December 6, 2022 by Sylwia Kosmala-Grzechnik


Since the UK left the EU, all substances manufactured in or imported into the UK at tonnages of 1 tonne per year or above need to be registered under UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). Companies that registered substances under EU REACH while the UK was still a member of the EU, or that were previously considered as downstream users, could benefit from transitional provisions, such as grandfathering and downstream user import notifications (DUIN). These were put in place to reduce the impact of introducing new legislation and disruption in the supply chain. By grandfathering EU REACH registrations or submitting a DUIN, companies were allowed additional time of 2, 4 or 6 years plus 300 days after the end of the transition period (that is October 2023, 2025 and 2027, respectively) to meet their full registration obligations under UK REACH. Time flies fast and the first of the original deadlines for full registration  (October 2023) is in less than a year from now…!

However, due to concerns raised by industry on the feasibility and cost of accessing data to fulfil their registration requirements, a consultation was launched during summer 2022 by the Department of Environment, Food and Rural Affairs (DEFRA). The consultation focussed on an alternative transitional registration (ATR) model to reduce costs of transition from EU REACH to UK REACH and on extending the deadlines for producing full registration data.

The options which were proposed and subject to consultation, are listed below:

  • Baseline – Do not change the current submission deadlines. (27 October 2023, 27 October 2025, and 27 October 2027).
  • Option 1 – Extend all the current submission deadlines for each tonnage band by three years to October 2026, October 2028, and October 2030.
  • Option 2 – Extend the first submission deadline by 3 years to October 2026, the second by 2 years to October 2027, and the third by 1 year to October 2028.

The consultation closed on 1 September 2022 and the overview of responses was published last week.

An overwhelming majority of the respondents (82%) voted for Option 1, namely the largest extension of the registration deadlines, by three years for each deadline compared to current deadlines.  This option was voted for by small and large companies, with various roles in the supply chain, including manufacturers, downstream users, only representatives, importers and exporters. The respondents voting for this option noted that extending all deadlines provides the best opportunity for industry to prepare good quality dossiers in time and avoid any disruptions in the supply chain.

As indicated by the UK authority upon launching the consultation, the authority’s preferred solution was Option 2 as this would allow more time for industry while ensuring the authority can take necessary actions in the quickest time possible. However, this option was selected by only 13% of respondents, who noted that this option would provide a reasonable timeframe to submit the registrations and would enable a quicker transition into a new regulatory regime. Only a small number of votes were received in favour of the option to ‘do nothing’ and the majority of these respondents were from NGOs.

Therefore, despite the original preference of the UK authorities being for option 2, the current UK REACH registration deadlines for each tonnage band will be extended by 3 years (October 2026, October 2028, and October 2030) based on the results of the consultation. The decision to extend the deadlines will be legislated by the UK government, subject to the consent of the Scottish and Welsh governments.

If you need any help to decide on your next steps under UK REACH, here at wca we can provide advice on your obligations under UK REACH, support with developing a registration strategy, or act as your UK Only Representative, if you need one. Please do not hesitate to contact us and we can discuss with you how to proceed.