UK REACH for Chemical Importers

UK REACH treats a GB-established importer much like a manufacturer. If you import a substance into Great Britain, on its own or in a mixture, at one tonne or more a year, you must register it with the Agency (HSE), or you cannot place it on the market. How soon you must do that depends on your status before Brexit:

• Grandfathered registrants and DUIN notifiers have deferred deadlines. S.I. 2026/849 moved these to 27 October 2029, 2030 and 2031.
• New importers must register in full before their imports reach 1 tonne a year.

Approach: I read the GB text of UK REACH (assimilated Regulation 1907/2006, latest revision on legislation.gov.uk). I checked it against HSE's guidance pages and Defra's response to its consultation on the deadlines. The 2026 amending instrument itself would not open, so I took its content from the official search listing and the Defra response.

1. Are you an "importer"?

• Definitions: "Import" means "the physical introduction into Great Britain". An "importer" is a person "established within Great Britain who is responsible for import". "Import shall be deemed to be placing on the market" ^[1].
• Non-GB suppliers: a non-GB company cannot be the importer. It "may by mutual agreement appoint" a GB-established only representative (OR) to take on the importer obligations. The non-GB manufacturer "shall inform" its GB importers, who are then "regarded as downstream users" ^[2].

2. Core registration duty

• "No data, no market": substances "shall not be manufactured in Great Britain or placed on the market unless they have been registered" where this is required ^[3].
• Tonnage trigger: any manufacturer or importer of a substance "in quantities of one tonne or more per year shall submit a registration to the Agency", with a fee ^[4].
• Polymers: importers must register the monomers if both of these apply ^[4]:
  • the monomers make up 2% w/w or more of the polymer; and
  • they total one tonne or more a year.
• When you may start importing: you may start or continue importing if the Agency gives no indication to the contrary within three weeks of the submission date ^[5].
• New importers in practice: HSE says "a complete registration will be required prior to the manufacture or import into GB reaching 1 tonne per year". The steps are:
  1. Submit an Article 26 inquiry.
  2. Share data with existing registrants and grandfathered registrants.
  3. Submit the dossier and fee through the Comply with UK REACH service (HSE, new registrants).

3. Transitional routes (Title 14A)

Route	Who qualifies	What you must do
Grandfathered registration (Arts 127A/127B)	A GB-established registrant holding an EU REACH registration immediately before IP completion day	The registration becomes a GB registration with no fee. Some basic dossier data was due within 120 days. The rest of the Article 10 information is due within the "relevant post-IP completion period" [6][7]
DUIN (Art 127E)	A GB downstream user or distributor under EU REACH at any time in the 2 years before IP completion day, importing from an EU registrant, an EU downstream user or an EU-appointed OR	You are treated as a downstream user or distributor, not an importer, for those imports. You had to send the Agency information within 300 days: more at 10 t/y or more, including safety data sheet information [8][9]. Your supplier may appoint a GB OR to take these duties on [10]
Northern Ireland goods (Art 139A)	Importers of qualifying NI goods from an NI supplier that is an EU REACH registrant or downstream user	You are treated as a downstream user. You must notify the Agency "before" the import, with more information at 10 t/y or more [11]

DUIN in practice:

• HSE says the original notification deadline was 27 October 2021, but eligible companies can still submit.
• Companies that were not previously a registrant, downstream user or distributor under EU REACH "must pursue full registration instead" (HSE, DUIN).
• Respondents to Defra's consultation said DUIN rules stop them importing more than 999 kg a year unless they imported the substance during the 2-year qualifying window. The government made no specific commitment to change this (Defra government response).

Current deadlines (Art 127P(4B), as amended by S.I. 2026/849 from 6 August 2026) ^[12]:

• 27 October 2029:
  • substances on the candidate list by 27 October 2027;
  • CMR Category 1A/1B substances at 1 t/y or more;
  • Aquatic Acute 1 or Aquatic Chronic 1 substances at 100 t/y or more;
  • all substances at 1,000 t/y or more.
• 27 October 2030:
  • substances added to the candidate list between 28 October 2027 and 27 October 2028;
  • all substances at 100 t/y or more.
• 27 October 2031: all substances at 1 t/y or more.

The instrument is The REACH (Amendment) (No. 2) Regulations 2026. Defra says it replaced the earlier 2026, 2028 and 2030 deadlines while it finalises the alternative transitional registration model (ATRm) (Defra response).

4. Duties that apply regardless of registration status

• Substances in articles (Art 7) ^[13]:

  • You must register a substance in articles if it totals over 1 tonne a year and is intended to be released.
  • You must notify the Agency of a candidate-list SVHC in articles if it totals over 1 tonne a year and is above 0.1% w/w. This applies six months after the substance is listed, unless you can exclude exposure.

• Safety data sheets (Art 31): an SDS is required for:

  • hazardous substances and mixtures;
  • PBT and vPvB substances;
  • candidate-list substances.

  It "shall be supplied in English". It must be updated "without delay", for example after an authorisation or restriction decision ^[14][15].

• Information on SVHCs in articles (Art 33): if an article contains an SVHC above 0.1% w/w, you must give recipients enough information for safe use, at least the substance name. Consumers who ask must get it free within 45 days ^[16].

• Authorisation (Art 56): an importer "shall not place a substance on the market" if it is on Annex XIV, unless the use is authorised, exempt or within the transitional cases ^[17]. The GB Authorisation List is separate from the EU one, e.g. trixylyl phosphate is entry 47 ^[18].

• Restrictions (Art 67): substances covered by Annex XVII "shall not be manufactured, placed on the market or used" unless they meet its conditions ^[19].

• Record keeping (Art 36): you must keep the information needed for your duties for at least 10 years after you last imported the substance ^[20].

5. Practical takeaways

• If you have a grandfathered registration or a DUIN: your full dossier is due on the 2029, 2030 or 2031 date that matches your tonnage and hazard profile. Under a DUIN, check you stay within the substances and suppliers you notified.
• If you are a new importer: you need a full UK REACH registration before you reach 1 t/y. Alternatively, your non-GB supplier can appoint a GB only representative, in which case you become a downstream user.
• Monitor the GB lists: the GB Candidate, Authorisation and Restriction lists are separate from the EU ones. A candidate-list addition can bring your deadline forward to 2029 or 2030 and triggers SDS and Article 33 duties.