December 16, 2021 by Lucy Kennelly


Under UK REACH, all companies producing or importing substances into Great Britain at ≥ 1 tonne per annum must submit a registration to the UK Health and Safety Executive (HSE). Substances which have been grandfathered or have been notified by a Downstream User Import Notification (DUIN) need to have a full registration submitted by the transitional registration deadlines. The first deadline for registrations is currently 27 October 2023, followed by two further deadlines in 2025 and 2027.

However, concerns have arisen from industry on the feasibility and cost of accessing data to fulfil the registration requirements. Defra Secretary of State George Eustice has written a letter to Chemical Industries Association chief executive Steve Elliott, addressing these concerns.

The letter states that the UK authorities will “explore a new model for transitional registrations,” with an aim to reduce the effort and cost to businesses of accessing data packages to support their registrations by focusing on “uses and exposures of chemicals in the GB context.” This approach has “the potential to provide clearer evidence on whether each company is managing chemicals safely and support more targeted regulatory actions.”

The UK authorities will be holding a consultation in 2022 to discuss this new model for UK REACH. The government will consult on extending the deadlines for producing full registration data, and will discuss with industry and other stakeholders how to reduce the need for replicating EU REACH data. The first registration deadline is likely to be extended from 27 October 2023 to 27 October 2025, with the consultation considering possible extensions of the other two deadlines.

The first transitional registration deadline applies to substances which are:

  • Imported or manufactured at 1000 tonnes or more per annum
  • Carcinogenic, mutagenic or toxic for reproduction at 1 tonne or more per annum
  • Very toxic to aquatic organisms (acute or chronic) at 100 tonnes or more per annum
  • Candidate List substances (as of 31 December 2020)

If you are looking for assistance with your next steps under UK REACH, wca can support with developing a registration strategy, act as your UK Only Representative, or provide advice on your obligations under UK REACH. Please do not hesitate to contact us and we can discuss with you how to proceed.