What is covered
UK REACH regulates substances — on their own, in mixtures, and in certain articles. It applies to chemicals placed on the market in England, Scotland or Wales.
| Form | Treatment |
|---|---|
| Substance on its own | Registrable at ≥1 t/y by its manufacturer or importer. |
| Substance in a mixture | The mixture is not registered. Each component substance is, based on the tonnage of that substance you place on the market across all your products. |
| Substance in an article | Registrable only where intended to be released in normal use, at ≥1 t/y. Candidate list substances above 0.1% w/w carry separate notification and communication duties. |
| Polymer | Exempt from registration; the monomers and other reactants above 2% w/w are not. Detail |
| Intermediate | Non-isolated: outside scope. Isolated: registrable on reduced requirements under strictly controlled conditions. |
The territory question
UK REACH applies to Great Britain: England, Scotland and Wales. Northern Ireland continues to apply EU REACH under the Windsor Framework.
The practical consequence is that "the UK" is not one chemicals market. Movements that feel domestic can be regulatory events:
- Bringing a substance from Northern Ireland into Great Britain is an import for UK REACH purposes.
- Supplying from Great Britain into Northern Ireland places goods on an EU REACH market.
- A business trading across the whole UK may owe both a UK REACH registration and an EU REACH registration for the same substance.
The five roles
Everything in UK REACH follows from your role. The same drum of solvent creates a registration duty for one company and none for another, depending purely on how it arrived.
Manufacturer
Produces a substance within Great Britain. Registers at one tonne a year or more. Also counts if you extract a substance from natural material.
Importer
Physically brings a substance into GB from outside it — the EU, Northern Ireland or anywhere else. The registrant is whoever is responsible for the import, which is usually the party named on the customs entry, not the party that placed the order.
Only Representative
A GB-established entity appointed by a non-GB manufacturer to carry the importer's obligations. Where one exists and covers your volume, your import is treated as a downstream use. How it works →
Downstream user
Uses a substance in an industrial or professional activity, sourced within GB. No registration duty, but you must keep within the conditions of the registered uses — or run your own chemical safety report for a use outside them.
Distributor
Stores and supplies without using. No registration duty unless you also import. You do carry supply chain communication obligations in both directions.
Consumers and retailers
Not duty holders for registration. Retailers supplying to the public have SDS and information-on-request duties for candidate list substances in articles.
The most expensive mistake in scope analysis
Companies assume that buying from a European supplier makes them a downstream user. It does not. If you are the one importing into Great Britain, you are the importer and the registrant — no matter how large or how compliant your supplier is on the other side. The only thing that changes this is an Only Representative appointed for the GB market.
Calculating your tonnage correctly
Tonnage is calculated per substance, per legal entity, per calendar year, and it is the total you manufacture or import — not the amount you sell, and not the amount of finished product.
- Aggregate the same substance across every mixture and every product line.
- Count material imported for your own use as well as for resale.
- Include samples, trial quantities and free-of-charge material unless separately exempt.
- Do not aggregate across group companies — each legal entity stands alone.
- For substances registered in earlier years, a three-year average is normally used.
What each tonnage band requires →
Regulations that sit alongside, not inside
UK REACH is not the whole of GB chemicals law. These run in parallel and have their own duties:
| Regime | Covers |
|---|---|
| GB CLP | Classification, labelling and packaging. Applies regardless of registration status. |
| GB BPR | Biocidal products and active substances. |
| GB PPP | Plant protection products. |
| Cosmetics, food contact, medicines, detergents | Sector regimes with their own approval routes. |
| COSHH | Workplace exposure control — the occupational duty, distinct from market access. |
General information on the scope of UK REACH. Role determination on a specific supply chain depends on contractual and customs facts — send us the arrangement and we will assess it.