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HomeResourcesUK REACH (& Brexit)The UK REACH Roadmap

The UK REACH Roadmap

4 min read

UK REACH came into force on 1 January 2021 following the UK’s departure from the European Union. Since then, progress has been gradual, with evolving timelines and uncertainty around future requirements.

This series of articles aims to explain the key requirements under UK REACH and provide practical guidance on how businesses can comply with the regulation.

What is UK REACH?

UK REACH is the chemical regulatory framework that applies in Great Britain (England, Scotland and Wales) following Brexit. It requires companies that manufacture, import or use chemical substances to understand and manage the risks those substances may pose to human health and the environment. UK REACH does not apply in Northern Ireland, where EU REACH continues to apply.

UK REACH primarily impacts GB-based manufacturers, importers, and Only Representatives (OR). The main obligation under the regulation is registration. Companies importing or manufacturing substances at 1 tonne or more per year may have registration obligations depending on their role and circumstances.

To support businesses transitioning from EU REACH, several transitional provisions are available, including Grandfathering, Downstream User Import Notifications (DUINs) and New Registrations of Existing Substances (NRES). These mechanisms can allow eligible companies to continue accessing the GB market while deferring certain registration requirements until the applicable UK REACH deadlines.

H2 Compliance will be publishing a series of articles to explain these provisions in more detail and outline how they may affect your business.

What Comes Next for UK REACH?

There is still some uncertainty around the future direction of UK REACH. DEFRA has committed to exploring alternative arrangements for transitional registrations, including potential changes to the information requirements for full registration dossiers. This is known as the Alternative Transitional Registration Model (ATRm).

To support this work, DEFRA has extended the transitional registration submission deadlines. The current deadlines are as follows:

Deadline (last date for dossier submission)TonnageHazardous property
27 October 20291000 tonnes or more per yearCarcinogenic, mutagenic or toxic for reproduction (CMRs) – 1 tonne or more per year Very toxic to aquatic organisms (acute or chronic) – 100 tonnes or more per year Candidate list substances of very high concern (SVHC) on or before 27 October 2027
27 October 2030100 tonnes or more per yearCandidate list SVHC substances during the period beginning with 28 October 2027 to 27 October 2028
27 October 20311 tonne or more per year 

As these deadlines approach, companies should use the available time to understand their obligations, confirm their substance portfolios, and develop a clear compliance strategy.

Whether you have already submitted a Downstream User Import Notification (DUIN), grandfathered an existing EU REACH registration, intend to register under the New Registration of Existing Substances (NRES) process, or have not yet assessed your UK REACH obligations, now is the time to start preparing.

This article is the first in a new series, The UK REACH Roadmap, where we will break down the key elements of UK REACH and provide practical guidance to help organisations navigate the regulation with confidence.

Over the coming weeks, we will explore topics including:

  • Downstream User Import Notifications (DUINs)
  • New Registrations of Existing Substances (NRES)
  • Registration deadlines and tonnage bands
  • Planning your route to UK REACH compliance
  • Common compliance challenges and how to avoid them

If terms such as DUIN, Grandfathering or NRES are unfamiliar, don’t worry. The purpose of this series is to explain these concepts in practical terms and help businesses understand what actions may be required. Companies will then be better equipped to create a roadmap to compliance under UK REACH.

For many GB importers, DUINs were the first practical step in maintaining market access after Brexit, which makes them a logical starting point for this series.

Therefore, in our next article, we will look to explore DUINs in more detail, who needed to submit one, and what it means for future registration obligations.

Follow our LinkedIn page to stay up to date with future articles in this series.

For any assistance with compliance with UK REACH please feel free to contact us.

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Published September 16th, 2026

Article image generated with the assistance of Artificial Intelligence.