The Blog

On the first day of CHEMUK 2025, an insightful panel session on “UK REACH: How to Survive in ’25” took place, outlining the latest developments and providing guidance on the future direction of UK REACH.

Here is a summary of the key insights shared yesterday at CHEMUK:

The Current UK REACH Landscape:

Since its inception, UK REACH has seen significant activity, with over 9,600 notifications submitted for around 20,000 substances. While substantial progress has been made, there is still an opportunity for late downstream user import notifications (DUINs) to ensure full compliance.

Regulatory Framework:

In the UK, Defra oversees chemical policy, while the Health and Safety Executive (HSE) is responsible for managing authorisations and restrictions under UK REACH.

Alternative Transitional Registration Model (ATRm):

The ATRm aims to reduce the £1–2 billion cost of duplicating EU REACH data for UK registrations. A consultation, held from May 16 to July 25, 2024, garnered 241 responses. The government is currently reviewing the feedback, with further announcements expected once political uncertainties are resolved.

Key Deadlines Coming:

The next major registration deadline is in October 2026. Industry concerns persist about meeting this deadline, especially with pending clarity on ATRm.

Fee Structure Reforms:

Starting in April 2025, UK REACH will implement a flat registration fee of £2,222, expected to save the industry around £40 million over six years. SMEs will benefit from discounted rates.

IT System Enhancements:

Recent updates to the UK REACH IT system include improved tracking, bug fixes, updated guidance, and a new user feedback email channel, aimed at streamlining the user experience.

Authorisations and Restrictions:

As of now, 36 authorisation decisions have been made, with more in the pipeline. Active restriction projects focus on substances like tattoo ink ingredients and per- and polyfluoroalkyl substances (PFAS), particularly in firefighting foams.

PFAS Focus:

PFAS is an increasing public and regulatory concern. The UK is developing restrictions and considering broader international and domestic actions.

Work Programme and Communication:

There was a delay in publishing the annual REACH work programme, but efforts are ongoing to improve timing. Participants are encouraged to stay engaged, use official guidance, and consider joining user panels for feedback.

Conclusion:

To navigate the evolving regulatory landscape, stay proactive! Track updates, engage with consultations, use available guidance, and ensure your organisation remains compliant with UK REACH requirements. REACHLaw is certainly doing this for our clients, and if you need support, we would be delighted to assist. Contact us to sales@reachlaw.fi