The UK Government is proposing to extend transitional registration deadlines under UK REACH, aiming to give businesses more time to comply while the Alternative Transitional Registration model (ATRm) is still under development.
Background: Brexit & UK REACH
Post-Brexit, companies that previously registered substances under EU REACH had to transition to UK REACH, requiring:
• Downstream User Import Notifications (DUINs)
• Full registration dossiers, due by tiered deadlines based on tonnage and hazard.
Original deadlines:
• 27 Oct 2026: Substances ≥1,000 tpa or high-hazard
• 27 Oct 2028: Medium-tonnage substances
• 27 Oct 2030: Lower-tonnage substances
Why Are Extensions Being Proposed?
The Government acknowledges key concerns:
• ATRm is not yet finalized, creating uncertainty.
• Businesses face high costs and potential data duplication.
• Non-compliance risks could impact supply chains.
To address this, the UK aims to delay deadlines to align with ATRm launch and reduce industry burden.
Proposed New Deadlines
The Department for Environment, Food & Rural Affairs (DEFRA) has put forward three options:
Option 1 (Preferred): Oct 2029, Oct 2030, Oct 2031
Option 2: Apr 2029, Apr 2031, Apr 2033
Option 3: Apr 2029, Apr 2030, Apr 2031
Option 1 offers the most balanced approach, spacing deadlines by one year and providing a 2-year extension for the first tranche.
Industry Impact
If adopted, the extension would:
• Give businesses breathing room to adapt to ATRm
• Lower compliance costs by preventing premature data collection
• Avoid market disruption from rushed registration timelines
What Businesses Should Do Now?
• Submit feedback to DEFRA by 8 September 2025
• Follow ATRm developments to understand future obligations
• Start preparing early, even if deadlines are pushed
The UK's proposed extension of UK REACH deadlines is a pragmatic move to align with its evolving regulatory framework and support industry stability. Businesses have a key role to play by contributing to the ongoing consultation.
Reference: DEFRA Consultation Portal
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