Register chemicals under UK REACH

If you manufacture or import chemical substances into Great Britain (England, Scotland, and Wales), you must register them under UK REACH. This is separate from EU REACH and applies regardless of any previous EU registrations you held before Brexit.

UK REACH is administered by the Health and Safety Executive (HSE). Registration ensures that chemical hazards are properly assessed and that downstream users have the information they need to handle substances safely.

Who needs to register

You must register your substances if you are:

• A manufacturer producing chemical substances in Great Britain
• An importer bringing chemical substances into Great Britain from any country outside GB (including EU countries and Northern Ireland)

Registration applies per substance, per legal entity. If two companies in the same corporate group both import the same substance, each must register separately.

When registration is required

You must register if you manufacture or import 1 tonne or more of a substance per year. This is the minimum threshold - lower quantities do not require registration, though other obligations may still apply.

The 1 tonne threshold applies to each individual substance. If you handle multiple substances, assess each one separately against the threshold.

Exemptions from registration

Some substances are exempt from UK REACH registration:

• Substances used only in food or feeding stuffs (covered by food safety regulations)
• Medicinal products for human or veterinary use
• Substances in Annex IV (minimal risk substances like water, nitrogen, noble gases)
• Substances in Annex V (naturally occurring substances not chemically modified)
• Radioactive substances
• Substances under customs supervision in transit or temporary storage
• Substances manufactured or imported for product and process-oriented research and development (PPORD) - time-limited exemption

If you believe an exemption applies, document your reasoning. HSE may request evidence during compliance checks.

Tonnage bands and registration deadlines

UK REACH uses tonnage bands to determine your registration requirements and deadlines. Higher tonnage bands require more extensive data and earlier registration.

Calculating your tonnage band

Your tonnage band is based on the total quantity you manufacture or import per calendar year. Consider:

• All imports of the same substance, regardless of supplier or country of origin
• Substances contained in mixtures (calculate the proportion)
• Substances intended for release from articles (specific calculation rules apply)

If your tonnage fluctuates year to year, register based on your highest anticipated annual tonnage. You can update your registration if circumstances change significantly.

Step-by-step registration process

Registering under UK REACH involves preparing a technical dossier and submitting it through the HSE IT system.

Preparing your dossier

The registration dossier must contain:

Substance identity information:

• IUPAC name and other identifiers
• CAS number (if allocated)
• EC number (if previously registered under EU REACH)
• Molecular formula and structural formula
• Composition details including impurities

Tonnage and use information:

• Tonnage band (1-10T, 10-100T, 100-1000T, or 1000+T)
• Brief description of identified uses
• Uses you advise against (if any)

Hazard information:

• Classification under GB CLP Regulation
• Hazard statements and precautionary statements
• Study summaries for physicochemical, toxicological, and ecotoxicological properties
• Robust study summaries (higher tonnages require more detailed data)

Safe use information:

• Guidance on safe use
• Exposure scenarios (for substances above 10 tonnes)
• Chemical Safety Report (for substances above 10 tonnes)

Data requirements by tonnage band

Higher tonnage bands require more extensive testing data:

Costs and fees

Registration fees vary by tonnage band and company size. HSE offers reduced fees for small and medium-sized enterprises (SMEs).

Indicative registration fees:

• 1-10 tonnes: approximately £1,000-£2,000
• 10-100 tonnes: approximately £3,000-£5,000
• 100-1,000 tonnes: approximately £10,000-£15,000
• 1,000+ tonnes: £25,000 or more

These are HSE administrative fees only. You should also budget for:

• Data access costs: If joining a Substance Information Exchange Forum (SIEF) or consortium, you may need to purchase access to existing study data. Costs vary widely depending on the substance and data requirements.
• Testing costs: New studies, if required, can cost £10,000-£500,000+ depending on the test type.
• Consultant fees: Regulatory consultants typically charge £5,000-£20,000+ for dossier preparation.
• IUCLID software: Free from ECHA, but training may be needed.

SME verification

To claim reduced SME fees, you must provide evidence of your company size. HSE may verify your employee numbers and turnover against Companies House records.

Related obligations

GB CLP classification and labelling

All hazardous substances placed on the GB market must be classified, labelled, and packaged in accordance with the GB CLP Regulation. This applies whether or not you need to register under UK REACH.

Safety data sheets

Once registered, you must include your UK REACH registration number in Section 1.1 of the Safety Data Sheet (SDS) before supplying the substance to customers. The SDS must follow the 16-section format specified in Annex II of UK REACH.

Downstream user obligations

If you use chemicals but do not manufacture or import them yourself, you are a downstream user. You do not need to register, but you have obligations to:

• Check that your uses are covered by your suppliers' registrations
• Notify HSE if your use is not covered and you cannot change your process
• Implement the exposure scenarios in your suppliers' extended Safety Data Sheets
• Communicate information up and down the supply chain

Only Representative arrangements

Non-GB manufacturers can appoint an Only Representative (OR) based in Great Britain to fulfil registration obligations on their behalf. If you are appointed as an OR, you take on full responsibility for registration and compliance. Importers in the same supply chain become downstream users rather than registrants.

What happens if you do not register

Manufacturing or importing substances above 1 tonne without registration is an offence. Penalties include:

• Fines of up to £20,000
• Imprisonment in serious cases
• Prohibition notices stopping you from placing substances on the market
• Seizure and destruction of non-compliant substances

HSE conducts compliance checks and can request registration evidence at any time. Downstream users and customers may also request proof of registration before purchasing.

Next steps

To register your substances under UK REACH:

1. Identify all substances you manufacture or import above 1 tonne per year
2. Determine your tonnage band for each substance
3. Check if any exemptions apply
4. Create an account on the HSE UK REACH IT system
5. Join or form a SIEF for each substance to share data costs
6. Prepare your registration dossier using IUCLID format
7. Submit before your deadline and pay the registration fee

Start early - gathering data and coordinating with other registrants takes time. For complex substances, begin preparation at least 18-24 months before your deadline.