UK REACH registration deadline approaching

UK REACH registration deadlines depend on the tonnage of each substance you manufacture or import per year. Tonnage is the main factor, but CMR category 1A or 1B substances at 1 tonne or more per year, and some other hazard-based and Candidate List substances, fall under earlier deadlines. Check which deadline applies to each of your substances:

• 1,000+ tonnes per year -- earliest deadline
• 100-999 tonnes per year -- intermediate deadline
• 1-99 tonnes per year -- final deadline

If you manufacture or import multiple substances, each has its own tonnage calculation and potentially a different deadline. Check every substance individually.

Beyond standard registration, some substances carry additional requirements that affect your timeline. Substances of Very High Concern (SVHCs) on the UK REACH Candidate List trigger duties to pass on safety information and, for articles, possible notification to HSE. Substances on the Authorisation List require separate authorisation to continue using them.

Check every substance you manufacture, import, or use against the UK REACH Candidate List and Authorisation List. These obligations apply in addition to registration, not instead of it.

A UK REACH registration dossier requires hazard data, exposure information, and a Chemical Safety Report for substances at 10 tonnes or more per year. The data requirements increase with tonnage band. If you held an EU REACH registration, some of your existing data may be transferable, but you must ensure it meets UK REACH-specific requirements.

Consider joining a Substance Information Exchange Forum (SIEF) to share data and costs with other registrants of the same substance. Joint submission reduces duplication and is encouraged by HSE.

If your deadline has passed or you cannot complete registration in time, you may need to change your role in the supply chain. A downstream user who does not manufacture or import the substance directly does not need to register it -- but they must ensure their supplier holds a valid registration covering the relevant use.

Switching from importer to downstream user means sourcing the substance from a GB-based supplier or a non-GB supplier who has appointed an Only Representative. This is a significant supply chain decision that should not be left to the last moment.