January 7, 2026 by Rhiannon Smith
Following Brexit, the EU chemical regulation (REACH – Registration, Evaluation, Authorisation, and Restriction of Chemicals) was mirrored in the UK as UK REACH. In the spring of 2024, the then-UK government opened a consultation on the ATRm (alternative transitional registration model) – amendments to the information requirements for UK REACH, with the proposal that these are significantly reduced and would rely mainly on the published summaries available via the ECHA dissemination portal. Shortly after the consultation was opened, the UK held a general election and there was a change in government. The new government has not released the outcome of this consultation, and given the uncertainty on the information to be provided, there are concerns that industry would not be able to meet the current deadlines.
The current UK REACH deadlines depend on the tonnage band and hazard profile of the substance:
- 27 October 2026: ≥1000 tpa (tonnes per annum) or carcinogenic, mutagenic or toxic for reproduction at ≥1 tpa, or very toxic to aquatic organisms (acute or chronic) at ≥100 tpa or Candidate List substances (as of 31 December 2023)
- 27 October 2028: ≥100 tpa or Candidate List substances (as at 27 October 2026)
- 27 October 2030: ≥1 tpa
As such, a further consultation was held in summer of 2025 on the extension of the deadlines by which full datasets must be submitted under UK REACH for substances which were previously registered in the EU. The consultation asked for views on options to leave the deadlines as they are currently (baseline) or to extend the deadlines to: 27 October 2029/2030/2031 (option 1); 27 April 2029/2031/2033 (option 2); or 27 April 2029/2030/2031 (option 3). The outcome of this consultation has recently been published.
Based on their response to the input from stakeholders to the consultation, the UK government are proposing to the devolved Scottish and Welsh governments (note EU REACH continues to apply in Northern Ireland under the Windsor Framework) that the UK REACH deadlines are delayed to 27 October 2029/2030/2031 (option 1).
The UK government are also proposing to align the compliance check deadlines with the revised submission deadlines so that industry has time to submit the necessary data before the regulatory review is undertaken, with compliance checks to follow a 1, 2 and 5 year schedule after each submission deadline (i.e. October 2030/2032/2036), reflecting the current legislative model.
The extension of the deadlines gives the UK government some further time to confirm what needs to be included in UK REACH submissions (depending on the outcome of the consultation on the ATRm) and then gives industry some time to prepare and submit the dossiers within the relevant timelines. At wca, we will continue to monitor the situation and work with companies to ensure these new deadlines are met and to assist with dossier preparation as soon as there is further clarity on the information requirements.
If you have any questions on UK REACH or if we can assist you with this in any way, please contact us.