On 22 December 2025, the UK Government published its Summary of Responses and Government
Response following an 8-week public consultation on extending UK REACH dossier submission deadlines for transitional registrations. The consultation examined whether the existing deadlines remain appropriate while the Alternative Transitional Registration Model (ATRm) is under development.
The outcome confirms the government’s intention to provide industry with additional time while maintaining high standards of chemical safety and regulatory oversight.
Background
UK REACH is the regulatory framework governing the registration, evaluation, authorisation, and restriction of chemicals in Great Britain. Transitional registrations apply to substances that were previously registered under EU REACH and were allowed for continued market access following Brexit.
Original transitional dossier submission deadlines were set as follows:
- 27 October 2026
- 27 October 2028
- 27 October 2030
Industry stakeholders raised several concerns, including:
- High costs associated with full dossier submissions
- Duplication of data already submitted under EU REACH
- Limited clarity on future data requirements under ATRm
To address these challenges, the Department for Environment, Food & Rural Affairs (Defra) launched a consultation to explore potential deadline extensions.
Consultation Scope
The consultation focused on:
- Extending UK REACH transitional dossier submission deadlines
- Aligning statutory compliance check timelines with revised deadlines
- Ensuring a proportionate approach without compromising chemical safety
Proposed Options Considered
| Option | Description | Proposed Submission Deadlines |
|---|---|---|
| Baseline – Do Nothing | Retain existing submission deadlines without change. | 27 Oct 2026 27 Oct 2028 27 Oct 2030 |
| Option 1 (Preferred) | Extend the first deadline by 3 years with one-year gaps between subsequent deadlines. | 27 Oct 2029 27 Oct 2030 27 Oct 2031 |
| Option 2 | Extend all deadlines by 2½ years while retaining two-year gaps. |
27 Apr 2029 27 Apr 2031 27 Apr 2033 |
| Option 3 | Extend the first deadline by 2½ years with one-year gaps thereafter. | 27 Apr 2029 27 Apr 2030 27 Apr 2031 |
Stakeholder Feedback
- Strong opposition to retaining current deadlines
- Broad industry support for deadline extensions
- Repeated calls for:
- Greater regulatory certainty
- Reduced compliance costs
- Clear guidance on ATRm requirements
- NGOs emphasised timely access to hazard and risk data
- SMEs highlighted resource and compliance capacity constraints
Government Response
1. Deadline Extensions
The government confirmed Option 1 as the most balanced and proportionate approach, providing sufficient preparation time without unnecessary regulatory delay.
2. Compliance Checks
Statutory compliance check deadlines will be legally aligned with the revised dossier submission timelines to ensure effective enforcement and fairness.
3. Economic Considerations
No conclusive evidence was identified showing disproportionate cost impacts from any option. Further engagement with stakeholders is planned to assess longer-term impacts.
Next Steps
The UK Government plans to introduce secondary legislation in 2026, subject to agreements from devolved administrations. The legislation will:
- Formally extend UK REACH transitional registration deadlines
- Update statutory compliance check timelines
The revised framework will take effect before the first new submission deadline.
Source: Summary of responses and government response – GOV.UK
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