UK REACH. These include:

• Radioactive substances
• Substances under customs supervision
• Non-isolated intermediates
• Waste
• Some naturally occurring low-hazard substances

Other substances covered by more specific legislation are subject to tailored provisions under UK REACH. These include:

• Human and veterinary medicines
• Food and foodstuff additives
• Plant protection products and biocides
• Isolated intermediates
• Substances used for research and development.

Transitional Provisions

Before the end of the Brexit transition period, GB companies importing substances from the EU/EEA could rely on an EU REACH registration held further up the supply chain and were generally considered downstream users. From 1 January 2021, these companies became importers under UK REACH and therefore became responsible for ensuring that the substances they import are covered by a valid UK REACH registration.

UK REACH introduced transitional provisions to allow companies and existing supply chains to transition from EU REACH to UK REACH. These included the grandfathering of eligible EU REACH registrations, Downstream User Import Notifications (DUINs) and New Registration of an Existing Substance (NRES).

 Grandfathering: When UK REACH took effect, eligible GB-based holders of EU REACH registrations were able to have their existing registrations recognised under UK REACH. This transitional arrangement is known as grandfathering. The original deadline for submitting the initial information required to grandfather a registration was 30 April 2021. However, eligible companies that missed this deadline can still submit the required information and should do so as soon as possible. Companies using the grandfathering provisions must submit the information required for full UK REACH registration by the applicable transitional registration deadline.

Downstream User Import Notification (DUIN): GB-based companies that were downstream users or distributors under EU REACH in the two years before 1 January 2021 and continued importing the relevant substances into Great Britain may use the DUIN provisions. This also applies to certain GB importers that were regarded as downstream users under EU REACH because their non-EU supplier had appointed an EU-based Only Representative (OR). A DUIN allows the registration obligation to be deferred until the applicable transitional registration deadline.

Non-GB manufacturers, formulators and article producers may appoint a GB-based OR to submit a DUIN on behalf of eligible GB importers. However, the GB importer must itself meet the DUIN eligibility requirements.

The original deadline for submitting a DUIN was 27 October 2021. However, eligible companies that missed this deadline can still submit a notification and should do so as soon as possible.

New Registration of an Existing Substance (NRES): A new UK REACH registration for a substance that was already registered under EU REACH before 1 January 2021 is referred to as a New Registration of an Existing Substance (NRES). A full UK REACH registration is required, although submission of the full information requirements may be deferred until the applicable transitional registration deadline.

Transitional Registration Deadlines

The deadline for submitting the full information required under the UK REACH transitional arrangements depends on the tonnage and/or hazard profile of the substance. The transitional registration deadlines were most recently extended in 2026 to allow additional time for the development and implementation of the Alternative Transitional Registration model (ATRm). The current deadlines are 27 October 2029, 27 October 2030 and 27 October 2031.

The applicable deadline for each tonnage band and hazard category is shown in the table below.

Substances Not Previously Registered under EU REACH

For substances that were not registered under EU REACH before 1 January 2021, the transitional provisions do not apply. A full UK REACH registration must be completed before manufacture or import into GB reaches 1 tonne per year. The information requirements for the applicable tonnage band must be fulfilled in full before the registration is granted, taking into account any applicable data waivers.

UK REACH Registration Process

There are no provisions for pre-registration under UK REACH, and pre-registrations previously submitted to ECHA under EU REACH are no longer valid in Great Britain.

The first step for a new registration under UK REACH is to submit an Article 26 inquiry to the HSE. The inquiry dossier is prepared in IUCLID and contains information about the company and the substance it intends to manufacture or import into Great Britain.

Once the inquiry has been successfully completed, HSE provides the registrant with an inquiry number and facilitates contact with existing registrants and other successful inquirers for the same substance. This enables potential registrants to begin the data-sharing process.

The next step is the registration itself. Where there is more than one registrant for a substance, registrations are generally submitted jointly in accordance with the ‘one substance, one registration’ principle retained from EU REACH. Each legal entity must nevertheless submit its own registration dossier. Co-registrants must agree on a lead registrant, who submits the joint information on behalf of the group.

Registration dossiers are prepared using IUCLID and submitted to HSE through the Comply with UK REACH service. The process and information requirements for preparing a registration dossier are the same as under EU REACH.

Fees

A revised UK REACH registration fee structure took effect on 1 April 2025. One of the most significant changes was the removal of tonnage bands, meaning that a flat registration fee now applies regardless of the tonnage of a substance. In addition, the same fee applies to both individual and joint registrations. Reduced fees continue to be available for micro, small and medium-sized enterprises (SMEs). The current fees for full registration under UK REACH are shown in the table below.

To qualify for the reduced fees, companies must meet the applicable SME criteria based on headcount and either annual turnover or annual balance sheet total. The criteria for medium, small and micro enterprises are shown in the table below.