The Blog

The UK government has announced a new strategic approach to adding Substances of Very High Concern (SVHCs) to the UK REACH Candidate List. This is an important shift for businesses operating in the United Kingdom (Great Britain), particularly those trading with the EU.

What is changing

1. The 2021 interim principles no longer apply

In 2021, Defra and the Welsh and Scottish Governments had agreed the following interim principles for including SVHCs on the Candidate List in UK REACH:

• Including SVHCs on the Candidate List should be used to encourage substitution away from particularly hazardous substances.
• A substance should not be proposed for inclusion on the Candidate List unless it is a good candidate for the Authorisation List.
• Regulatory Management Options Analysis (RMOA), informed by calls for evidence, should be used to determine if inclusion on the candidate list is the correct route.

As of 24 February 2026, the 2021 interim principles no longer apply. The UK government has replaced them with a new strategic approach that will:

• Draw more from regulatory decisions in other jurisdictions, especially the EU, and
• Review and align UK Candidate List additions with EU REACH SVHC updates where appropriate.

This is a notable post‑Brexit shift, instead of limiting additions only to those seen as strong candidates for authorisation, the UK will systematically consider EU SVHC additions (since 1 Jan 2021) for inclusion on its own list.

2. The UK will more closely align its Candidate List with new EU REACH SVHC additions

3. Expect more substances to be flagged as SVHCs

Total number of substances currently on the UK REACH SVHC Candidate List: 209 substances

This is fewer than the EU REACH Candidate List, which currently has 253 substances.  It is important to note that historically, when UK REACH came into force, all substances that were on the EU REACH Candidate List at that time were carried over to the UK list.  Since then, the UK list has not been updated as regularly as the EU list, so its count has lagged behind the EU total because additions require UK assessment and formal listing.

4. Increased regulatory pressure to substitute hazardous substances with safer alternatives

5. More certainty for UK–EU supply chains, but also more compliance expectations

Why it matters

Inclusion on the Candidate List brings new communication duties and increases the likelihood of future authorisation requirements or restrictions.

The UK retains the ability to propose additional SVHCs independently of the EU, ensuring ongoing protection and regulatory flexibility. 

→ While the UK will now more closely consider EU SVHCs, including those added since 1 January 2021, each substance will still undergo a UK assessment and will only be added to the UK Candidate List where appropriate.

Actions to consider now:

• Review your chemical portfolio and supply chain
• Identify substances added to the EU Candidate List since 2021
• Start substitution planning early
• Make sure your SDS and customer communications are ready
• Track updates from Health and Safety Executive (HSE) and Department for Environment, Food and Rural Affairs (Defra)