10 Jul 2025
Understanding changing UK REACH requirements is essential for chemical manufacturers as U.K. regulations now differ notably from the former EU REACH rules. As the U.K. continues to shape its post-Brexit regulatory landscape, quick adaptation is needed to maintain market access and avoid costly delays or penalties. The new Alternative Transitional Registration model (ATRm) aims to address these industry challenges and simplify compliance. Here’s what to know about UK REACH’s latest status, upcoming deadlines and how ATRm may influence strategic planning and risk management.
What is UK REACH?
UK REACH was established by transposing EU REACH into U.K. law following Brexit. To ease the transition, the U.K. government introduced temporary measures such as:
- Grandfathered registrations
- Downstream User Import Notifications (DUINs)
- New Registrations of Existing Substances (NRES)
These transitional arrangements allowed continued market access while full registration requirements were phased in.
Key registration deadlines
The phased deadlines for full UK-REACH registration are as follows:
| Deadline | Tonnage Band | Hazardous Properties |
|---|---|---|
| 27 Oct 2026 | 1000+ tpa | CMR (≥1 tpa), very toxic to aquatic organisms (≥100 tpa), Candidate list as of 30 Dec 2023 |
| 27 Oct 2028 | 100–1000 tpa | Candidate list as of 27 Oct 2026 |
| 27 Oct 2030 | 1 tpa | All other substances |
Understanding the ATRm: What it means for you
Recognizing the financial burden of duplicating EU REACH data, the U.K. Department for Environment Food and Rural Affairs (DEFRA) proposed the Alternative Transitional Registration model (ATRm). This model aims to:
- Reduce the estimated £2 billion ($2.7 billion) cost to industry
- Minimize unnecessary animal testing
- Improve regulatory efficiency and data collection on substance use and exposure
A public consultation on the ATRm closed in July 2024, and DEFRA is currently analyzing feedback. A summary of responses is expected sometime in 2025.
Current industry options
With no final ATRm guidance yet published, chemical manufacturers face three main paths:
1. Proceed with full registration
- Use existing transitional arrangements (grandfathered, DUINs, or NRES)
- Negotiate access to EU REACH data (potentially repurchasing rights)
- Prepare and submit a full registration dossier and Chemical Safety Report (CSR) by 27 Oct 2026
2. Prepare for ATRm while staying proactive
- Continue benefiting from transitional arrangements
- Begin gathering use and exposure data as outlined in the 2024 consultation
- Prepare to submit a dossier by the 2026 deadline, assuming ATRm guidance is released in time
3. Wait for further DEFRA announcements
- Hope for another deadline extension
- Risk non-compliance if no extension is granted
What should you do now?
While the details of the ATRm are still being finalized, now is the time to prepare for what’s ahead. By staying informed and preparing for upcoming deadlines, you can keep your operations running as smoothly as possible. When you need further assistance navigating these changes, we're here to help.
Learn more about our global regulation support across Europe and UK REACH experience.