UK-REACH, the Registration, Evaluation, Authorisation and Restriction of Chemicals regulation, is one of the main pieces of legislation governing the regulation of chemicals in the UK.

With the UK's exit from the EU, UK-REACH applies to England, Scotland, Wales and Northern Ireland and continues to apply to the EU-REACH.

Under the UK-REACH regulation, companies outside the UK are required to meet the corresponding registration obligations under UK-REACH if they export ≥1 tonne/year of substances to the UK (including the substances themselves, substances in mixtures or substances intentionally released from articles).

The registration includes information about the company, information about the substance, hazards of the substance, uses, exposures, and other relevant information.

▌Transitional provisions

The UK-REACH regulation contains a number of transitional provisions to reduce the trade impact on industry as a result of the transition from EU-REACH to the new regulatory regime.

These provisions allow companies to submit some simple information to complete notifications and registrations in order to continue trading, and to provide complete registration data by the respective deadlines. The relevant transitional provisions apply to registrants, downstream users or distributors prior to the entry into force of UK-REACH and under the EU-REACH regime.

Depending on the registered tonnage and the nature of the hazard of the substance, the relevant deadlines are currently set as follows.

Officials are working with stakeholders to explore an alternative transitional registration model in response to concerns about the transition from EU-REACH to UK-REACH, including the cost of registration.

The current first registration deadline is October 2023, which is less than a year away. It is therefore necessary to amend existing legislation to extend the deadline to ensure sufficient time for substantive policy development and operational and legislative changes to be made to implement the new model.

Industry also needs time to prepare for compliance with UK-REACH. extending the registration deadline will reduce the potential for companies to make ineffective costly investments to comply with the current deadlines and data requirements. This will give them time to plan their business decisions in light of the extended deadline.

An official public consultation is currently out seeking proposals to extend the UK-REACH registration deadline. The public consultation also includes proposals to extend the UK regulator's legislative timetable for compliance review of 20% of registration dossiers under Regulation 41 of the UK-REACH Regulation.

These will need to be amended to ensure that they apply after the relevant registration deadlines have passed, otherwise there may not be any data submitted for review by the agency at that time.

▌List of options

The following table lists the options being considered.

Of these, option 2 is the UK government's preferred option. This would allow officials to receive registration information for the transition period sooner and give the industry sufficient time to respond to UK-REACH.

There is, of course, a third option which is 'do nothing' - no change to the current registration deadlines (i.e. 27 October 2023, 27 October 2025 and 27 October 2027).

If you have any ideas on how to extend the UK-REACH registration deadline, you can also submit your comments to the UK officials via the official website.