UK REACH Requirements Now in Force

A flask filled with yellow liquid next to a test tube rack holding many test tubes containing various colored liquids

February 16, 2021

New deadlines for registrations of chemical substances under UK REACH

As of January 1, 2021, UK REACH is in force and applicable in Great Britain. Northern Ireland will continue to operate under EU REACH. Initially, the operating principles of UK REACH will be broadly the same as EU REACH, including data requirements and tonnage triggers, and will continue to apply to individual substances. UK REACH is regulated by the Health and Safety Executive (HSE). The following important points should be noted:

  • UK-based EU REACH registrations, authorizations, and imported substances will still be valid after December 31, 2020.
  • All existing UK-based EU REACH registrants have 120 days to provide initial "grandfathering in" information to the UK authorities.
  • Current importers of substances from EU-based registrants have 300 days (i.e., until October 27, 2021) to provide initial information to the UK authorities by means of submitting Downstream User Import Notification (DUIN). They will then need to submit an Article 26 inquiry dossier for each substance before registration.
  • UK REACH registrations must then be completed according to the following criteria:


Annual tonnage


Deadline for registration (from October 28, 2021)


Any CLP classification

2 years


Very toxic to aquatic organisms (acute or chronic)


CMR substances


Candidate list substances (as of December 31, 2020)


Any CLP classification

4 years


Candidate list substances (as of October 27, 2023)


Any CLP classification

6 years


Note that companies will still be required to submit a registration for substances previously registered under EU REACH that are intended for manufacture or import in the UK for the first time. However, some companies may be able to defer the submission of the full information requirement such that they are able to share data with other registrants and grandfathered registrants. Companies will be informed whether this applies to them when their Article 26 inquiry dossier becomes successful.

UK REACH applies to substances within mixtures (such as cosmetics and other consumer chemicals), so manufacturers and importers of these product types should be aware of their responsibilities.

How Exponent Can Help

Exponent's international team of chemical regulation experts offers full and complete services to help substance manufacturers, importers, and downstream users comply with their responsibilities under UK REACH, including an Only Representative Registrant service for non-UK manufacturers.