UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the UK's post-Brexit chemicals regulation, enforced by the HSE. It requires registration of substances manufactured or imported into Great Britain above defined volume thresholds, and understanding who holds this responsibility matters when a product is made by a contract manufacturer rather than in-house.

Key points

  • Any GB-based legal entity manufacturing or importing a substance at or above 1 tonne per year must register it with the HSE.
  • Registration applies to substances, not mixtures directly - though the substances within a mixture must be registered if their aggregated import volumes reach 1 tonne or more per year.
  • Manufacturers or importers above 10 tonnes per year typically need to prepare a chemical safety report.
  • Registrants who previously relied on downstream user import notifications (DUINs) face phased transitional deadlines to submit full registrations, depending on tonnage band and hazard profile. These were extended in August 2026 and now run to 2029, 2030 and 2031 - see below.

What This Regulation Requires

UK REACH requires registration of chemical substances manufactured in or imported into Great Britain above the 1 tonne per year threshold, submitted to the HSE as the competent authority. Registration information scales with volume and hazard profile, with higher tonnage bands requiring more detailed safety data, including a chemical safety report above 10 tonnes per year.

Transitional Registration Deadlines

Substances that were already on the GB market when UK REACH began were brought across under transitional arrangements, giving existing registrants and downstream importers a phased period in which to submit full registration dossiers rather than doing so immediately. Those deadlines have now been extended twice.

The original dates were 2023, 2025 and 2027. They were pushed back three years in 2023, to 2026, 2028 and 2030, following disputes over the cost of accessing the data that registrations require. In July 2026 the government made The REACH (Amendment) (No. 2) Regulations 2026 (SI 2026/849), which came into force on 6 August 2026 and extended them again. The current deadlines are:

  • 27 October 2029 - substances on the EU SVHC candidate list before 31 December 2020; CMR substances at 1 tonne or more per year; substances very toxic to aquatic life at 100 tonnes or more per year; and all substances at 1,000 tonnes or more per year.
  • 27 October 2030 - substances added to the UK SVHC candidate list before the first deadline, and all substances at 100 tonnes or more per year.
  • 27 October 2031 - all remaining substances at 1 tonne or more per year.

The extension reflects the fact that the government's proposed Alternative Transitional Registration Model, intended to reduce the data cost of registering, has not yet been brought into effect. The deadlines have moved twice already, so check the current position before making decisions that depend on a specific date.

An extension is not a reason to stop tracking registration status. Substances in the first group - high tonnage, CMR or SVHC - carry the earliest deadline and the greatest scrutiny, and a manufacturer whose registration is incomplete when a deadline passes cannot lawfully continue supplying that substance in Great Britain.

Who It Applies To

UK REACH duties fall on the GB-based legal entity that manufactures or imports the substance - which, in a contract manufacturing relationship, could be either you or your manufacturer depending on who imports the raw materials and where the finished product's substances originate. This needs clarifying explicitly in your commercial agreement.

What This Means for Contract Manufacturing

When you outsource production, establish early who is responsible for UK REACH registration of the substances involved - this isn't always the manufacturer by default, particularly if you're importing certain raw materials yourself or specifying a formulation that uses substances not already registered by your manufacturer. Confirm registration status for key substances before committing to a formulation, and revisit this if you later change suppliers or raw materials.

Frequently Asked Questions

Does my contract manufacturer automatically handle UK REACH registration for our product?

Not necessarily - this depends on who is the GB-based manufacturer or importer of the specific substances involved, so confirm this explicitly rather than assuming it's covered by default.

Do I need to worry about UK REACH if my product is a mixture, not a single substance?

Registration applies to the substances within a mixture, not the mixture itself, so the individual substances still need registration if their aggregated volumes meet the threshold - check this with whoever supplies or imports each substance.

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Last reviewed: August 2026. Regulation and guidance change — verify anything you rely on against the primary source. Tell us if something here is out of date.