The countdown to 2026: is your registration on track?

While it may seem that the first major UK REACH registration deadline of October 2026 is far off, it’s essential to start preparing now. Proactiveness in understanding the actions required and the regulatory changes on the horizon are key to maintaining compliance. Non-compliance may result in your company being unable to access the UK market. 

The UK REACH landscape: a glimpse into the future

Although we are still awaiting feedback from DEFRA following the UK REACH consultation last year, there are some hints to the direction of travel from the Government. On the 17 March 2025, a new approach to ensure that both regulators and regulations support growth was announced. Even though chemicals are not mentioned in much detail, this could potentially indicate the thinking behind the Government’s approach to UK REACH and international cooperation to reduce regulatory burdens. However, we will have to wait for the amended UK REACH regulations to find out the detail and exactly what data will need to be submitted.

Key actions to prepare for 2026

Despite the delays on what the final data package will look like, there are several basic actions that companies should be taking in preparation. Even if your substance does not need to be registered until a later deadline, it is still worth considering the below actions:

Have you submitted a DUIN?

• If so, a DUIN will not allow access to the substance group where selection of a lead registrant (discussions on cost sharing, etc.) will be taking place. To be part of this group an inquiry dossier will need to be submitted. It is important this is submitted well before the October 2026 deadline to ensure you are involved with these discussions within the substance group.

Prepare analytical data for inquiry dossiers

• Inquiry dossiers require analytical data to confirm substance ID. Laboratories are going to get very busy ahead of the deadlines so it is worth planning for and obtaining this information as soon as possible to make your registration process smoother. This is especially the case if you have difficult to test substances that may require specialist techniques beyond the standard REACH package.

Get involved in the substance group

• Even if you don’t need to register at the first deadline, you should consider getting involved in the substance group so that your substance uses are included in the Chemical Safety Report (CSR).

Identify your lead registrant

• For many substances the Lead Registrant role is yet to be claimed – companies need to confirm what requires registration and allow time to gather the required data, which may be extended if a lead registrant is not selected.

Fees update

Changes to UK REACH registration fees were announced on 10 March and were enforced on 1 April 2025. The updates introduce both increases and reductions in different areas, and it’s important to reassess budgets considering these changes. The changes include:

• A flat fee of £2,222 for registration for all tonnage bands, leading to significant increases for the lowest tonnage band (1-10 tonnes) but significant reductions for higher tonnage bands.
• Significantly reduced registration fees for SMEs across all tonnage bands.
• A flat fee for updates for tonnage range adjustments again representing a significant increase for the lowest tonnage band but a significant reduction for higher tonnages.
• A significant reduction in the fee for legal identity changes.
• Increases in fees for Production and Process Orientated Research and Development (PPORD) notifications but charges for PPORD exemption extensions decrease.
• Increases of approximately 22% in fees for authorisation applications and review of authorisations under UK REACH.

Given these significant fee changes, it is important to review your upcoming budgets and adjust accordingly.

Stay ahead of the curve

The UK REACH registration deadline may still be a while away, but now is the time to start preparing. It’s crucial to stay informed about the upcoming regulatory changes, fee adjustments, and deadlines. Taking the steps outlined here will put your company in a strong position to meet registration deadlines with minimal disruption.

Ensuring you are monitoring the updates from DEFRA and UK REACH can ensure compliance is maintained. By staying proactive, you’ll ensure that you are able to continue placing your products on the UK market, your registrations are completed on time, your costs are well-managed, and your compliance strategies are ahead of the curve.

For more information on how Ricardo can help with UK REACH registrations, from planning your strategy to making new registrations to Only Representative services, see our dedicated UK REACH page.