United Kingdom: two consultations concluded, updates coming on UK REACH and GB CLP

The Department for Environment, Food & Rural Affairs has published the outcome of the consultation “UK REACH: Extending dossier submission deadlines for transitional registrations”, with summary of responses and government response. The consultation lasted for 8 weeks and closed on 8 September 2025.

Why it is relevant

UK REACH, in force in Great Britain since 31 December 2020, requires that all substances manufactured or imported into the territory be registered with the Health and Safety Executive (HSE), which acts as the competent authority for UK REACH. The data provided during registration is essential not only for identifying the hazards, uses and exposure modes of chemical substances, but also to allow the regulator — namely the HSE itself — to fulfil its control and supervisory role. It should be remembered that the European REACH regulation continues to apply exclusively in Northern Ireland.

Current deadlines (art. 127P UK REACH) and consulted options

The document summarises that, according to Article 127P UK REACH, the three deadlines currently in force are 27 October 2026, 27 October 2028 and 27 October 2030, differentiated according to tonnage and the hazard profile of the substances (such as inclusion in the Candidate List, CMR classification, high aquatic toxicity and thresholds of 100/1000 tpa); Defra then solicited opinions on three possible extension options, in addition to keeping the current deadlines (“do nothing”):

Option 1: 27 October 2029 / 27 October 2030 / 27 October 2031 (gap of 1 year)
Option 2: 27 April 2029 / 27 April 2031 / 27 April 2033 (gap of 2 years)
Option 3: 27 April 2029 / 27 April 2030 / 27 April 2031 (gap of 1 year)

A total of 210 responses were collected (200 via the portal and 10 by email). The majority of participants expressed as their first preference option 2, while option 1 was often indicated as the second choice; the option to keep the current deadlines (“do nothing”) was widely rejected.

Despite the numerical majority in favour of option 2, the Government considered option 1 the most balanced solution. Consequently, it announces (subject to the necessary consent of Scottish and Welsh ministers) its intention to legislate in 2026 to postpone the deadlines to 27 October 2029 / 27 October 2030 / 27 October 2031.

In parallel, the Health and Safety Executive (HSE) has published its own response to the consultation on “Chemicals Legislative Reform Proposals”, held from 23 June 2025 to 18 August 2025.

The consultation concerned several regulatory areas - including BPR, CLP, PIC and others - but below is a summary of the main proposals relating to GB CLP, with particular attention to the possible consequences for companies operating in Northern Ireland (NI), where the EU regime continues to apply.

The four proposals to amend GB CLP (in summary)

Proposal 1 – Review of procedures for harmonised classifications (Articles 37 and 37A)

HSE proposes to amend the current procedures for adopting harmonised classifications, eliminating the obligation to automatically consider all opinions adopted by the Committee for Risk Assessment (RAC) of ECHA.

In essence, the United Kingdom intends to assess harmonised classifications autonomously, while retaining the possibility of relying on decisions already adopted in other jurisdictions.

Strict obligations would nevertheless remain fully applicable for the most serious hazard classes, such as carcinogenic, mutagenic, reproductive toxic (CMR) substances or respiratory sensitisers.

Proposal 2 – Elimination of the national GB database and the obligation to notify classifications

The proposal provides for the abolition of the British notification database and the obligation for companies to notify the classifications of substances.

Many operators welcomed the reduction in administrative burdens; others expressed concern about the possible loss of information available to the authorities.

However, HSE considers that the obligation is largely duplicative and ineffective, given that information on substances is already available through labelling, other regulatory obligations and public databases.

Proposal 3 – Transfer of explanatory notes on harmonised classifications to the HSE website

Currently, some explanatory notes relating to harmonised classifications are contained in Annex VI of GB CLP. HSE proposes to transfer them to its institutional website.

The aim is to allow faster updates and greater accessibility. However, some stakeholders stressed the need to ensure clarity and traceability of changes. HSE has assured that it will accompany the change with adequate communication measures.

Proposal 4 – Introduction of a general power to update GB CLP

HSE proposes to introduce a legal basis enabling the British government to amend GB CLP and related regulations more easily.

According to HSE, this tool is necessary to quickly update legislation and adapt it to technical developments or international obligations. Some stakeholders have, however, pointed out the risk that the British system may gradually diverge from that of the European Union, with possible impacts for companies operating in both markets.

The consultation also sought opinions on how to manage two distinct regimes (GB and NI) after changes to EU CLP and in the context of the Windsor Framework. HSE declares its intention to safeguard the UK Internal Market with a more coherent regime between Great Britain and Northern Ireland and foresees that the implementing legislation will be designed to ensure at least 6 months before any labelling changes have impacts in NI and the EU.

Overall, the two outcomes confirm a clear message: regulatory updates will follow the consultations, with an explicit intervention horizon in 2026 for UK REACH (extension of deadlines) and with GB CLP reforms aimed at simplification/operationality and managing GB–NI frictions.

For companies operating on UK/GB markets and (directly or indirectly) in Northern Ireland, it becomes strategic to monitor:

(i) the updated UK REACH calendar (and the alignment of compliance checks),
(ii) the evolution of GB procedures for harmonised classifications and information tools, and
(iii) the transition timing for any labelling requirements in NI.