UK REACH: where things stand
The UK Government opened the latest technical consultation on UK REACH draft legislation, on 29 September 2026. While the consultation is open for comment until 10 November, Defra are seeking comments only on whether the draft legal text is robust and practical for implementation. Amendments to the details are expected to be limited, and the draft legislation is likely to be laid before Parliament relatively intact in the first half of 2027.
While UK REACH registration deadlines for substances already on the UK market under the transitional arrangements start in October 2029, the UK chemicals industry must already comply with certain UK REACH requirements. The draft legislation sets out the intended requirements for future transitional substance registrations, but there are obligations that apply today. Those obligations also depend on where in the UK a company operates.
How UK REACH came about
When the UK left the European Union at the end of 2020, most of the country also left EU chemicals regulation. Northern Ireland (NI) was the exception: under the Northern Ireland Protocol and confirmed later in the Windsor Framework, NI continues to operate under EU REACH. EU REACH is a broad and complex system designed to protect human health and the environment. The UK helped to shape and implement it, and from 2007 it influenced UK chemicals policy alongside that of our continental European neighbours.
For a high-value industry, built on complex supply chains and low-friction borders, the cost and demands of EU REACH were broadly balanced by access to the EU-27 market. In Great Britain, that calculation changed on 1st January 2021, when UK REACH arrived.
Against the deal-or-no-deal politics of late 2020, UK REACH began largely as a copy of EU REACH. In practice, it moved registration onto a new UK timetable and created a domestic administrative system. The first deadlines – for the highest-hazard substances in the highest tonnage bands- were set for October 2023.
It quickly became clear that repeating 13 years of EU work for a much smaller market would be expensive, and that the original timetable was simply too tight. The Government agreed delays while industry capacity and regulatory resources were reconsidered. The UK Authorities looked for a workable balance between regulatory cost and legitimate public expectations.
The Government proposed the Alternative Transitional REACH model (ATRm) which was announced in a public consultation in 2024. This proposed to reduce the hazard data required for those substances already EU-REACH registered and on the GB market. The Government proposed removing the need to (re)purchase hazard data access at the outset, to reduce the cost of implementation, while still requiring GB-based businesses to take responsibility for and assess the risks from uses of their substances in GB.
Extensions moving registration deadlines to 2029-2031 are now law, but the route to registration – through the ATRm or otherwise – remains unsettled. The transitional model is not yet law and guidance has yet to appear. Hazard summaries may help reduce data-purchase costs, but concerns remain: both GB manufacturers and GB importers will still have to register for UK REACH. Many businesses buying substances or products from EU suppliers could therefore become registrants for the first time, as importers, whether they planned to or not.
The likely consequences are higher costs, extra staffing demands and fewer substances or product choices. Some products may become less effective if financial pressure forces difficult decisions in UK boardrooms. Regulation often starts with an economic cull: suppliers withdraw first from small, specialist markets. Yet those markets can be important to human health or future economic growth.
Where UK REACH applies
Despite its name, UK REACH does not apply across the whole United Kingdom. Businesses in Northern Ireland continue to follow EU REACH under the Northern Ireland Protocol and confirmed by the Windsor Framework. UK REACH applies in England, Scotland, Wales and their associated islands – the territory referred to as Great Britain (GB).
The legal technicalities of UK REACH registration may not yet be law, but chemicals compliance is not an open field. A company’s present and potential responsibilities depend on where it sits in the supply chain.
Grandfathered registrations
GB-based companies that had paid a registration fee and held an active EU REACH registration for a substance before 31st December 2020 could effectively reclaim their EU REACH registration known as “grandfathering”, directly into UK REACH. They did so by supplying limited information through the UK online portal, “Comply with UK REACH”.
UK REACH recognises just over 4,000 grandfathered substances. Defra first published the list in 2021; it is available here:
These registrations are not considered complete because no hazard data were transferred with them. Once the final UK REACH deadlines and requirements are agreed, further work will be needed. Companies that have grandfathered – or later register – the same substance are placed in a substance group, allowing them to communicate about the registration.
Businesses that grandfathered substances were generally already acting as importers or GB-based manufacturers before 1st January 2021. UK-based Only Representatives could keep registrations through grandfathering too, but they could also transfer them to an EU-26 business or legal entity and also preserve the EU REACH registration. There was no equivalent route for EU-26 registrants wanting to continue in GB.
Downstream User Import Notifications (DUINs)
UK REACH had no “pre-registration” phase; it was judged unnecessary because EU REACH registration of existing substances had already been completed before GB left the EU.
Some GB-based Downstream Users became importers after exit and could therefore become UK REACH registrants. A business that bought and imported a substance from the EU in 2018, 2019 or 2020 had to identify itself by opening an account on “Comply with UK REACH” and obtaining a Downstream User Import Notification (DUIN) number. It then sent that number and its Legal Entity Name to the UK HSE using a DUIN spreadsheet, with the option to add limited information about the substances imported. A DUIN carried no commitment to register a substance, and there was no fee.
The original DUIN deadline was 27th October 2021. By the end of that month, Defra had recorded 5,354 submissions. That is the number of legal entities that obtained a DUIN number and returned the template – not the number of substances covered. No official substance list has been published, probably because only limited substance-specific information was compulsory although each substance on a DUIN should have been linked to an EU joint registration. Technically, even now, the DUIN process remains open to eligible GB-based businesses that did not complete their declaration before GB left the EU. However proof of pre-2021 sales into GB will be required.
Comply with UK REACH
“Comply with UK REACH” is the Government portal for claiming grandfathered registrations, opening Downstream User accounts, obtaining DUIN numbers and submitting registration dossiers. Think of it as the UK counterpart to EU REACH-IT. Businesses must provide certain legal-entity details to open an account.
Link: https://www.hse.gov.uk/reach/using-comply-with-uk-reach.htm
New Registration of Existing Substances (NRES)
Chemical markets and supply chains do not stand still. To avoid freezing the market as it looked at the end of EU membership, UK authorities created the New Registration of Existing Substances (NRES) process under Article 26 of UK REACH. This process caters for businesses that began importing or manufacturing a substance in GB that already existed on the EU market, but that they had not themselves imported or manufactured before 1st January 2021. NRES involves a limited submission to the UK HSE through “Comply with UK REACH”. Because it contains no hazard data, the dossier is treated as a temporary incomplete transitional registration. UK REACH fees still apply, although the good news is that they were significantly reduced on 1st April 2025.
Link: https://www.hse.gov.uk/reach/fees-and-charges-table.htm
After paying the fee, the registrant receives a UK REACH registration number and joins the relevant substance group, where details of other registrants for that substance can be viewed through the “Comply with UK REACH” account.
For a GB business that holds a DUIN for a business-critical substance but does not know what its supplier plans to do, NRES can provide useful certainty at a relatively modest immediate cost. It lets the company import in its own right rather than remain tied to one supplier.
New substances
A substance that is new to the GB market, was not on the EU market before 1st January 2021, and is manufactured or imported above one tonne a year will need a full registration before it enters the GB market. The data for the relevant tonnage band must be submitted at the same time. If access to both markets is planned, developing the EU and UK dossiers together may be sensible. Other routes may be available for substances still in development, including a Process-oriented Research and Development dossier (PPORD).
Choosing the right route
There is no one-size-fits-all answer. ACRE can help you weigh the available UK REACH routes and choose the most practical option. Contact us to discuss your position. We also provide Only Representative services for manufacturers and formulators outside the UK seeking access to the GB market as well as for Non-EU and GB businesses looking to access the EU.
About the author
Dr Craig Kelly, Director, Senior Consultant: Craig brings his long experience of working in both EU and UK REACH to assist our clients with their decisions, and also includes consortium support. He also brings his expertise in toxicology and ecotoxicology to support clients with technical aspects of their regulatory projects. This includes dossier updates, study quality and technical review, and preparing endpoint summaries and testing plans.
FAQs
Does UK REACH apply across the whole UK?
No. Northern Ireland continues to operate under EU REACH as agreed via the Windsor Framework. UK REACH applies only in Great Britain: England, Scotland and Wales.
What happened to my EU REACH registration after Brexit?
If you were GB-based and held an active EU REACH registration for a substance before 31 December 2020, you could transfer it into UK REACH by “grandfathering” it through the Comply with UK REACH portal. Just over 4F,000 substances have been grandfathered this way.
Is a grandfathered registration a finished registration?
No. No hazard data transferred with it, so once the final UK REACH deadlines and requirements are agreed, further work will be needed.
What is a DUIN, and do I need one?
A Downstream User Import Notification applies to GB businesses that imported a substance from the EU in 2018, 2019 or 2020 and became importers after exit. There’s no fee and no commitment to register attached to it. The original deadline was October 2021, but the process technically remains open to eligible businesses that haven’t yet completed it.
What is NRES, and when does it apply?
New Registration of Existing Substances applies when you start importing or manufacturing a substance in GB that already existed on the EU market, but that you personally hadn’t imported or manufactured before 1 January 2021. Fees apply, reduced since 1 April 2025.
What if my substance is genuinely new to the GB market?
If it wasn’t on the EU market before 1 January 2021 and you’re manufacturing or importing above one tonne a year, you’ll need a full registration, with hazard data for the relevant tonnage band submitted alongside it.
