Jul 312025

UK proposes to extend transitional chemical registration deadlines under UK REACH

Maria Isabel Manley and Victoria Kerr
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GB based Chemical manufacturers or importers that relied on EU REACH registrations to continue marketing their products in Great Britain following Brexit have until 8 September 2025 to respond to a UK Government consultation on proposed revised transitional registration deadlines under UK REACH. Marie Manley and Victoria Kerr explain the background to the consultation, and why stakeholders should consider engaging with it.

The Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH) is the main legislation for the regulation of chemicals in the EU and requires chemical substances that are manufactured in or imported into the EEA to be registered with the European Chemicals Agency. Following the UK’s departure from the EU, the UK put in place a separate “UK REACH” Regime in Great Britain (GB) that closely mirrors the EU system, with the UK’s Health and Safety Executive (HSE) serving as the UK REACH Competent Agency.

As in the EU, UK REACH requires that information concerning substances manufactured in or imported into GB at a level of at least one tonne per annum must be compiled into a dossier and submitted to the HSE for registration. Such information includes the identity and physicochemical characteristics of each substance with information about their hazards, uses and the exposures that can occur to people and the environment.

Transitional UK REACH registration provisions

With the aim of minimising disruption and providing continuity for businesses, the UK Government introduced the following transitional registration provisions for EU REACH registration holders based in GB:

  • Companies that previously registered substances under EU REACH could “grandfather” their registrations into UK REACH by submitting initial preliminary information to the HSE. However, full information will still need to be submitted by 27 October 2026, 27 October 2028, or 27 October 2030, depending on tonnage band and hazard profile.
  • Importers of substances that relied on EU REACH authorisations held by the EU or EEA entities could continue to use the substance using a Downstream User Import Notification (DUIN) by a certain date. However, they would still have to submit a new registration to the HSE by 27 October 2026, 27 October 2028, or 27 October 2030, depending on tonnage band and hazard profile of the substance.

An Alternative Transitional Registration Model

The life sciences industry has raised concerns about the significant cost to companies of buying or accessing the EU hazard data required to support these transitional registrations. Indeed, it is estimated that the cost to businesses could reach up to £2 billion by 2030. Such financial burden could potentially result in companies not registering their substances thereby leading to reduced availability of chemical substances on the GB market.

In response to these concerns, the UK Government is currently considering an alternative transitional registration model (ATRm), the aim of which is to “uphold existing human health and environmental protections (by gaining better information on the use and exposure of substances in Great Britain (England, Scotland and Wales)), while reducing costs to businesses transitioning from EU REACH to UK REACH.” In particular, ATRm policy proposals include:

  • A proposal to significantly reduce the hazard information provided in registrations for transitional substances.
  • A proposal to enhance what information on ‘use and exposure’ registrants in GB need to provide in registrations.
  • A proposal for reduced hazard requirements in Chemical Safety Reports carried out by all registrants of a transitional substance manufactured or imported in quantities of over 10 tonnes per annum.

A first consultation inviting members of the life sciences industry to provide their views on these proposals was issued by the Government in 2024 and responses are currently under consideration.

Proposal to extend transitional registration deadlines

As the detailed design of the ATRm is still under review by the UK Government, it is now clear that the necessary legislative changes cannot be delivered in time to implement the ATRm before the current first registration deadline in October 2026. The Government has therefore deemed it necessary to consult on the following revised transitional submission deadlines:

  • Option 1: October 2029, October 2030, and October 2031.
  • Option 2: April 2029, April 2031, and April 2033.
  • Option 3: April 2029, April 2030, and April 2031.

The consultation was launched on 14 July 2025 and provides businesses with an opportunity to express their views on the proposed deadlines, amongst other, by 8 September 2025. According to the Government, “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.”

The proposal to extend transitional registration deadlines will be welcomed by the Industry as not only do they allow the Government to finalise a less burdensome ATRm, they also provide additional time for businesses to comply with the transitional provisions.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.

Maria Isabel Manley

London

mmanley@sidley.com

Victoria Kerr

London

vkerr@sidley.com

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