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UK REACH Update: The New Strategic Approach to SVHCs

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Following the UK’s exit from the EU in 2021, DEFRA (Department for Environment, Food & Rural Affairs) set out interim principles for adding substances of very high concern to the UK candidate list. However, a policy announcement by DEFRA on the 24th February 2026, indicates a move towards closer alignment with the EU REACH Candidate List, marking the official retirement of the “Interim Principles”

The Registry of Intentions (ROI) is the UK’s early warning list, to propose a substance for the Candidate List of SVHCs. A substance is first entered here, to allow companies an opportunity to comment, it also acts as a signal to industry to initiate substitution planning.

Up until March 2026, there was no substances listed on the UK ROI-SVHC list. However, since the announcement in February, the registry has seen 26 entries added, as the UK begins its systematic review of substances added to the EU candidate list since 2021. The UK has retained its ability to propose further potential SVHCs, where it is considered that substances meet the criteria set out in Article 57 of UK REACH.

A public consultation opened on 9th March 2026, relating to the 15 entries below. Interested parties have until 20th April 2026, to submit comments. The remaining 11 entries on the UK RoI- SVHC list are to be included in the second batch for consultation in June 2026.

  • 2,2′,6,6′-tetrabromo-4,4′-isopropylidenediphenol [TBBPA]
  • 2,2-bis(bromomethyl)propane-1,3-diol (BMP); 2,2-dimethylpropan-1-ol, tribromo

derivative/3-bromo-2,2-bis(bromomethyl)-1-propanol (TBNPA); 2,3-dibromo-1-propanol (2,3-DBPA)

  • 2-(4-tert-butylbenzyl)propionaldehyde and its individual stereoisomers [Lysmeral]
  • 2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1- one [Omnirad]
  • 6,6′-di-tert-butyl-2,2′-methylenedi-p-cresol [DMBC]
  • 6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acid [Tetra-PSCA]
  • Barium diboron tetraoxide
  • Bis(2-(2-methoxyethoxy)ethyl)ether [tetraglyme]
  • Bis(α,α-dimethylbenzyl) peroxide
  • Dioctyltin dilaurate, stannane, dioctyl-, bis(coco acyloxy) derivatives., and any other stannane, dioctyl-, bis(fatty acyloxy) derivatives. wherein C12 is the predominant carbon number of the fatty acyloxy moiety [DOTL]
  • Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide
  • N-(hydroxymethyl)acrylamide
  • Orthoboric acid, sodium salt
  • Reactive Brown 51: Tetra(sodium/potassium) 7-[(E)-{2-acetamido-4-[(E)-(4-{[4-chloro-6- ({2-[(4-fluoro-6-{[4-(vinylsulfonyl)phenyl]amino}-1,3,5-triazine-2-

yl)amino]propyl}amino)-1,3,5-triazine-2-yl]amino}-5-sulfonato-1-naphthyl)diazenyl]-5- methoxyphenyl}diazenyl]-1,3,6- naphthalenetrisulfonate1; Reactive Brown 51

  • Tris(2-methoxyethoxy)vinylsilane

If a substance is officially moved from the ROI to the Candidate List, immediate legal obligations are triggered for any company handling them in concentrations above 0.1% w/w:

  • Communication: You must provide safe-use information to customers down the supply chain.
  • Notification: Producers and importers must notify the HSE if their article contains a Candidate List substance in a concentration above 0.1% (w/w) and if the substance is present in quantities totalling over 1 tonne per year.

However, as entry onto the Candidate List is intended as a precursor to the Authorisation List (Annex 14), which would lead to a ban on all non-exempted uses, without specific permission (authorisation), it is critical companies are monitoring the early waring lists. H2 Compliance allow companies stay ahead of their regulatory obligations, with our unique software solution Element 1. Monitoring lists such as the UK ROI-SVHC list, and others under the EU/UK REACH regulations helps companies anticipate new restrictions & authorisations and take proactive measures, such as substituting or eliminating hazardous chemicals.

If you would like to know more on our Substance Tracking software solution, contact us for a free professional consultation.

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Published March 13th, 2026

Image generated with the assistance of Artificial Intelligence.