If your business makes, imports or uses chemicals in Great Britain, UK REACH almost certainly affects you. Since the end of the Brexit transition period, GB has operated its own chemicals regime, separate from EU REACH, and the rules, deadlines and costs have been shifting ever since.
This guide explains who UK REACH applies to, what you must do, and the practical steps to take now.
What is UK REACH?
UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the Great Britain chemicals regulation that took over from EU REACH on 1 January 2021. It is administered by the Health and Safety Executive (HSE) as the UK REACH agency, with policy led by Defra.
Its core principle is “no data, no market“: a substance on the GB market must be registered, and the information needed to use it safely must be available and passed down the supply chain.
Important: UK REACH applies in England, Scotland and Wales. Northern Ireland continues to follow EU REACH under the Windsor Framework, so businesses trading across the UK may need to comply with both systems.
Does REACH apply to your business?
Who needs to comply?
Your obligations depend on your role in the supply chain.
| Role | What it means | Typical obligations |
|---|---|---|
| Manufacturer | You make a substance in GB | Register substances at 1 tonne or more per year; classify and label; supply compliant safety data sheets |
| Importer | You bring a substance, a mixture or an article into GB from outside GB, including from the EU | Register substances at 1 tonne or more per year; meet transitional notification or registration requirements; communicate hazards downstream |
| Downstream user | You use chemicals in your business activities (formulators, manufacturers, industrial and professional users) | Follow the safety data sheet and exposure scenarios; check that suppliers are registered; pass information up and down the chain |
| Distributor / retailer | You store and sell chemicals without changing them | Pass on safety information; check the supply chain is compliant |
| Article producer / importer | You make or import products such as equipment, furniture or textiles | Notify and communicate on SVHCs in articles; check restrictions apply |
Obligations apply per legal entity, so a group with several GB companies needs to assess each one.
The main UK REACH requirements
1. Registration
Manufacturers and importers of substances at 1 tonne or more per year must register them with HSE. Because most businesses could not complete full registrations on day one, the government introduced transitional arrangements:
- Grandfathering: companies that held an EU REACH registration could carry it across to UK REACH.
- Downstream User Import Notification (DUIN): downstream users who had been importing from the EU could notify HSE and keep trading while full registration deadlines run.
- New Registration of Existing Substances (NRES): a route for substances that were not already registered under EU REACH but were on the GB market.
- Inquiry and registration of new substances: substances not previously on the GB market need a full registration before supply.
2. Transitional registration deadlines
The deadlines have been pushed back twice. Defra has been developing an Alternative Transitional Registration model (ATRm) that is intended to reduce data requirements and costs. Because the ATRm could not be legislated before the original first deadline of October 2026, the government extended the submission dates. The revised deadlines are 27 October 2029, 27 October 2030 and 27 October 2031, phased by tonnage and hazard:
- 27 October 2029: the highest tonnage and hazard band (broadly substances at 1,000 tonnes or more per year, and certain highly hazardous substances at lower tonnages)
- 27 October 2030: substances at 100 tonnes or more per year
- 27 October 2031: all other substances at 1 tonne or more per year
Even with extra time, you should not wait. The detailed ATRm information requirements are still being finalised, and data gathering, supplier agreements and cost-sharing take time.
3. Safety data sheets and communication in the supply chain
Suppliers must provide safety data sheets (SDS) that meet UK REACH requirements, and downstream users must apply the advice in them. Make sure your SDSs carry the correct GB details and that you have a process to update them when information changes. Where substances of very high concern (SVHCs) are present in articles above the threshold concentration, you must pass on information so the articles can be used safely.
4. Restrictions
Annex 17 of UK REACH lists substances and uses that are restricted or banned. If you manufacture, supply or use a restricted substance, you need to confirm that your use is permitted and that any conditions are met. Restrictions can apply to substances on their own, in mixtures and in articles.
5. Authorisation
Substances of very high concern can be added to the Authorisation List (Annex 14), after which they cannot be used or placed on the GB market without authorisation. Watch the UK REACH Candidate List and the Authorisation List and check whether any of your substances are listed.
6. Classification and labelling
UK REACH works alongside GB CLP, which governs the classification, labelling and packaging of hazardous chemicals. Suppliers must classify and label correctly, and use the GB mandatory classifications where they apply.
Practical steps to get compliant
- Map your chemicals. List every substance and mixture you make, import or use, with volumes and suppliers.
- Confirm your role. Identify whether you are a manufacturer, importer, downstream user, distributor or article producer for each substance.
- Check your supply chain. Ask suppliers whether they hold a UK REACH registration or notification, and get confirmation in writing.
- Review your transitional status. Establish whether you have a grandfathered registration, a DUIN, an NRES submission or nothing at all.
- Check tonnage bands and deadlines. Work out which deadline applies to each substance and plan backwards from it.
- Review safety data sheets. Check they are current and meet UK requirements.
- Screen for restrictions and SVHCs. Check your substances and products against Annex 17 and the Candidate and Authorisation Lists.
- Assign responsibility and keep records. Name an owner for UK REACH, and keep evidence of your assessments and supplier correspondence.
- Monitor developments. Follow HSE and Defra updates on the ATRm, fees and deadlines.
What happens if you do not comply?
Supplying or using chemicals in breach of UK REACH can lead to enforcement action by regulators, including notices and prosecution, as well as commercial risk. Non-compliant supply chains can lose market access, and customers increasingly require evidence of regulatory compliance.
Frequently asked questions
Does UK REACH apply if I only import from the EU? Yes. Since 1 January 2021, substances imported from the EU into GB are treated as imports and can carry registration or notification duties.
Does UK REACH apply in Northern Ireland? No. Northern Ireland follows EU REACH under the Windsor Framework, although businesses moving goods between NI and GB may face obligations under both regimes.
Do small businesses need to comply? Yes. There is no general exemption for small businesses, although the 1 tonne per year threshold means many smaller businesses fall into the downstream user category rather than registrant.
Have the deadlines changed? Yes. The transitional registration deadlines were extended to 27 October 2029, 2030 and 2031. Check the current position with HSE or Defra before making decisions.
How we can help
UK REACH sits alongside COSHH, GB CLP and your wider health, safety and environmental duties. We can help you map relevant legislation for your business and compile a legal register. The register will also include details of how your business must comply with each piece of legislation.
Contact us to discuss your legal register requirements.
This article is for general information only and is not legal advice. Regulations and deadlines change, so confirm the current position with HSE, Defra or a qualified adviser.
