Consultation on Extending the UK REACH Transitional Registration Submission Deadlines

Overview

This consultation is seeking views from stakeholders on the government’s proposals to extend the UK REACH transitional registration submission deadlines. The existing deadlines are October 2026, October 2028 and October 2030.  These deadlines are phased according to the tonnages and hazard profiles of the substances being registered.

Under UK REACH, businesses are required to register with the UK REACH Agency (the Health and Safety Executive, HSE) information on chemicals substances that are placed on the GB market.  When the UK left the EU, information on substances on the GB market which had been registered with UK REACH was not passed to the HSE.  The substances in question have remained on the GB market, but this information still needs to be registered with UK REACH.

The UK REACH alternative transitional registration model (ATRm) will specify what these information registration requirements involve.  A public consultation from May 2024 to July 2024 set out some proposals, which had been developed under the previous government administration by Defra, the Health and Safety Executive (HSE) and the Environment Agency (EA).  The current government, in cooperation with the Devolved governments in Scotland and Wales, is considering the next steps. Given that the detailed design of the ATRm is still under review, we cannot confirm at this stage exactly what information industry will be required to provide by the submission deadlines. However, it is our expectation that the final information requirements will not exceed those outlined in the 2024 ATRm consultation.

Given these ongoing considerations, it will no longer be possible to deliver the legislative changes to implement ATRm before the current first submission deadline in October 2026 together with a suitable transition period.  

It is therefore necessary to consult on revised transitional submission deadlines, which provide sufficient time for the government to complete the ATRm and for industry to prepare to comply.

The proposed new deadlines under consultation are:

• Option 1: October 2029, October 2030, October 2031
• Option 2: April 2029, April 2031, April 2033
• Option 3: April 2029, April 2030, April 2031

Option 1 is the government’s preferred option as it allows time to finalise the design and implementation of the ATRm and provides industry with a transition period of approximately two years.

Moving from a two-year gap to a one-year gap between deadlines would provide sufficient time for information to be gathered and submitted by industry, while managing down the overall period before the regulators are in receipt of complete registration data.

This consultation is also seeking views on the government’s proposal to extend the dates for the requirement on HSE to carry out compliance checks on 20% of registration dossiers received.  This applies under Article 41(5) of the UK REACH Regulation. At present this duty aligns with the current submission deadlines.