The United Kingdom’s (UK) Department for Environment, Food and Rural Affairs (Defra) began a public consultation on July 14, 2025, on its proposals to extend the UK REACH transitional registration submission deadlines. UK REACH requires businesses to register with the Health and Safety Executive (HSE) chemicals that are placed on the market in Great Britain (GB). According to Defra, when the UK left the European Union (EU), “information on substances on the GB market which had been registered with UK REACH was not passed to the HSE.” The substances in question have remained on the GB market, but this information still needs to be registered with UK REACH. As reported in our July 12, 2023, blog item, UK REACH was amended in 2023 to extend the deadlines three years to October 2026, October 2028, and October 2030. Defra’s preferred option is to extend the deadlines to October 2029, October 2030, and October 2031. Comments are due September 8, 2025.

The UK REACH alternative transitional registration model (ATRm) will specify what information is required for registration. As reported in our June 28, 2024, blog item, Defra held a public consultation in 2024 on proposals developed under the previous government administration. According to Defra, “[t]he current government, in cooperation with the Devolved governments in Scotland and Wales, is considering the next steps.” Because the design of the ATRm is still under review, Defra states that it “cannot confirm” exactly what information industry will be required to provide by the current submission deadlines. Defra expects that the final information requirements “will not exceed those outlined in the 2024 ATRm consultation,” however.

Since it is no longer possible to deliver the legislative changes to implement ATRm before the current first submission deadline in October 2026 with a “suitable” transition period, Defra is consulting on revised transitional submission deadlines that would provide sufficient time for the government to complete the ATRm and for industry to prepare to comply. The proposed new deadlines under consultation are:

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

Defra states that it prefers Option 1 “as it allows time to finalise the design and implementation of the ATRm and provides industry with a transition period of approximately two years.” According to Defra, moving from a two-year gap to a one-year gap between deadlines would provide sufficient time for industry to gather and submit information, “while managing down the overall period before the regulators are in receipt of complete registration data.”

Defra also seeks comment on the government’s proposal to extend the dates for the requirement on HSE to carry out compliance checks on 20 percent of the registration dossiers received. This applies under UK REACH Article 41(5). Defra notes that at present, this duty aligns with the current submission deadlines.