Research and analysis

RPC Opinion: Extension of the UK REACH Submission Deadlines

Published 31 March 2026

1. Extension of the UK REACH Submission Deadlines

Lead department	Department for Environment, Food and Rural Affairs
Summary of proposal	The proposal is to extend the current UK REACH submission deadlines to allow government time to develop and legislate an alternative transitional registration model.
Submission type	Options Assessment – 28th April 2025
Legislation type	Secondary legislation
Implementation date	TBD
RPC reference	RPC-DEFRA-25048-OA(1)
Date of issue	3 June 2025

2. RPC opinion

Rating[1]	RPC opinion
Fit for purpose	The Department evidences the problem under consideration. The OA has considered a long-list of eight policy options and has used an options framework. The Department justifies the selection of the preferred option as it provides the most effective balance between a quicker receipt of data, whilst mitigating against the risk of industry missing the deadlines.

3. RPC summary

Category	Quality[2]	RPC comments
Rationale	Green	The Department evidences the problem under consideration. However, the OA could be improved by drawing more explicitly on the industry engagement that has taken place. The OA’s argument for intervention is focused on regulatory inflexibility. The OA provides suitable objectives, which follow the SMART framework.
Identification of options (including SaMBA)	Green	The OA has considered a long-list of eight policy options and has used an options framework. However, the OA would be improved by including more detail on this process. The Department has provided a sufficient SaMBA, explaining that the policy is expected to benefit all businesses.
Justification for preferred way forward	Green	The Department has estimated an NSPV for all shortlisted options. The OA also discusses non-monetised impacts. The OA would be improved by detailing the steps taken to reach the NPSV estimate. The Department justifies the selection of the preferred option as it provides the most effective balance between a quicker receipt of data, whilst mitigating against the risk of industry missing the deadlines.
Regulatory Scorecard	Satisfactory	The OA indicates that the proposal will have a positive impact on total welfare, explaining how there will still be a high level of protection for human health and environment. The OA also indicates that the proposal will have a positive impact on business. The Department considers the impact of the proposal on wider government priorities but could further explain how avoiding unnecessary expenses may improve competition and innovation of chemical firms.
Monitoring and evaluation	Satisfactory	The Department outlines the data sources which will be used to underpin this review.
The OA could benefit from including further detail on the nature of these qualitative and quantitative data and how they will be gathered.

4. Summary of proposal

The UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation is one of the main pieces of legislation overseeing chemical manufacture, supply and use in Great Britain (GB).

REACH currently requires data on substances that are manufactured in, or imported into, GB to be registered with the UK Agency - the Health and Safety Executive (HSE). The submission deadline for businesses to submit their data to the HSE was originally set as October 2023 for all registrants. In light of industry concerns at the financial burden, the UK Government proposed the exploration of an Alternative Transitional Registration model (ATRm) as a potential solution, and the deadline for submission was extended by SI in 2023 to allow government time to develop and legislate for the ATRm and to allow industry two years to comply. An impact assessment of that extension was cleared by the Regulatory Policy Committee in 202[3].

However, with the change of government there was a pause to any further consultation and the ATRm has been delayed while the Government considers its approach to chemicals and the implications of the wider EU reset considerations. Government intervention is therefore necessary to extend the current transitional deadlines for data submission to ensure there is sufficient time to allow for substantive development of the policy, and to make operational and legislation changes for the model.

The OA has considered three short-list options for intervention:

• Option 1 (preferred) - Allow a 2-year industry implementation period but reduce to one-year spacing as follows: October 2029, October 2030, October 2031.
• Option 2 - Extend to April 2029, April 2031 and April 2033: this option provides a more ambitious timeframe for industry to submit for the first deadline but retains 2-year intervals.
• Option 3 - Extend to April 2029, April 2030 and April 2031. This option has similar strengths and drawbacks to option 1, with the 1-year intervals, whilst reducing the overall timeline by 6-months.

The OA presents an NSPV of £83m for the preferred option (Option 1), with an EANDCB of -£9.6m (2024 prices, 2024 base year). This is largely driven by a reduction in the present value of REACH registration costs to firms, and familiarisation costs. These estimates have decreased from the estimates presented in the 2023 IA, which saw an NPSV of £170m and an EANDCB of -£17m (2019 prices, 2020 present value). The reason for this reduction is due to the different length of extension and the delay this has had on the costs.  

5. Rationale

Problem under consideration

The OA outlines the problem under consideration, explaining how there is a misalignment between the current deadline for companies to register their chemical data and the implementation timeline for the new transitional provisions (ATRm), meaning businesses would be required to submit data under the current, more costly legal requirements, which the ATRm aims to avoid. The Department evidences this problem, referencing the £2 billion cost faced by industry for completing the registration without the ATRm. However, this evidence is limited, and the OA could be improved by drawing more explicitly on the industry engagement that has taken place to further develop the evidence base and support the problem under consideration. Furthermore, the Department could provide more detail on the business and industry groups who have raised concerns about the lack of clarity from the current mis-sequencing, as this assessment currently provides minimal detail on the consultation, methodology, response rates or representativeness.  

The OA could also benefit from providing further detail on how the ATRm will work in practise to reduce registration costs for industry, as it is not currently clear how the ATRm will function for a lay reader. This would help to explain how the ATRm presents a solution for the existing financial burdens and demonstrate how the proposal solves for the problems under consideration.

Argument for intervention

The OA’s argument for intervention is focused on regulatory inflexibility. The Department explains that maintaining the existing submission deadlines risks legal and regulatory anomaly, resulting in confusion, inconsistent compliance requirements and potential inefficiencies in data submission and regulatory enforcement. The OA could benefit from providing evidence to support these arguments, perhaps utilising evidence from the industry engagement that has taken place. As the intervention further extends an existing deadline extension, the OA could benefit from explaining how the proposal mitigates against further regulatory confusion. The OA could also consider the likelihood of a further extension, and the associated risks.

The OA could also discuss the existence of any market failures to form its argument for intervention, such as the market inefficiencies that would occur if the existing requirements were maintained and businesses were required to purchase EU hazard data.  

Objectives and theory of change

The OA provides suitable objectives, which follow the SMART framework. The theory of change diagram, although fit for purpose, could be improved by further developing the long-term outcomes section to consider the overarching long-term importance of chemical safety. The OA could also benefit from including arrows in the diagram to help illustrate the step-by-step process by which the outcomes can be achieved.

6. Identification of options (inc. SaMBA)

Identification of the ‘long-list’ of options 

The OA has considered a long-list of eight policy options for extending current data submission deadlines, including an option which retains the current 2030 deadline using highly condensed intervals, options which use 1-year intervals and an option which provides a temporary extension. The Department details these options in the OA, describing qualitatively what they would involve and their associated risks. The Department states that it has used an options framework filter to generate the longlist, and that this has been developed alongside stakeholder workshops to develop and scope viable options. However, the OA would be improved by including more detail on this process, such as the discussions that took place with stakeholders and industry experts and how research and other evidence has been used to form the policies. Furthermore, whilst the Department states that it has identified the scope of what would be delivered, the OA could further use the strategic framework filter to demonstrate clearly how the scope and delivery has been incrementally increased for each option. In addition to scope and delivery, the Department could also use the framework filter systematically to build up options that differ based on funding and implementation.

The OA could also benefit from expanding its long-list to discuss other approaches or options that could address the problems under consideration. In particular, the long-list could include changes that focus instead on easing the financial burdens for companies securing data from EU sources. This could be applied in combination with the long-list options that have been set out. The Department could then explain why these have not been carried through to the short-list.

Justification for the short-listed options

The OA presents three short-listed options (Options 1-3), discarding Options 4 through 8 as they do not satisfy the SMART objectives. Whilst the Department has used SMART objectives to rank and discard the long-listed options, clearly explaining the red/amber/green ratings, the OA would be improved by applying the critical success factors (CSFs) to the long-list to display a systematic process of how the longlisted options were discarded to produce a short-list. The Department explains that SMART objectives have been used rather than the CSFs, as CSFs place emphasis on areas such as expenditure and supplier involvement, which are not directly applicable in this area. However, the Department could still use CSFs by adapting them or focusing on other more applicable success factors, such as achievability and value for money. Furthermore, SMART objectives are not an effective method for justifying the generation of the short-list, as it is best practise for all long-list options in an OA to meet SMART objectives.  

The OA should also include the do-nothing option in the shortlist, in line with Green Book guidance. Although the OA explains that the do-nothing option does not deliver the policy objective as it would result in increased financial burdens, lower quality data submissions and non-compliance risks, this should be stated explicitly in the shortlist.

Consideration of alternatives to regulation 

The Department discusses non-regulatory policy alternatives, such as an information campaign to industry, and explains why this is not suitable as it would not override the current legal duty on firms.

SaMBA and medium-sized business (MSB) assessment 

The Department has provided a sufficient SaMBA. The OA outlines why exemptions for SMBs are not appropriate, explaining that the policy is expected to benefit all businesses by removing the need for businesses to compile data for the 2026 deadline and incur the nugatory spend. Furthermore, the Department evidence that a large proportion (43%) of registrations at the final deadline will be completed by SMBs. It is reasonable, therefore, to assume the intended policy objectives would not be met if these businesses were exempt.

The OA has considered the possible impacts of the preferred option on SMBs, explaining that SMBs might be disproportionately impacted by the uncertainty of the deadline change, as well as shorter extensions for later deadlines, as they are unlikely to have specialised regulatory staff. However, this is a relatively small issue and overall, the policy will benefit SMBs.  Nevertheless, the OA would benefit from considering any potential mitigations for SMBs facing uncertainty. Some consideration could also be given to how different tonnage bands, which determine the compliance timing, affect different business sizes. For example, if small and/or micro businesses typically fall below the 100 and/or 1000 tonnage limits then they will, in effect, have more time to comply than large businesses. While it may not be possible to quantifiably evidence tonnage differences by firm size, the OA would benefit from a qualitative assessment in this regard.

7. Justification for preferred way forward

Identifying impacts and scale

The Department has identified and monetised the key impacts from the proposal, estimating an NSPV for all shortlisted options, with an estimated NPSV of £83m for the preferred option. The OA uses the same methodology to identify the impacts for all shortlisted options. As the proposal extends the submission deadline, the main discounted benefit is the reduction in the present value of REACH registration costs to firms, as these costs will now be occurred at a later date. The different NPSV estimate for each shortlisted option reflects the difference in the length of extension. The Department then compares these benefits against the familiarisation costs for all options which is crucial.  

The OA also discusses non-monetised impacts from the proposal, such as the delay causing a reduction in human health and environmental protection. The Department concludes overall that the UK REACH regime will still be able to ensure a high level of protection for human health and the environment and provides qualitative evidence to justify this.

The OA also states that a key non-monetised benefit is the avoidance of nugatory spend by business on submitting information under registration requirements that will be changed. Whilst the Department explains this impact, the OA could be improved by providing any rough estimates to indicate the scale of savings expected by business.

The Department uses the current costs of REACH registration to calculate the savings expected by businesses, rather than the new lower registration costs that will be associated with the ATRm. This means the estimates presented are conservative, and the savings are likely to be increased when the ATRm registration system is implemented. Whilst this conservative approach is appropriate, the OA could benefit from providing any further detail on the registration savings expected with the ATRm.

Appraisal of the shortlisted options

Whilst the Department presents quantified estimates for the (delayed) costs of registration, the OA does not provide a full explanation methodology or modelling underpinning them. The OA explains that the costs of registration are made up of the costs to buy or commission hazard data, acquire data and general administrative and compliance costs. However, the OA would be improved by detailing the steps taken to reach these cost estimates, including the source, and appropriateness of the assumptions made, as well as the data sources used. This would improve the analytical transparency of the options assessment.

The OA sets out the methodology behind the familiarisation cost but could benefit from providing some justification for the assumptions used. For instance, the source of the document length and reading time assumptions is not clear. Furthermore, the OA could indicate the data source underpinning the labour costs and the estimated number of firms in the chemical sector.

The OA has conducted sensitivity analysis, presenting the NPSV estimates for each option in a range. However, the methodology behind this sensitivity analysis is not detailed and the OA would benefit from outlining which uncertain inputs and assumptions have been varied to estimate these ranges.

Selection of the preferred option

The Department states that the preferred option is to allow a 2-year industry implementation period but reduce to one-year spacing between each deadline (Option 1). This option has the middle NPSV compared to the other shortlisted options, and the Department justifies this option as the preferred option as it provides the most effective balance between a quicker receipt of data, whilst mitigating against the risk of industry missing the deadlines. As the only difference between the preferred option and Option 3 is a 6-month reduction in the overall timeline the OA could expand on the marginal trade-off that occurs between the data being received earlier and providing sufficient time for industry to submit. This could take the form of qualitative evidence, such as stakeholder feedback on the feasibility of meeting those deadlines. If the evidence is limited, the Department should be transparent about this. This would help to support the selection.

8. Regulatory Scorecard

8.1 Part A

Impact on total welfare

The proposal is expected to have a positive impact on total welfare, with the OA presenting an NPSV estimate of £83m for the preferred option. This is largely driven by delayed registration costs for businesses. The OA also details the potential human health and environmental impacts from the proposal, explaining how there will still be a high level of protection for human health and environment because of the information on chemicals registered under EU REACH and HSE’s ability to seek risk management data from other sources. However, whilst this explanation is sufficient, the OA could benefit from explicitly clarifying what the counterfactual position is for firms as it is not clear what their requirements are (and if this includes submitting data under EU or UK REACH) whilst there is this delay. Furthermore, given that HSE can access data from EU REACH in the interim, the OA could benefit from further clarifying why a new UK REACH system is needed. This could involve further explaining the challenge involved in making decisions based on EU data in the long-run. The OA could also benefit from considering the impacts of the preferred option adopting decisions made by the EU in the interim (given the EU has access to the full data and can evaluate the risks). This could also be applied to the other options in the long-list and short-list.

Impacts on business

The OA indicates that the proposal will have a positive impact on business, presenting an EANDCB of -£9.6m for the preferred option. This largely consists of the delayed registration costs.

The OA confirms that the actual impacts of the ATRm development are outside the scope of this measure. This is assumed to include any business impacts from adjusting to a new registration model, such as training or capital costs. The OA could benefit from clarifying this and confirming that the RPC will see an OA submitted for scrutiny in due course. The OA could also consider whether some businesses would have already started taking the necessary measures to adhere to the current submission deadlines, and the impact this may have.

Impacts on households, individuals or consumers

There are not expected to be any impacts on households from the preferred option. It has not been possible to assess the extent to which the reduced costs will be passed on to consumers.

Distributional impacts

There are not expected to be any distributional impacts from the preferred option. The policy applies to the chemical sector, and indirectly to its downstream users. However, there are not any distributional concerns as this measure will resolve a problem faced by the industry.

8.2 Part B

The Department considers the impact of the proposal on wider government priorities, explaining that the policy will support business environment by alleviating the current uncertainty faced by businesses. By adjusting deadlines, the proposal will provide businesses with much-needed clarity and reduce anxiety in the chemical industry. The OA could be improved by providing any relevant evidence to illustrate the scale of this impact for business, perhaps by utilising any relevant results from industry engagement. The Department could also expand its overall discussion of the business environment impact, detailing how avoiding unnecessary expenses may improve competition and innovation of chemical firms. In particular, given the sector’s importance for downstream industries, the Department could consider how reducing internal costs will affect the demand and supply mechanisms in a competitive market equilibrium and impact the long-term price and quality of chemical goods.

The Department indicates that the policy will also have a positive international impact, as it will facilitate the development of the ATRm, which will reduce unnecessary barriers between EU and GB trade. The OA could benefit from expanding on this impact, further considering the positive impact from the proposal aligning GB REACH with EU REACH.

The Department states that the policy may work against natural capital and decarbonisation. However, the OA explains that whilst the policy reduces the ability of regulators to effectively prioritise chemical registration, it will still be possible to maintain high levels of environmental protection as the regulator has other means of accessing relevant information. The OA would benefit from clarity over the specific aspects of Natural Capital might be affected. For instance, the OA could apply the Department’s Enabling Natural Capital Approach screening tool, as part of its ‘four steps’.

9. Monitoring and evaluation

The OA explains that there is an existing monitoring and evaluation strategy in place for the transition from EU REACH to UK REACH. The Department outlines the data sources which will be used to underpin this review, including trade data, interviews with industry and HSE data. The OA could benefit from including further detail on the nature of these qualitative and quantitative data and how they will be gathered. This could include identifying the metrics and key research questions that will be used in the interviews, as well as when they will be rolled out. Furthermore, the OA should clarify how the interviews will be carried out, and whether this references structured interviews with small groups, or business ‘surveys’ with the larger sector. The OA could then relate these directly to the theory of change diagram and SMART objectives. The OA could also provide further clarity on how the current deadline extension impacts will be evaluated within the broader UK REACH transition.

The OA states that possible unintended consequences from the policy will be evaluated but could discuss what these consequences might be and provide more detail on how the evaluation plan will attempt to assess these impacts. The OA could also consider any external factors that will have an impact on the success of the intervention. 

Regulatory Policy Committee

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[1] The RPC opinion rating is based only on the robustness of the rationale, options identification (including SaMBA) and justification for preferred way forward, as set out in the Better Regulation Framework guidance. RPC ratings are fit for purpose or not fit for purpose.

[2] The RPC quality ratings are used to indicate the quality and robustness of the evidence used to support different analytical areas. The definitions of the RPC quality ratings can be accessed here.

[3] UK REACH: Extending data submission deadlines - RPC Opinion