The Mix Ratio · Issue 1 · November 2026
The UK REACH deadline that moved
A note from me
I'm Vinay. I run Next Generation Chemical, the UK and Europe partner of the Polytek Synergy group, a polyurethane manufacturer in India.
We're new. This is our first real year. I'm not a chemist, and one of the hardest parts of this year has been learning the rules that UK and European PU buyers deal with every day: what's law, what's only a proposal, and which date actually matters.
So I'm writing it down, once a month, as plainly as I can. One rule explained properly, a short list of dates to watch, and one practical answer from our chemists. If it's useful, please forward it to whoever handles purchasing or compliance at your site.
This month's rule: the UK REACH deadline that moved
What it is
Under UK REACH, chemicals that were on the GB market under EU REACH have to be fully registered with HSE. The first deadline for that was 27 October 2026. It has moved.
The new dates
- 27 October 2029: substances at 1,000 tonnes or more a year, CMRs at 1 tonne or more, substances very toxic to aquatic life at 100 tonnes or more, and SVHCs listed by 27 October 2027.
- 27 October 2030: 100 tonnes or more a year.
- 27 October 2031: 1 tonne or more a year.
Who it affects
Anyone who imports a chemical into Great Britain or makes it here. A manufacturer outside GB can't register directly. A GB importer registers, or a GB-based "only representative" does it on the maker's behalf. If you buy from a GB distributor, the duty may sit with them, but it's still your supply at risk if nobody registers.
What's still moving
The government is designing a lighter "alternative transitional registration model" (ATRm). The consultation on the legal text closes on 10 November 2026.
What to do this week
- Email each supplier of imported substances and mixtures with two questions: who is the GB registrant (or only representative) for each substance, and which deadline applies?
- Keep the answers with your SDS file.
- If anyone can't answer, that's your early warning.
- HSE, Recognising your EU REACH registrations under UK REACH: hse.gov.uk/reach/grandfathering-registrations.htm
- The REACH (Amendment) (No. 2) Regulations 2026, Explanatory Memorandum: legislation.gov.uk/uksi/2026/849
- Defra, ATRm technical consultation: consultations.defra.gov.uk
The watchlist
| Date | What | Where |
|---|---|---|
| 10 Nov 2026 | ATRm technical consultation closes | GB |
| 23 Mar 2027 | Compliance date for the latest GB mandatory classification list | GB |
| 24 Mar 2027 | Future Homes Standard in force (24 Sep 2027 for higher-risk buildings) | England |
| By Aug 2028 | Diisocyanate training refreshers due at the latest for anyone trained before the 2023 start (training must be renewed at least every five years) | GB + EU |
Sources for each date are on our Rules, Plainly page.
Ask our chemists
"Your polyol and my current one have the same name. Why did my foam come out different?"
Our chemists' answer: the name tells you the family, not the behaviour. Compare four lines on the two TDSs side by side: the OH value (together with water content, it sets how much isocyanate the blend needs), the functionality (more arms, a firmer network), the EO/PO make-up (reactivity and how open the cells end up), and water and acidity (small numbers, big effects on rise and cure). Then trial. Never switch on the name alone. There's a fuller checklist on how to compare a TDS.
Supply note
On 30 June 2026 the European Commission opened an anti-dumping investigation into polyether polyols from China, including blends. Provisional duties are possible within seven to eight months of the notice, so around late January or February 2027. It's an EU case and doesn't apply to imports into Great Britain directly. If most of your polyol comes from one country, now is a sensible time to qualify a second source.
- EU notice of initiation C/2026/3478: eur-lex.europa.eu
One question back
Which rule would you most like explained next month? Email me. I read every one.
Vinay
General information, not legal advice. Each summary is dated and links to its source. Rules change; check the source for your own situation before acting.