UK REACH: when chemicals rules apply to what you import
Most buyers import finished goods, not chemicals — so when does UK REACH actually bite? The one-tonne rule, the deferred deadlines, and what to ask suppliers.
Substances, mixtures and articles are treated differently
UK REACH is built around substances. Most substances manufactured in or imported into Great Britain at one tonne or more per year have to be registered — polymers and substances in certain exempt annexes sit outside it — and that is what catches importers of raw chemicals, coatings, adhesives and cleaning products.
Most sourcing buyers are importing articles — a chair, a lamp, a bottle — rather than substances. Articles are generally not registrable in the same way. The exception worth knowing: where a substance is intended to be released from the article in normal use and exceeds one tonne a year, it does need registering. Scented products, fragranced toys and filled markers are the usual examples.
The one-tonne threshold, and the deadlines that moved
Where registration does apply, the trigger is one tonne per year of the substance, per importer. Below that you are outside the registration duty, though other duties can still apply.
The transitional deadlines have been extended, and now fall on 27 October 2029, 2030 and 2031 depending on tonnage band and hazard profile. If your business was a downstream user or distributor under EU REACH before 2021, a downstream user import notification is what preserves access to those deferred dates — worth checking whether one was ever filed, because the extension only helps businesses that are inside the transitional route.
Substances of very high concern in the things you buy
The practical REACH question for a sourcing buyer is whether a candidate-list substance of very high concern is present above 0.1% by weight. Two duties follow. If it is above 0.1% and totals more than one tonne a year, you must notify HSE, no later than six months after the substance is added to the candidate list. Separately, above 0.1% you must pass on enough information for the article to be used safely — at minimum the substance name — to anyone you supply, and answer consumer requests free of charge within 45 days. In a complex article the 0.1% applies to each component part rather than the whole product, which is exactly why component-level answers matter.
Restrictions matter more than registration for most importers. Certain substances are restricted or banned in specific uses — plasticisers, flame retardants, azo dyes and heavy metals come up repeatedly in consumer goods from China — and a restricted substance in your product is a compliance failure regardless of tonnage.
What to ask a Chinese factory
Ask for a substance declaration covering the restricted substances relevant to your product type, and for test reports from an accredited laboratory rather than a self-declaration on factory letterhead. Chinese factories are used to these requests from EU buyers, so the documents usually exist.
Be specific about the material and the component. A declaration covering 'the product' is weak; one covering the coating, the plastic part, the solder and the textile is useful. Substituted materials between sample and production are the usual reason a previously compliant product fails.
Great Britain and Northern Ireland differ
UK REACH applies in Great Britain. Northern Ireland continues to follow EU REACH under the Windsor Framework, so the two regimes and their candidate lists can diverge. If you supply both, check both rather than assuming one answer covers the United Kingdom.
Because the detail moves and the deadlines have already shifted once, treat this guide as orientation and confirm your own position with HSE guidance before you rely on it. We build restricted-substance requirements and test scope into the specification, so the evidence exists before goods ship.
Frequently asked questions
Do I have to register under UK REACH if I import finished products?
Usually not. Registration applies to substances manufactured in or imported into Great Britain at one tonne or more a year. Importers of articles such as furniture or electricals are generally outside the registration duty, but restrictions on substances contained in those articles still apply.
What is the tonnage threshold?
One tonne per year per importer for the substance concerned. Below that the registration duty does not apply, though other duties can.
When are the UK REACH deadlines?
The transitional registration deadlines were extended to 27 October 2029, 2030 and 2031, depending on tonnage band and hazard profile. Access to those deferred dates depends on being inside the transitional route.
Does UK REACH apply in Northern Ireland?
No. UK REACH applies in Great Britain; Northern Ireland follows EU REACH under the Windsor Framework, so the two can diverge.