UK REACH vs EU REACH

UK REACH started from the same legal text as EU REACH: the EU Regulation became UK law on 1 January 2021 and kept its key principles. Since then the two have run as separate systems. UK REACH covers Great Britain only, while EU REACH still applies in Northern Ireland. The UK regime has its own regulators and decision-makers, its own registration duties and deadlines, and its own candidate, authorisation and restriction lists. A company selling into both markets has to comply with both regimes (HSE, UK REACH explained).

Approach: The regulatory datasets I normally search didn't respond this time, so I couldn't check the GB legal text or the HSE and ECHA lists there. Everything below comes from official HSE, GOV.UK and Defra pages I opened.

Main differences

Area	UK REACH (GB)	EU REACH
Where it applies	England, Scotland and Wales. It regulates "chemicals placed on the market in GB"	The EU, and Northern Ireland "under the terms of the Northern Ireland Protocol" (HSE)
Who decides	HSE gives the scientific advice. The Secretary of State for Defra makes authorisation decisions. Scottish and Welsh ministers must consent where the matter is devolved (GOV.UK)	ECHA gives opinions on EU applications; GB transitional decisions were "informed by" those ECHA opinions (same source)
Only Representatives	Must be "a natural or legal person established in Great Britain" (HSE roles)	Separate EU arrangements
Importers from the EU	GB companies that were downstream users of EU-registered substances "will become importers under UK REACH" and so take on registration duties (HSE roles)	No registration duty for these companies as downstream users
Lists	Copied from the EU lists at the end of 2020, independent since then	ECHA's lists

Registration and transition

• Grandfathering: GB-based holders of EU REACH registrations (manufacturers, importers and GB Only Representatives) could carry them over. They had to send initial information by 30 April 2021, although HSE says "you can still submit" it (HSE grandfathering).
• DUINs (downstream user import notifications): Former GB downstream users and distributors who notified by 27 October 2021 can delay registering. They only need to register if they want to keep importing the substance after the relevant deadline (HSE DUIN).
• Full data deadlines: HSE now gives three dates (HSE grandfathering):
  • 27 October 2029: substances at 1,000 tonnes a year or more, CMRs at 1 tonne or more, very toxic aquatic substances at 100 tonnes or more, and candidate-list substances added by 27 October 2027.
  • 27 October 2030: substances at 100 tonnes a year or more, and candidate-list substances added between 28 October 2027 and 27 October 2028.
  • 27 October 2031: substances at 1 tonne a year or more.
• Change from earlier dates: The previous deadlines were October 2026, 2028 and 2030. Government chose the 2029-2031 timetable in its consultation response (updated 22 December 2025). It said the legislation "will be brought forward in 2026". It also said the later dates give time to "finalise and legislate for the ATRm", the Alternative Transitional Registration model (GOV.UK response).
• 2026 amending regulations: I found two on legislation.gov.uk, the REACH (Amendment) Regulations 2026 (SI 2026/195) and the REACH (Amendment) (No. 2) Regulations 2026 (SI 2026/849). I could not open either text, so I can't say what each one changes.

SVHCs, authorisation and restrictions

• Candidate list: Every substance on the EU candidate list at exit was copied onto the UK list. Substances the EU has added since 1 January 2021 "will be reviewed and added to the UK REACH candidate list where appropriate", so they are not added automatically. HSE can also propose its own SVHCs under Article 59 (Defra approach, 24 February 2026).
• Authorisation (Annex XIV): The EU Annex XIV entries were kept, but "since 31 December 2020 the 2 lists have been independent of each other" (HSE). GB keeps its own register of granted and refused authorisations. For example, the Vertik-Al Limited consortium was refused on 25 August 2026 (GOV.UK).
• Restrictions (Annex XVII): GB runs its own restriction process.
  • PFAS in firefighting foam: Defra, with the Scottish and Welsh Governments, asked HSE for an Annex 15 report on 5 March 2024. HSE then ran consultations under Articles 69-71 of UK REACH (HSE consultation).
  • Lead in ammunition: This is a GB-only restriction decision, dated 27 June 2025 (GOV.UK).
  • EU restrictions since 2021: None of the official pages I opened says whether these apply in GB, so I can't confirm it.
• Overall direction: The 2025-26 work programme aims to be "more aligned with our closest trading partners" and to "draw more from regulatory decision-making in other jurisdictions" (GOV.UK, 31 July 2025).
• Evaluation: HSE aims to "complement, not replicate" EU evaluation work. Until the UK's own registration database is fully populated, it fills gaps for GB from ECHA's public data (HSE).

If you have a particular substance in mind, I can compare its status on the GB and EU candidate, authorisation and restriction lists once those sources are available again.