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Frequently asked questions
Direct answers to what companies actually ask us. Where the honest answer is "it depends", we say what it depends on.
Do I need to register under UK REACH?
If you manufacture a substance in Great Britain, or import one into Great Britain, at one tonne or more per legal entity per year, and no exemption applies — yes. If you buy inside GB from a GB supplier, you are a downstream user and you do not register. Scope and roles →
My EU REACH registration covers the UK, doesn't it?
No. UK REACH is a separate regulation with a separate regulator and a separate database. An EU registration number has no legal effect in Great Britain unless the registration was brought across through grandfathering. It remains valid for Northern Ireland, which stayed under EU REACH. The differences →
What are the current UK REACH deadlines?
27 October 2029, 2030 and 2031, depending on tonnage and hazard profile. These replaced the earlier 2026, 2028 and 2030 dates, which a great deal of published guidance still shows. The extension was granted so the government could finish designing the Alternative Transitional Registration model. Full timeline →
Can I wait until 2029?
Only if you are in the transitional regime — that is, you hold a grandfathered registration or submitted a DUIN. If you do not, there is no transitional period: a new registration must be valid before you manufacture or import at one tonne a year. And even inside the transitional regime, a higher-band substance with real data gaps needs two to three years of lead time. Check your route →
I am not in the UK. Does UK REACH apply to me?
Not directly. It applies to your GB customers, who become importers and registrants when they buy from you. In practice this becomes your problem, because they will consolidate onto suppliers who have removed the burden. Appointing an Only Representative is how you remove it. How it works →
Does my EU Only Representative cover Great Britain?
No. An EU OR acts under EU REACH and covers the EU/EEA and Northern Ireland. Great Britain requires an OR established in Great Britain, acting under UK REACH. If you sell into both, you need both.
Is Northern Ireland covered by UK REACH?
No. Northern Ireland continues to apply EU REACH under the Windsor Framework. This means moving goods from NI into GB counts as an import for UK REACH purposes, and supplying from GB into NI places goods on an EU REACH market. A UK-wide business may need both registrations for the same substance.
What does a UK REACH registration cost?
Our fees start at £4,500 per substance for the 1–10 tonne band and rise with the data set. Outside our fees sit three costs no consultancy can quote reliably in advance: HSE statutory fees, letters of access or data purchase, and laboratory testing where a study is genuinely required. On a higher-band substance, data access alone can exceed everything else combined. Fee bands →
My substance is a polymer — am I exempt?
The polymer is exempt from registration. The monomers and other reactants present in bound form at 2% or more by weight, totalling one tonne a year or more, are not — and registering those is your obligation as the polymer's manufacturer or importer. This is the most commonly misread exemption in UK REACH. Exemptions →
Is there an exemption for small businesses?
No. There are reduced HSE fees for small and medium enterprises, but the obligations are identical regardless of company size. The one tonne threshold is the only volume relief, and it applies per legal entity per substance per year.
We have sold this chemical in Britain for decades. Surely that counts for something?
It does not create an exemption. Historic use gave phase-in substances longer deadlines under the transitional arrangements, not permanent relief. If you are not in the transitional regime, long-standing supply is not a defence.
Can you avoid animal testing?
Often, and the regulation prefers it. Vertebrate testing is a last resort in law. QSAR predictions, read-across, weight of evidence, exposure-based adaptation and data waivers can satisfy many information requirements — but only when properly built. An asserted read-across is a rejected dossier; a documented one is accepted evidence. Where each applies →
Is a registration number an approval?
No. It confirms you supplied the required information and paid the fee. It does not endorse safety, does not approve a specific use, and gives no protection against a later compliance check, candidate listing or restriction. The four pillars →
What happens if we are importing without a registration?
You are placing a substance on the GB market unlawfully. Enforcement sits with HSE, the Environment Agency and Border Force, with powers including prohibition notices, seizure and prosecution. The commercial risk usually arrives sooner than the regulatory one — as a customer audit question you cannot answer. Tell us the position and we will map the shortest route back to compliance.
How long does a registration take?
Where the data already exists and the rights are in place, a few months. Where there are real gaps, one to three years — because letters of access have to be negotiated, non-testing evidence built, and any new vertebrate study preceded by a testing proposal that HSE must decide before the work begins.
Do you work for other consultancies?
Yes, white-label, on the technical layer: data gap analysis, QSAR, read-across, literature review, robust study summaries and dossier construction. Your client relationship remains yours and we do not approach your clients.