UK REACH: extension of transitional registration deadlines

After Brexit, from 31 December 2020, the United Kingdom adopted the UK REACH regulation for the management of chemical substances in Great Britain, while EU REACH remains valid only in Northern Ireland. UK companies that had already registered substances under EU REACH must now also register them under UK REACH to continue operating legally.

The registration deadlines were initially set as a single date (October 2021), then, following various changes, split into several phases (2023, 2025, 2027) based on tonnage and substance risk. However, due to difficulties reported by businesses, the government has already postponed some deadlines and is working on a new registration model (ATRm) to make the system more sustainable.

The public consultation took place between 14 July and 8 September 2025, aiming to gather opinions on a possible further extension of the deadlines (proposed up to 2033), assessing the impact on businesses, health and environmental protection, and competitiveness. In addition, feedback was requested on aligning compliance checks with the new timelines. In this regard, the involvement of companies, associations, consultants, and NGOs provided a broad overview of the needs and expectations of the chemical sector regarding the evolution of post-Brexit regulations.

The consultation proposed four options:

• Maintain the current deadlines (27 October 2026, 2028, 2030)
• Option 1: postpone the first deadline by 3 years and apply one-year intervals between the following ones (27 October 2029, 2030, 2031)
• Option 2: postpone all deadlines by 2.5 years, maintaining two-year intervals (27 April 2029, 2031, 2033)
• Option 3: postpone the first deadline by 2.5 years, with one-year intervals (27 April 2029, 2030, 2031)

The consultation collected 210 responses from a wide range of stakeholders: large companies, SMEs, industry associations, consultants, and NGOs. The majority expressed a clear preference for Option 2 (70% as first choice), followed by Option 1 (23%). The option not to change the deadlines was strongly rejected (98% ranked it last).

The main reasons in favor of the extension were:

• More time to prepare high-quality dossiers, avoiding rushed and incomplete submissions.
• The ability to spread costs over time, especially important for SMEs and micro-enterprises.
• The need for clarification on the new ATRm model, still under development.
• Concerns about data duplication between UK and EU REACH, with requests for mutual recognition or data-sharing mechanisms to reduce costs and administrative burdens.
• Impact on competitiveness and supply chains, with the risk of trade barriers due to regulatory divergence between the UK and the EU.

NGOs, on the other hand, stressed the need not to excessively prolong the timelines, to avoid gaps in the availability of safety data and to ensure the protection of health and the environment.

Despite the strong support for Option 2, the UK government decided to adopt Option 1 as the most balanced solution. This choice allows the new ATRm model to be finalized and legislated before obligations begin, giving more time to prepare dossiers for the most hazardous and highest tonnage substances, without excessively delaying the implementation of the UK REACH system.

The new deadlines will therefore be:

• 27 October 2029
• 27 October 2030
• 27 October 2031

Furthermore, the dates for compliance checks will be aligned with the new dossier submission deadlines, to ensure that checks are carried out on complete and up-to-date data.

The new deadlines for submitting registration dossiers are differentiated according to the type of substance and the annual quantity imported or produced, in line with what has already been established previously.

Here is the updated breakdown:

27 October 2029

• Substances included in the EU REACH or UK REACH Candidate List before 31 December 2023.
• Carcinogenic, mutagenic, or toxic for reproduction (CMR) substances, produced or imported in quantities equal to or greater than 1 tonne/year per manufacturer or importer.
• Substances very toxic to the aquatic environment, produced or imported in quantities equal to or greater than 100 tonnes/year.
• All substances produced or imported in quantities equal to or greater than 1,000 tonnes/year.

27 October 2030

• Substances added to the UK REACH Candidate List between 1 January 2024 and 27 October 2026.
• All substances produced or imported in quantities equal to or greater than 100 tonnes/year per manufacturer or importer.

27 October 2031

• All other substances produced or imported in quantities equal to or greater than 1 tonne/year per manufacturer or importer.

Note:This breakdown prioritizes the most hazardous and/or highest tonnage substances, ensuring that those with the greatest potential impact on health and the environment are registered first. Companies should carefully check which category their substances fall into to plan compliance accordingly.

The consultation highlighted a strong demand for greater clarity, proportionality, and support for businesses, especially SMEs. The government is committed to providing guidelines and practical tools to facilitate the transition, maintaining a focus on the most hazardous substances and ensuring the protection of health and the environment.

For those operating in the chemical sector, both in the UK and abroad, it is essential to monitor regulatory developments and prepare for the new deadlines, assessing the impact on their activities, suppliers, and customers.