UK REACH quick compliance check

Use this checklist to verify your business meets its UK REACH obligations. Work through each section based on your role in the supply chain and follow any signpost where you need to act.

1. Confirm your supply chain role

Your UK REACH obligations depend on whether you are a manufacturer, importer, downstream user, or Only Representative. Manufacturers and importers must register substances. Downstream users have separate duties including exposure scenario compliance.

A downstream user under UK REACH is any natural or legal person in Great Britain (other than the manufacturer or importer) who uses a substance on its own or in a mixture in the course of industrial or professional activities. Distributors and consumers are not downstream users.

Downstream users have specific obligations relating to safety data sheets, exposure scenarios, authorisation, and communication within the supply chain. Many GB-based businesses that were downstream users under EU REACH became importers under UK REACH for substances sourced from the EU, and needed to submit DUIN notifications to HSE by 27 October 2021.

Safety Data Sheet (SDS) compliance: Must comply with conditions of use set out in the SDS received from suppliers. SDS requirements are set out in Annex II of UK REACH
Exposure scenario adherence: Must implement the risk management measures described in extended SDS exposure scenarios received from suppliers for registered substances at 10+ tonnes per year
Use outside exposure scenario: If a downstream user uses a substance in a way not covered by the supplier's exposure scenario, they must prepare their own Chemical Safety Report (downstream user CSR) or seek to have the use included in the supplier's registration
Downstream user CSR notification: If preparing their own CSR, must notify HSE within 6 months of receiving the SDS with the exposure scenario
Substance evaluation cooperation: Must cooperate with HSE requests during substance evaluation and provide requested information within the deadline specified
Supply chain communication: Must pass information up the supply chain to suppliers about new hazard information, concerns about risk management measures, or circumstances suggesting measures in the SDS may not be adequate
Authorisation compliance: If using an Annex XIV substance, the downstream user must either be covered by an authorisation granted to a supplier upstream or apply for their own authorisation
Authorisation notification: Downstream users relying on a supplier's authorisation must notify HSE within 3 months of first supply
Restriction compliance: Must comply with all restrictions in Annex XVII applicable to the substance or mixture being used
Record keeping: Must keep all information required for REACH compliance for at least 10 years after last manufacturing, importing, supplying, or using the substance

Downstream user obligations - HSE (opens in a new tab)

DUIN notifications for downstream users and distributors - HSE (opens in a new tab)

Supply chain role identified: manufacturer, importer, downstream user, or Only Representative Obligations for your specific role understood and documented UK-based legal entity identified as the registrant (non-UK companies need an Only Representative)

UK REACH registration guide

Full guidance on who must register, the registration process, tonnage bands, and transitional arrangements

2. Check registration and DUIN status

If you manufacture or import chemical substances above 1 tonne per year, you must have submitted a Downstream User Import Notification (DUIN) by 27 October 2023 and must complete full registration by your tonnage band deadline.

UK REACH came into force on 1 January 2021 when the UK left the EU single market. GB-based holders of EU REACH registrations were able to grandfather their registrations into UK REACH by providing basic information to the Health and Safety Executive (HSE).

Grandfathered registrations are subject to transitional deadlines by which full registration data must be submitted to HSE. Draft REACH (Amendment) (No. 2) Regulations 2026 to extend those deadlines were laid before Parliament on 24 March 2026 after Scottish and Welsh ministerial consent.

Regulator: Health and Safety Executive (HSE), acting as the UK REACH Agency
Geographic scope: Great Britain (England, Scotland, Wales) only. Northern Ireland follows EU REACH under the Windsor Framework
UK REACH in-force date: 1 January 2021
Grandfathering initial information deadline: 30 April 2021 (late submissions still accepted by HSE)
Downstream user/distributor notification (DUIN) deadline: 27 October 2021
Registration threshold: 1 tonne or more per year per manufacturer or importer

Current transitional submission deadlines

The deadlines below were set by the REACH (Amendment) Regulations 2023 (SI 2023/722), which extended the original deadlines by 3 years.

Deadline 1: 27 October 2026: Substances manufactured or imported at 1,000+ tonnes per year; substances classified as CMR categories 1A or 1B at 1+ tonne per year; substances classified as very toxic to aquatic organisms (acute or chronic) at 100+ tonnes per year; SVHCs on the UK REACH Candidate List as at 31 December 2020
Deadline 2: 27 October 2028: Substances manufactured or imported at 100+ tonnes per year; substances added to the UK REACH Candidate List between 1 January 2021 and 27 October 2026
Deadline 3: 27 October 2030: All other substances manufactured or imported at 1+ tonne per year

Further extension regulations laid in March 2026

Following its December 2025 consultation response and Scottish and Welsh ministerial consent, the government laid the draft REACH (Amendment) (No. 2) Regulations 2026 before Parliament on 24 March 2026. The draft proposed the following deadlines:

Proposed new Deadline 1: 27 October 2029 (extended from 27 October 2026)
Proposed new Deadline 2: 27 October 2030 (extended from 27 October 2028)
Proposed new Deadline 3: 27 October 2031 (extended from 27 October 2030)
Status of proposed extension: Draft REACH (Amendment) (No. 2) Regulations 2026 laid before Parliament on 24 March 2026 after Scottish and Welsh ministerial consent
Source: GOV.UK consultation outcome, 22 December 2025

Recognising EU REACH registrations (grandfathering) - HSE (opens in a new tab)

Government response on extending UK REACH deadlines (opens in a new tab)

DUIN submitted for all substances requiring registration Tonnage band identified for each substance Full registration deadline known for each tonnage band Data-sharing agreement in place with other registrants (where applicable) (optional) Registration fee budget allocated for upcoming deadline (optional)

3. Check SVHC obligations

Substances of Very High Concern (SVHCs) on the UK REACH Candidate List trigger additional duties including communication down the supply chain, notification to the HSE, and potential authorisation requirements.

The UK REACH Candidate List identifies Substances of Very High Concern (SVHCs) that may be prioritised for inclusion on the UK REACH Authorisation List (Annex XIV). SVHCs include substances that are carcinogenic, mutagenic, or toxic to reproduction (CMR); persistent, bioaccumulative, and toxic (PBT); very persistent and very bioaccumulative (vPvB); or substances of equivalent concern (e.g. endocrine disruptors).

When UK REACH came into force on 1 January 2021, all substances on the EU REACH Candidate List were carried over onto the UK REACH Candidate List. Since 31 December 2020, the UK and EU lists have been independent of each other and are diverging.

UK Candidate List at creation (31 December 2020): All SVHCs on the EU Candidate List as at 31 December 2020 were carried over (the EU list contained 211 entries at that date)
Independence from EU list: Since 31 December 2020, the UK and EU Candidate Lists are independent. Additions to one do not automatically apply to the other
EU Candidate List current size (for comparison): 251 entries (as of November 2025). The UK list has not yet been updated since the carry-over
UK Candidate List review: Government announced in December 2025 that it will review interim principles for additions to the UK REACH Candidate List by December 2026 and update the list accordingly
HSE role: HSE assesses substances added to the EU Candidate List since 2021 to determine whether SVHC identification is appropriate for UK REACH

Notification obligations for substances in articles

Importers and producers of articles must notify HSE if their articles contain a Candidate List substance, subject to the thresholds below.

Concentration threshold: 0.1% weight by weight (w/w) of the substance in the article
Tonnage threshold: 1 tonne or more per year of the substance across all articles produced or imported by that entity
Notification deadline: Within 6 months of a substance being added to the UK Candidate List
Multiple articles: For each article containing the SVHC at 0.1% (w/w) or more, the tonnage of the substance must be summed across all articles to assess whether the 1 tonne per year threshold is met
Exemption from notification: No notification required if the producer or importer can exclude human and environmental exposure during use and disposal, including reasonably foreseeable conditions

Supply chain communication obligations

Suppliers of articles containing Candidate List substances must communicate information down the supply chain.

Article 33 duty (business-to-business): Suppliers of articles containing a Candidate List SVHC above 0.1% (w/w) must provide the recipient with sufficient information to allow safe use, including as a minimum the name of the substance
Consumer right to information: Consumers can request information about Candidate List SVHCs in articles; the supplier must respond free of charge within 45 days
Safety Data Sheet for mixtures: If a mixture is not classified as hazardous but contains a Candidate List substance at 0.1% (w/w) or more (non-gaseous mixtures), a safety data sheet must be provided on request

UK REACH Candidate List of SVHCs - HSE (opens in a new tab)

Notifying substances in articles - HSE (opens in a new tab)

UK REACH SVHCs overview - HSE (opens in a new tab)

Products checked against the current UK REACH Candidate List for SVHCs Customers informed if articles contain SVHCs above 0.1% w/w HSE notified if placing articles containing Candidate List substances on the GB market Authorisation requirements checked for Annex XIV substances

UK REACH SVHC obligations

Candidate List duties, communication requirements, authorisation process, and substitution planning

4. Check Safety Data Sheets are current

Safety Data Sheets must be provided for hazardous substances and mixtures. They must comply with UK REACH Annex II format, reflect GB CLP classification, and be updated whenever new information becomes available.

Safety Data Sheets (SDSs) are the primary document for communicating hazard and safe handling information through the supply chain. In GB, SDS requirements are set by UK REACH (retained EU REACH Regulation (EC) No 1907/2006, Article 31 and Annex II), with classification information drawn from GB CLP.

The SDS must be compiled in accordance with the version of Annex II that was in force on 31 December 2020 (the UK did not adopt the EU's 2020 update to Annex II, Commission Regulation (EU) 2020/878, which only applies in the EU and Northern Ireland).

Legal basis: UK REACH Article 31 and Annex II (retained EU REACH Regulation 1907/2006 as amended for GB)
Language requirement: English (mandatory for SDSs supplied in Great Britain)
Format: 16 mandatory sections in the prescribed order; sections must not be left blank
GB Annex II version: Version in force on 31 December 2020. The EU 2020/878 update does NOT apply in GB.
Responsible authority: Defra (Department for Environment, Food and Rural Affairs) has lead policy responsibility for SDS requirements in GB
Enforcement: HSE and local authorities enforce SDS requirements under the REACH Enforcement Regulations 2008

When an SDS must be provided

Under UK REACH Article 31, an SDS must be provided to the recipient when:

A substance or mixture is classified as hazardous under GB CLP
A substance is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) under UK REACH Annex XIII criteria
A substance is on the UK REACH Candidate List (substances of very high concern, SVHCs)

An SDS must be provided on request where a mixture is not classified as hazardous but contains:

A substance posing health or environmental risk at 1% or more by weight (non-gaseous mixtures) or 0.2% or more by volume (gaseous mixtures)
A PBT, vPvB or Candidate List substance at 0.1% or more by weight
A substance with a GB workplace exposure limit

SDS for classified substances/mixtures: Mandatory - must be provided no later than first supply
SDS for PBT/vPvB substances: Mandatory - must be provided no later than first supply
SDS for Candidate List substances: Mandatory - must be provided no later than first supply
SDS on request - health/environmental substance threshold: 1% or more by weight (non-gaseous) or 0.2% or more by volume (gaseous)
SDS on request - PBT/vPvB/SVHC substance threshold: 0.1% or more by weight
SDS on request - workplace exposure limit: Must be provided on request if mixture contains substance with a GB workplace exposure limit
General public exemption: SDS need not be supplied where hazardous substances or mixtures sold to general public are provided with sufficient safety information, unless requested

16-section SDS format (UK REACH Annex II)

Every SDS must contain all 16 sections in the following prescribed order. No sections may be omitted, though individual subsections may state that information is not applicable or not available (with justification).

Section 1: Identification of the substance/mixture and of the company/undertaking - product identifier, relevant uses, supplier details, emergency telephone number
Section 2: Hazards identification - GB CLP classification, label elements (pictograms, signal word, H-statements, P-statements), other hazards (PBT/vPvB assessment)
Section 3: Composition/information on ingredients - chemical identity, impurities, concentration ranges of hazardous components
Section 4: First-aid measures - description of measures by route of exposure, important symptoms, indication of medical attention needed
Section 5: Firefighting measures - suitable extinguishing media, specific hazards from the chemical, advice for firefighters
Section 6: Accidental release measures - personal precautions, environmental precautions, containment and cleanup methods
Section 7: Handling and storage - precautions for safe handling, conditions for safe storage including incompatibilities, specific end uses
Section 8: Exposure controls/personal protection - GB workplace exposure limits (WELs), engineering controls, PPE requirements
Section 9: Physical and chemical properties - appearance, odour, pH, melting/boiling point, flash point, flammability, vapour pressure, density, solubility
Section 10: Stability and reactivity - reactivity hazards, chemical stability, conditions to avoid, incompatible materials, hazardous decomposition products
Section 11: Toxicological information - likely routes of exposure, symptoms related to physical/chemical/toxicological characteristics, numerical toxicity measures
Section 12: Ecological information - toxicity to aquatic organisms, persistence and degradability, bioaccumulative potential, mobility in soil
Section 13: Disposal considerations - waste treatment methods, relevant disposal legislation
Section 14: Transport information - UN number, proper shipping name, transport hazard class, packing group, environmental hazards, special precautions
Section 15: Regulatory information - GB safety, health and environmental regulations specific to the substance or mixture
Section 16: Other information - revision date, version number, changes from previous version, abbreviations, key literature references

Delivery and update obligations

The SDS must be provided free of charge, on paper or electronically, no later than the date on which the substance or mixture is first supplied to the recipient.

Delivery timing: No later than the date of first supply to the recipient
Delivery format: Paper or electronic (e.g. email, PDF download), free of charge
Update obligation: Supplier must update the SDS without delay when new information affecting risk management becomes available, or when a new hazard is identified, or when an authorisation is granted or refused, or when a restriction is imposed
Update distribution: Updated SDS must be provided to all recipients who received the substance or mixture within the preceding 12 months
Revision tracking: Updated SDS must be dated, marked as revision, and changes identified in Section 16
Exposure scenarios: Where a chemical safety assessment has been carried out, relevant exposure scenarios must be annexed to the SDS (extended SDS)

Enforcement and penalties

SDS requirements are enforced under the REACH Enforcement Regulations 2008. Failure to provide an SDS, or providing an SDS that does not comply with Annex II requirements, is a criminal offence.

Enforcement legislation: REACH Enforcement Regulations 2008 (SI 2008/2852)
Summary conviction penalty: Fine not exceeding the statutory maximum and/or imprisonment up to 3 months
Conviction on indictment penalty: Unlimited fine and/or imprisonment up to 2 years
Enforcing authority: HSE and local authorities

Safety Data Sheets provided for all hazardous substances and mixtures supplied SDSs comply with UK REACH Annex II format (16 sections) SDSs reflect current GB CLP classification and labelling Exposure scenarios annexed to SDSs where required (for registered substances) SDSs updated when new hazard information or risk management measures change

GB CLP classification and labelling

How to classify, label, and package hazardous chemicals under GB CLP, including SDS requirements and poison centre notification

5. Check downstream user duties (if applicable)

Downstream users must check that their uses are covered by the registration of their suppliers. If your use is not covered, you may need to notify HSE or conduct your own chemical safety assessment.

Safety Data Sheet (SDS) compliance: Must comply with conditions of use set out in the SDS received from suppliers. SDS requirements are set out in Annex II of UK REACH
Exposure scenario adherence: Must implement the risk management measures described in extended SDS exposure scenarios received from suppliers for registered substances at 10+ tonnes per year
Use outside exposure scenario: If a downstream user uses a substance in a way not covered by the supplier's exposure scenario, they must prepare their own Chemical Safety Report (downstream user CSR) or seek to have the use included in the supplier's registration
Downstream user CSR notification: If preparing their own CSR, must notify HSE within 6 months of receiving the SDS with the exposure scenario
Substance evaluation cooperation: Must cooperate with HSE requests during substance evaluation and provide requested information within the deadline specified
Supply chain communication: Must pass information up the supply chain to suppliers about new hazard information, concerns about risk management measures, or circumstances suggesting measures in the SDS may not be adequate
Authorisation compliance: If using an Annex XIV substance, the downstream user must either be covered by an authorisation granted to a supplier upstream or apply for their own authorisation
Authorisation notification: Downstream users relying on a supplier's authorisation must notify HSE within 3 months of first supply
Restriction compliance: Must comply with all restrictions in Annex XVII applicable to the substance or mixture being used
Record keeping: Must keep all information required for REACH compliance for at least 10 years after last manufacturing, importing, supplying, or using the substance

Downstream user obligations - HSE (opens in a new tab)

DUIN notifications for downstream users and distributors - HSE (opens in a new tab)

Confirmed that your uses are covered by your supplier's registration Exposure scenarios from supplier's SDS reviewed and implemented HSE notified if your use is not covered by supplier's registration Risk management measures from exposure scenarios applied in your workplace

UK REACH downstream user guide

Duties for downstream users including exposure scenario compliance, uncovered uses, and notification obligations

Next steps

If any check above raised concerns, follow the signpost to the relevant guide for detailed action steps. Monitor the HSE UK REACH website for updates to the Candidate List, Authorisation List, and Restriction List.

UK REACH compliance checklist

UK REACH quick compliance check

UK REACH registration guide

UK REACH SVHC obligations

GB CLP classification and labelling

UK REACH downstream user guide

Next steps

Next steps

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