Superseded If you are working to October 2026, 2028 or 2030, your plan is out of date
Those were the deadlines set by the 2022 extension. Following a Defra consultation that drew 210 responses, the government has legislated to move them back a further three years, because it could not complete the Alternative Transitional Registration model (ATRm) before the first deadline fell due.
The current timeline
Which deadline applies to you depends on annual tonnage and hazard profile — the higher the volume or the greater the concern, the earlier you submit.
| Deadline | Applies to |
|---|---|
| 27 October 2029 |
Substances manufactured or imported at 1,000 tonnes a year or more; CMR substances (carcinogenic, mutagenic or toxic for reproduction, category 1A/1B) at 1 tonne a year or more; substances very toxic to aquatic organisms at 100 tonnes a year or more; candidate list SVHCs listed on or before 27 October 2027. |
| 27 October 2030 |
Substances manufactured or imported at 100 tonnes a year or more; candidate list SVHCs listed between 28 October 2027 and 27 October 2028. |
| 27 October 2031 | All other substances manufactured or imported at 1 tonne a year or more. |
Who these deadlines are for
The transitional deadlines apply to companies that secured their place in the transitional regime at the time of EU exit — through grandfathering or a Downstream User Import Notification. They are the date by which the full registration data must arrive, not the date the obligation started.
New substances have no transitional period
If you did not grandfather and did not submit a DUIN, you are not in the transitional regime. A new UK REACH registration must be submitted and validated before you manufacture or import at one tonne a year or more. There is no 2029 to wait for.
What the ATRm might change
The Alternative Transitional Registration model is the government's attempt to reduce the cost of rebuilding a GB chemicals database that largely duplicates data already held in the EU. The declared intent is to require less full study data and lean more on hazard information companies can access without repurchasing letters of access.
The design is not finalised and has not been legislated. What that means practically:
- Do not assume your data requirement will shrink. Until the model is law, plan against the current Annex VII–X requirements.
- Do the work that survives either outcome. Substance identity, tonnage confirmation, role analysis, exemption screening and inventory of the data you already own are needed under any model.
- Do not buy letters of access early. This is the one cost that could be materially reduced. It is also the largest.
The deadlines that did not move
The extension covers transitional registration submissions only. Everything else runs on its own clock:
| Obligation | Timing |
|---|---|
| New substance registration | Before first manufacture or import at ≥1 t/y |
| Tonnage band increase | Update the dossier before exceeding the next band |
| Safety data sheet updates | Without delay on new hazard information; recipients updated within the previous 12 months |
| GB CLP classification and labelling | Applies now, independently of registration status |
| Candidate list SVHC in articles above 0.1% | Notification and supply chain communication duties apply now |
| HSE evaluation decisions | The deadline stated in the decision itself |
| PPORD exemption | Five years from notification, extendable |
Why 2029 is not as far away as it looks
A registration is not a form. For a substance with real data gaps, the critical path runs: substance identification and analytical characterisation → data gap analysis → negotiation of access to existing studies or commissioning of new ones → non-testing evidence where studies can be avoided → dossier construction → chemical safety assessment → submission → HSE completeness check.
Where new vertebrate studies prove unavoidable, testing proposals must themselves be submitted and decided before the work begins. Two to three years of lead time on a higher-tier substance is normal, not cautious.
Reflects the extension of the UK REACH transitional registration submission deadlines to 27 October 2029, 2030 and 2031, and the ongoing development of the ATRm. Deadlines under active policy review change; confirm the current position for any decision with financial consequences.