Trader/Importer/Distributor registrants based in the UK cannot appoint an OR and will either need to set up an operation in the EU and register or all your customers/downstream users now need to register or have registrations as importers.

The IT platform 'Comply with UK REACH' is used for UK registration maintenance and submissions.  The window for UK manufacturers to claim grandfathering rights into the new UK-REACH system closed at the end of April 2021 . Potential co-registrants will be expected to work together eventually to prepare a single full registration dossier.

EU manufacturers based in the EU can appoint UK based Only Representatives but were not eligible to claim grandfathering rights.  They, along with downstream users who now find themselves as importers, had until 27th October 2021 to submit a DUIN (Downstream User Import Notification)  The window for this is also now closed.  In order to progress to be able to submit registrations, those who submit DUINS must then go on to submit an inquiry dossier in order to be able to participate in data sharing discussions.

The names of those companies that have grandfathered registrations or submitted inquiry dossiers is available on a substance by substance basis through the 'Comply with UK REACH' website (ie not generally available) so those companies can get together to start discussions on data sharing, to agree a lead registrant and work toward a single joint registration.

Authorisations in the name of UK legal entities ceased to exist after 31/12/20.

All UK based chemical manufacturers and users should have audited their supply chains to identify any chemical purchases that cross EU/UK borders to understand the degree to which they are affected and the measures they should have taken.  It is anticipated that some EU manufacturers may not want to commit to the costs of registering substances in the UK if their market would not sustain the costs.

Due to the growing realisation of the costs to industry and doubts of the benefits of implementing a straight replicate of EU REACH in the UK, the the UK (via DEFRA) launched a consultation mid 2022 on a possible extension of the registration deadlines.  As a result of this, it was agreed that all registration deadlines would be delayed by 3 years (meaning the first one for the most hazardous and highest tonnage bands will now not be until October 2026.  The legislation to implement this delay was published in June 2023 and came into force the following month.  This delay also gives the government time to look at the options to refine and prioritise the data requirements so the can be based more on risk rather than purely hazard and tonnage.  To this end, the UK published a policy document in November 2023 outlining its intention to consult on refinements to UK REACH that could both reduce the data requirements and the registration fees.  This consultation for an 'Alternative Transition Model' was launched in May 2024 and was open for a 3 month comment period.  The aim of the new model is to radically reduce the costs for industry and the regulator.  The expectation is that the data requirements for UK REACH will be radically simplified.  Only substances registered above 1000 tpa will need to have any data submitted.  All that will be required are PNECs, DNELs, a PBT assessment, biodegradability data and certain physicochemical data (a subset of the current annex VII.)  It should be noted however that this is only for transition substancees - new substances never before registered would still need to have the full dataset available, depending on tonnage.  The trade off for reduced hazard data is that the alternative model would require enhanced data on uses and substance exposure during use.  However, the requirement for wide consultation on the new model and the amount of work that will be required to develop the detail means that it is now apparent there is insufficient time before the first deadline of the end of the transition period in October 2026 for high tonnage and the most hazardous substances.  The UK launched a consultation on 14/7/25 on further postponing the transition deadlines by another 2.5 to 3 years.  The options being consulted on are (for >1000 tpa, 100-1000 tpa and <100 tpa):

• Option 1: October 2029, October 2030, October 2031
• Option 2: April 2029, April 2031, April 2033
• Option 3: April 2029, April 2030, April 2031

The consultation runs until 8/9/25 and can be found here.  Legislation will be required to implement the new deadlines.  We can be sure that they will be delayed, just not which opption.

Again, as part of the transition process, the UK radically overhauled the fee structure from the start of April 2025, greatly reducing registration fees.  For the registration of new substances, these are now based only on company size.  Tonnage variations and the distinction between joint and single registrations now disappear.  All fees are now very similar to the old fee structure for 1-10 tpa substances.  Other fees are also amended.  The fees have been reduced since the old fees directly read across from EU REACH are not justified based on the amount of work that needs to be done to support these substances in the UK.

Trade issues

Now that the UK has left the European single market and customs union, movement of goods between the UK and EU will operate in a different way.  There is a deal with the EU which allows tariff and quota-free trade between the UK and EU. Trade between the UK and non-EU countries has reverted to World Trade Organisation terms unless there is a continuity agreement with the country in question. These continuity agreements are essentially just a roll-over of the existing EU free trade agreement with that country (of which we were part until 31 ^st December 2020).  Of the 70 countries covered by an FTA with the EU, about 60 are now covered in roll-over agreements with the UK.

Looking ahead, we can expect some levels of divergence in trade policy between the UK and the EU which may impact upon movement of chemicals, with potential implications for tariffs, quotas, customs procedures, and excise movements.

If you would like further information or guidance on what you should be doing whether it be on REACH or trade policy issues,  please get in touch with via the Contact menu option.