REGAFFAIRS AI
Guide · 2026-11-03 · 6 min

REACH United Kingdom rules and UK Candidate List explained

UK REACH applies in Great Britain, while EU REACH applies in Northern Ireland. Check separate Candidate Lists, supplier duties and updated deadlines.

REACH in the United Kingdom follows two systems: UK REACH applies in Great Britain, while EU REACH applies in Northern Ireland. The systems have separate Candidate Lists, so an EU addition does not automatically become a GB addition. HSE explains the territorial split, and Defra's February 2026 policy sets out how GB reviews EU additions.

The position below was checked on 3 November 2026. Suppliers need to establish which list applies, then separate information duties from notification and authorisation controls.

Which REACH system applies to your market?

Great Britain means England, Scotland and Wales. A business placing chemicals on the GB market must assess UK REACH requirements. EU REACH continues to apply in Northern Ireland. Businesses active in both markets may need to comply with both systems, which operate independently. Start with the destination market rather than treating a UK-wide supplier declaration as sufficient. Source: HSE.

For a GB Candidate List check, use HSE's UK Candidate List. It contains substances of very high concern, or SVHCs, identified through Article 59. All substances on the EU Candidate List when UK REACH came into force were carried onto the UK list. That shared starting point does not establish that the lists remain identical. Sources: HSE and Defra.

Ask which jurisdiction and list a supplier checked. A statement about EU Candidate List status alone does not settle GB status, or the reverse. Check the substance against the applicable live list before deciding which supplier duties follow.

What changed for the UK Candidate List in February 2026?

Defra published its new approach on 24 February 2026. EU additions since 1 January 2021, and future EU additions, will be reviewed and added to the UK Candidate List where appropriate. GB also retains the ability to propose other substances that meet Article 57 criteria. Source: Defra's current approach.

This is a review policy. It does not itself add every EU-listed substance to the GB list. A policy announcement or proposal is therefore not enough evidence of a completed UK listing. Use HSE's live list for a substance-level decision. Sources: Defra and HSE's Candidate List.

The February policy also states that the 2021 interim principles no longer apply. Those earlier principles linked proposals to suitability for authorisation and a Regulatory Management Options Analysis, or RMOA. The government withdrew that paper on 24 February 2026. Do not use its selection conditions as current mandatory prerequisites for Candidate List proposals. Sources: current policy and withdrawn interim principles.

Article 57 criteria are not proof of listing

Article 57 concerns the properties that can qualify a substance as an SVHC. HSE identifies these groups:

  • Carcinogenic, mutagenic or toxic to reproduction substances meeting GB CLP category 1A or 1B criteria.
  • Persistent, bioaccumulative and toxic substances, or very persistent and very bioaccumulative substances, under Annex 13.
  • Substances with an equivalent level of concern identified case by case, including relevant endocrine-disrupting properties.

These properties establish potential eligibility, not actual Candidate List membership. Source: HSE's SVHC overview.

Identification follows a separate process. Publication of an Annex 15 dossier starts a six-week consultation on substance identity or hazard properties. Where comments are submitted, HSE has 45 days after consultation ends to decide. Its Registry of SVHC Intentions until Outcome records proposals and outcomes. A registry proposal does not prove that the substance has joined the Candidate List. Source: HSE.

Does Candidate List inclusion mean a ban?

No. Candidate List inclusion can lead to consideration for the Authorisation List, but those are separate stages. It does not mean every listed substance needs authorisation for every use. Check the applicable control rather than treating the word "SVHC" as a ban. Source: Defra.

Listing does create supplier duties. Which duty applies depends on whether you supply a substance, a mixture or an article. Article communication and producer/importer notification also have different thresholds. Source: HSE.

Supplier duties after UK Candidate List inclusion

The distinction between "above 0.1%" and "0.1% or higher" matters. So does the difference between an article and a mixture. Use the relevant row rather than one general SVHC threshold.

SituationDuty or check
Article contains a listed substance above 0.1% by weightGive the recipient enough information for safe use, including at least the substance name.
Consumer requests information about such an articleProvide equivalent information within 45 days.
Supply of a UK Candidate List substanceSupply a safety data sheet, or SDS.
Non-gaseous mixture is not classified as hazardous under GB CLP and contains a listed substance at 0.1% by weight or higherSupply an SDS on request.
Article producer/importer exceeds both notification thresholdsAssess HSE notification and any applicable exemption.

The communication and SDS requirements above come from HSE's SVHC overview. Do not attach a one-tonne threshold to article communication: that threshold belongs to the separate notification test.

For notification, the listed substance must exceed 0.1% by weight in the articles and total over one tonne per producer/importer per year. Both conditions apply. HSE specifies notification no later than six months after inclusion. Source: HSE's substances-in-articles notification guidance.

Article 7 provides exemptions from notification. These include a substance already registered for that use, or exclusion of exposure during normal or reasonably foreseeable use, including disposal. The exposure exemption requires appropriate instructions to recipients. An exemption from notification does not remove every communication duty. Source: Article 7.

Latest UK REACH update on registration deadlines

The transitional registration deadline extension is enacted, not merely proposed. The REACH (Amendment) (No. 2) Regulations 2026, SI 2026/849, were made on 16 July 2026. They came into force on 6 August 2026 and changed the transitional submission years to 2029, 2030 and 2031. Source: the enacted instrument.

HSE gives the deadlines as 27 October 2029, 27 October 2030 and 27 October 2031. The applicable date depends on tonnage and toxicity, including Candidate List status. Use HSE's applicability table rather than choosing a deadline from tonnage alone.

These are transitional deadlines. They are not permission for every new importer or manufacturer to wait, and a downstream user import notification, or DUIN, is not a pre-registration. Source: HSE. The deadline amendment does not itself enact the alternative transitional registration model or remove registration data requirements. Source: SI 2026/849.

REACH and COSHH address different duties

REACH does not replace workplace exposure controls. HSE explains that REACH and COSHH sit side by side, and extra controls identified by a COSHH assessment still apply. A supply-chain REACH check therefore does not complete the workplace assessment. Source: HSE's REACH and COSHH guidance.

What to check in a supplier response

Record the destination market, the applicable list and the substance's actual entry. Then assess the duty for your supply-chain role. A supplier declaration for one market does not settle the requirements in the other. If transitional registration arrangements apply, check the relevant deadline separately. Sources: HSE on scope, SVHC duties and transitional deadlines.

When reviewing an article supplier's response, check whether it addresses safe-use information or only the notification threshold. A statement that annual quantities are below one tonne does not answer the communication question. For a non-hazardous mixture, ask separately whether an SDS is available on request. These checks use different tests, even when they concern the same Candidate List substance. Source: HSE's supplier-duty guidance.

RegAffairs AI answers how UK REACH differs from EU REACH. For GB substance-level decisions, HSE's UK Candidate List is the official list to check.

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