UK REACH Deadline Extensions: From Brexit to 2031

UK REACH Deadline Extensions: From Brexit to 2031

Since the introduction of UK REACH following the UK’s exit from the EU, the regulatory framework has continued to evolve.

When UK REACH replaced EU REACH, new registration deadlines were established, following a public consultation,for substances placed on the Great Britain (GB) market under transitional arrangements. These deadlines were set for 2023, 2025 and 2027.

Over time, concerns were raised across industry regarding the deadline feasibility. Key challenges included the cost and practicality of duplicating EU REACH data, constraints on access to existing studies, and the overall scale of the registration effort required. In 2022, in response, the UK government launched a second public consultation to assess whether the existing timelines remained appropriate and to explore alternative approaches.

Following this consultation, the government announced the first postponement of the UK REACH registration deadlines in 2023, formally extending them to 2026, 2028 and 2030. This initial deferral was intended to provide industry with additional time to address data access issues, manage costs, and prepare for compliance while longer-term reforms to the UK REACH system were considered.

When the UK left the EU, chemical data which had been submitted under EU REACH was not transferred to the HSE. These chemical were still being supplied in Great Britain though, so HSE required that companies re-submit data. For this, the government is working on the Alternative Transitional Registration model (ATRm), which will define exactly what information companies must submit for those chemicals. As time has passed and the details of the ATRm are still not agreed, first deadline Oct 2026 was no longer realistic. As such, in July 2025, Defra started a consultation for a second postponement of the UK REACH deadlines.

Consultation options and outcome

The consultation presented four options for consideration:

• Do Nothing: do not change the current submission deadlines: 27 October 2026, 27 October 2028 and 27 October 2030
• Option 1: Moves the first submission deadline back by 3 years and would apply one-year gaps between the subsequent registration deadlines: 27 October 2029, 27 October 2030 and 27 October 2031
• Option 2: Moves the first submissio deadlines back by 2.5 years and would retain the current 2-year gaps between the subsequent registration deadlines: 27 April 2029, 27 April 2031 and 27 April 2033
• Option 3: Moves the first submission deadline back by 2.5 years and would apply 1-year gaps between the subsequent registration deadlines: 27 April 2029, 27 April 2030 and 27 April 2031

The preferred approach among respondents for the consultation was option 2, as it would provide sufficient time for the preparation of registration dossiers while allowing costs and resource demands to be distributed more proportionately across the registration phases. However, the government confirmed that Option 1 would be taken forward.

Government decision and revised deadlines

The government’s decision to adopt Option 1 has been justified on the basis that the requirements under the Alternative Transitional Registration model (ATRm) are expected to be less onerous than those under EU REACH. In addition, option 1 provides industry with more time than Option 2 to prepare and submit information on the most hazardous and highest tonnage substances. The shorter intervals between deadlines are also intended to ensure that regulators receive safety data sooner, thereby supporting the continued protection of human health and the environment.

As a result, the revised deadlines for the submission of full UK REACH registration dossiers are now:

27 October 2029

for all substances manufactured or imported in quantities of 1,000 tpa or more substances included on the EU REACH Candidate List or UK REACH Candidate List before 31 December 2023; substances that are carcinogenic, mutagenic or toxic for reproduction and manufactured or imported in quantities of 1 tonne per year (tpa) or more per manufacturer or importer; substances that are very toxic to aquatic life and manufactured or imported in quantities of 100 tpa or more.

27 October 2030

for all substances manufactured or imported in quantities of 100 tpa or more per manufacturer or importer and substances added to the UK REACH Candidate List between 1 January 2024 and 27 October 2026.

27 October 2031

for all other substances manufactured or imported in quantities of 1 tpa or more per manufacturer of importer

These deadlines apply to the submission of complete UK REACH registration information, including hazard data, exposure assessments and risk characterisation.

 

Implications for duty holders

While the extension provides additional time, UK REACH remains fully in force and the obligation to register substances placed on the GB market continues to apply.

To wrap up, and as a reminder, under current UK legislation,

• if you were already supplying substances to customers in Great Britain prior to Jan 1, 2021, you may submit a Downstream User Import Notification (DUIN). This allows you to maintain supply to those (pre-2021) customers until the relevant registration deadline applies, according to the substance hazard and applicable tonnage band.
• But if you are now (post 2020) supplying into the GB either existing substances to new GB customers or EU registered substances that were not placed on the GB market prior to 2021, then a DUIN is not valid for those supply chains. In these cases, a New Registration of an Existing Substance (NRES) is required. This process involves submitting an inquiry dossier, followed by an interim registration dossier, until the full registration deadline applies.
• And for any new substances, i.e. not EU REACH registered as of Jan 1, 2021, being supplied into GB at a tonnage band above 1Ton per year, a full registration according to EU requirements applies.

 

Companies are encouraged to use the additional time to develop structured, well-considered UK REACH strategies rather than deferring action.

Contact Apeiron

If you would like support in translating the revised timelines and ATRm requirements into a clear, practical UK REACH compliance plan, we would be pleased to assist.

Luisa Vilar
luisa.vilar@apeiron-team.eu