UK REACH Transitional Registration Deadline Extension

Introduction: The Latest on UK REACH Transitional Registration Deadlines

The regulatory landscape for chemical businesses in the UK is marked by ongoing evolution. In July 2025, the UK Government, through the Department for Environment, Food & Rural Affairs (Defra), launched a new public consultation proposing further extensions to the transitional registration deadlines for chemicals under UK REACH. For companies importing, manufacturing, or distributing chemicals in Great Britain, these developments are central to both compliance strategy and operational continuity. As Olalla Consulting, our mission is to guide clients through regulatory changes with clarity, practical solutions, and expert support. This blog post will outline the UK REACH background, dissect the current consultation, explain the three proposed options, interpret responses from government and industry leaders, and provide actionable recommendations for affected businesses.

Understanding UK REACH: Origins and Relationship to EU REACH

What is UK REACH?

UK REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) is the regulatory framework governing the manufacture, import, supply, and use of chemicals in Great Britain (England, Scotland, and Wales). It applies to individual substances, mixtures, and, in some cases, articles (products) containing chemicals, provided they are manufactured or imported in quantities of one tonne or more per year. Its core aim is to protect human health and the environment while supporting competitiveness and innovation within the chemicals sector.

UK REACH was adopted into domestic law on 1 January 2021, following the UK’s exit from the European Union. As a direct result of Brexit, UK REACH replicates much of the EU REACH framework but operates independently and is enforced by the UK Health and Safety Executive (HSE) and the Environment Agency.

The EU–UK REACH Relationship and Key Divergences

While UK REACH and EU REACH retain similar principles—such as the “no data, no market” rule, the precautionary principle, and mandatory registration and risk management for companies placing chemicals on the market—there are major operational differences:

• Separate Regulatory Systems: Chemical products on the UK and EU markets must comply separately with UK REACH and EU REACH, registering with HSE and ECHA, respectively.
• Divergence in Substances Regulated: After Brexit, UK and EU SVHC (Substances of Very High Concern) lists have started to diverge. For example, as of early 2025, EU REACH has more up-to-date SVHC entries compared to the static list in UK REACH.
• Data Sharing Barriers: There’s no automatic transfer of registration dossiers or data between EU and UK authorities, leading to duplicate registration requirements and significant cost burdens for industry.
• Dual Compliance for Northern Ireland: Under the Windsor Framework, EU REACH continues to apply in Northern Ireland, while UK REACH applies in Great Britain.

For businesses, the operational implication is clear: compliance with both frameworks (where relevant) is mandatory, requiring close attention to both sets of evolving deadlines and data requirements.

The Purpose and Mechanics of Transitional Registrations

Why Transitional Registration?

The initial transition from EU to UK REACH was designed to minimize disruption to chemical supply chains. To facilitate a smooth transfer:

• Businesses already holding registrations with ECHA as of 31 December 2020 received “grandfathered” UK REACH registrations.
• Downstream users and distributors under EU REACH could continue importing chemicals into Great Britain by submitting a Downstream User Import Notification (DUIN), deferring the full registration deadline.
• Transitional provisions for New Registrations of Existing Substances (NRES) were also put in place.

These transitional registrations allow continued supply and use of chemicals, giving businesses time to compile and submit the substantial datasets and supporting information (dossiers) required for full UK REACH registration.

Submission Deadlines by Tonnage and Hazard

The registration deadlines are tiered, depending on the tonnage and hazard profile of the substance:

CMRs: Carcinogenic, Mutagenic, or toxic to Reproduction substances
SVHCs: Substances of Very High Concern

These deadlines, however, have already undergone one round of extensions and are the subject of the latest government consultation.

The Alternative Transitional Registration Model (ATRm)

Rationale: Reducing Industry Burden

A major pain point for UK industry has been the potential cost—estimated at between £2 billion and £3.5 billion, of recreating and re-purchasing the same data sets already submitted to ECHA. The government, acknowledging this, proposed the Alternative Transitional Registration Model (ATRm) to reduce unnecessary cost and duplication, particularly avoiding repeat animal testing, while maintaining robust health and environmental protections.

ATRm is intended to modify the format and scope of information required for transitional registrations by:

• Focusing submission requirements on use and exposure data specific to the UK context, especially for high-concern substances.
• Reducing hazard data requirements where valid data is already available from EU or other global sources.
• Allowing a more targeted, risk-based regulatory approach.

Detailed policy design for ATRm is still being finalized and is not expected in time for the previously scheduled first deadline of October 2026.

ATRm Progress Update

Consultations were held between May and July 2024, but as of October 2025, ATRm is still under development. Defra has indicated that final information requirements in ATRm are not expected to exceed those set out in the 2024 consultation, but the precise detail is awaited.

DEFRA’s 2025 Consultation: Why Deadline Extensions Are Back on the Table

Causes for Repeated Extensions

Despite transition measures, ongoing uncertainty over ATRm’s detailed requirements has made it clear that it is no longer feasible, either for government or industry, to meet the October 2026 deadline. Without an extension, companies would face the risk of investing substantial resources in preparing full registrations that may soon become obsolete under the final ATRm.

This regulatory limbo creates a dual threat:

• Compliance Risk: Companies unable to prepare accurate dossiers before ATRm’s publication may risk non-compliance and market disruption.
• Resource Waste: Without clarity, investments in compliance could be “nugatory”—wasted on soon-to-be superseded requirements.

To address this, Defra published the July 2025 consultation proposing further extensions, coupled with a call for feedback on three specific options for adjusted deadlines.

Regulatory and Political Context

This is not the first time such extensions have been tabled. The current deadlines were themselves the result of an earlier extension, formalized in the REACH (Amendment) Regulations 2023 (Statutory Instrument 2023/722) following industry pressure and governmental acknowledgment of the wide-ranging impact on the chemicals sector and its supply chains.

The Three Options: Summary Table and Analysis

Defra’s July 2025 consultation outlines three options for new transitional registration deadlines and invites stakeholder views on the advantages and disadvantages of each.

Deadline Options Table

Key:

• First Deadline: Highest priority / highest tonnage substances
• Second / Third Deadlines: Lower priority / tonnage

Detailed Explanation of Each Option

Option 1 (Government’s Preferred Option): October 2029, October 2030, October 2031

This option pushes each deadline back by roughly three years from the previous (already extended) deadlines, continuing the principle of a two-year transition period following ATRm finalization. The last two deadlines are now just a year apart. The government sees this as a practical balance, providing sufficient transition for industry to adapt to ATRm and phase-in requirements, while not prolonging regulatory uncertainty unduly.

Option 2: April 2029, April 2031, April 2033

Here, the first deadline is six months earlier than in Option 1, but the intervals between deadlines are longer (two years each). This longer overall window (up to April 2033 for the final phase) could better spread resource and cost pressures for businesses, especially those with larger or more complex portfolios.

Option 3: April 2029, April 2030, April 2031

This option equally starts the process earlier (six months ahead of Option 1) but compresses all deadlines into a two-year period, with only a single year between each. This appeals to those prioritizing accelerated data acquisition by regulators and a faster move towards regulatory certainty.

Rationale and Implications of the Options

• Option 1 is preferred by government as it allows a reasonable transition without over-extending regulatory uncertainty, while keeping a manageable interval between deadlines for phased industry preparation.
• Option 2 may be favoured by businesses with significant compliance burdens, as it allows costs and resource commitments to be spread over a larger timespan.
• Option 3 responds to calls—primarily from environmental groups and some NGOs—for rapid regulatory certainty and minimal delay before the regulator receives complete data.

The government’s consultation document specifically emphasizes that submission deadlines should align with the eventual implementation of ATRm, and that a suitable gap between deadline phases enables learnings from earlier submissions to inform best practices later.

Extension of Compliance Checks Under Article 41(5)

UK REACH Article 41(5) requires HSE to carry out compliance checks on at least 20% of registration dossiers for each tonnage band. The timing of these checks is linked to the submission deadlines.

Defra is also consulting on moving the compliance check deadlines to align them with the newly proposed submission deadlines. This means, for example, that compliance checks for the highest tonnage/hazard substances would not commence until after the relevant (postponed) registration deadline. This alignment ensures regulators have access to a critical mass of submitted data before performing compliance checks, maximizing the efficiency and meaningfulness of regulatory oversight.

The Implications: What Does This Mean for Your Business?

Short-Term: Immediate Regulatory Relief

For businesses currently preparing for near-term (2026–2030) UK REACH deadlines, the proposed extensions offer urgent relief from potential resource bottlenecks, legal non-compliance, and investment in “soon-to-be-redundant” compliance activities.

• Time to Prepare: Additional years for compliance planning and portfolio review, pending final ATRm requirements.
• Cost Management: Opportunities to spread anticipated costs, align compliance planning with inventory turnover, and avoid duplicative data acquisition.
• Flexibility: Room to implement learnings from the “first wave” of submissions (highest tonnage) into subsequent registration phases.

Medium-to-Long Term: Strategic Uncertainty Remains

• Uncertainty Persists: As ATRm details remain unpublished, businesses must monitor regulatory developments closely and maintain flexibility in compliance strategy.
• Opportunity for Engagement: The consultation period gives industry a chance to influence final deadline choices and shape the regulatory environment.
• Vendor/Supply Chain Impact: Businesses that are part of wider supply chains, often spanning both EU and UK jurisdictions—must remain alert to partnership, data-sharing, and procurement implications of deadline extensions.
• Potential for Market Exit: Ongoing uncertainty and extended timelines could lead some overseas suppliers to revalue market participation, especially where the cost of compliance outweighs anticipated market value.

Alignment with UK and International Policy Agendas

The government’s extension rationale highlights that, during the additional years, HSE and businesses can continue to rely on EU data, inherited safety practices, and associated regimes—including COSHH, CLP, and sector-specific regulations, to safeguard human health and the environment.

Industry and Expert Perspectives: Snaith, Borthwick, and Sector Responses

Peter Snaith: Industry Pragmatism and SME Challenges

Peter Snaith, partner at Womble Bond Dickinson, reflects the prevailing industry view that longer deadlines would provide “more time to prepare registrations,” allowing businesses to manage costs and resources efficiently. He emphasizes the burden faced by companies—especially SMEs and downstream users—that must now duplicate, at significant expense, the process previously completed for EU REACH. Snaith suggests that lengthier transitions would avoid bottlenecks and offer less-experienced businesses a greater opportunity to meet regulatory obligations under the new framework.

Ashley Borthwick: Environment and Safety Priorities

Ashley Borthwick, also at Womble Bond Dickinson, notes that certain organizations, notably NGOs and some public health/environmental groups, prefer shorter intervals (as in Option 3). Their main concern is that further extension of deadlines could delay the availability of critical safety data and slow the regulatory action needed to address hazardous substances. Borthwick highlights calls for prioritizing the registration of more hazardous substances, regardless of tonnage, to maintain the highest public health and environmental standards.

Views from the Chemical Sector and Trade Associations

Sector responses coalesce around a few themes:

• Relief Coupled with Frustration: Business groups, including the Chemical Business Association (CBA) and the Chemical Industries Association (CIA), express relief at further extensions but deep frustration at delays in finalizing ATRm and persistent regulatory drift since Brexit.
• Economic Impact: The cost burden of duplicative registrations is seen as a “casualty of Brexit,” with repeated delays generating planning uncertainty, supply chain risk, and potential reduction in innovation.
• SME Disadvantage: SMEs, which make up a significant portion of the UK chemical sector, are most vulnerable to compression of deadlines and benefit disproportionately from lengthier transition periods.
• Calls for UK-EU Regulatory Cohesion: Many stakeholders voiced their support for minimizing divergence between UK and EU chemical regulations and, if feasible, re-establishing frameworks for mutual recognition or data sharing.

What Should Businesses Do Now? Olalla Consulting’s Supportive Approach

Navigating these shifting sands requires an agile, well-informed compliance strategy. Olalla Consulting recommends the following immediate and medium-term actions for affected businesses:

1. Monitor Regulatory Developments Closely

• Participate in Consultation: Submit feedback to Defra (individually or via trade associations) before the 8 September 2025 deadline to ensure your business’s needs and realities are considered.
• Track ATRm Policy: Remain alert to announcements regarding the final ATRm design, as this will fundamentally shape registration requirements and long-term compliance obligations.

2. Conduct a Portfolio Review

• Identify Exposures: Map your company’s portfolio to the relevant tonnage and hazard categories, and cross-reference with both existing and expected (under ATRm) data requirements.
• Prioritize Substances: Consider prioritizing the review and potential pre-registration or inquiry processes for high-risk or high-value substances that could be subject to earlier controls.
• Assess Data Availability: Evaluate current data access—especially for substances where rights under EU REACH may not be straightforward to transfer or duplicate.

3. Engage with Supply Chains

• Supplier Communication: Ensure non-UK suppliers understand their obligations and the evolving UK requirements.
• Only Representative Arrangements: Review and, if needed, revise Only Representative contracts to ensure compliance for imports originating outside the UK.

4. Plan for Resource and Cost Allocation

• Spread Investment: Use the (prospective) extra time to plan and sequence investments in data acquisition, dossier compilation, and regulatory support.
• Training and Recruitment: Build in time for upskilling staff or hiring specialized consultants, including (eco)toxicologists, regulatory affairs officers, and IT/data managers.

5. Prepare for the Future

• Scenario Planning: Model different compliance scenarios, including best- and worst-case timing for ATRm finalization, to best mitigate business risk.
• Continuous Compliance: Remember that obligations under existing workplace safety regimes (COSHH, CLP, etc.) remain active throughout this extension period.

How Olalla Consulting Can Help

At Olalla Consulting, we combine deep scientific expertise with pragmatic regulatory and industry insight. Our hands-on approach ensures clients:

• Stay abreast of legal changes and deadlines;
• Optimize compliance strategies and reduce unnecessary spend;
• Maintain supply chain continuity and market access;
• Receive tailored support, including portfolio mapping, risk assessment, and expert data review.

Our services are uniquely designed for the cosmetics, cleaning, household, and chemical sectors, where UK REACH and other regulatory frameworks interlock. We’re committed to delivering peace of mind and practical solutions for businesses of all sizes, from innovative start-ups to household brands.