Know The Difference Between EU REACH and UK REACH

Know The Difference Between EU REACH and UK REACH

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The EU REACH or (Registration, Evaluation, Authorization, and Restriction of Chemicals) and UK REACH are the most important regulatory frameworks designed to manage the risks posed by the hazardous chemicals. Also, these two frameworks share similar goals, making notable differences in their implementation especially after the UK’s departure from the European Union. Hence, this blog explores the differences between the EU REACH and UK REACH compliance significantly. 

Similarities Between EU REACH and UK REACH As suggested above, both the regulations EU REACH and UK REACH share similar goals and that is the management of the chemicals that are of very high concern or Substances of Very High Concern (SVHCs). The chemicals which are classified under the SVHC are based on their level of toxicity, persistence, and bioaccumulation. This list is essential for ensuring the public and environmental safety. Also, as of January 2025, the EU REACH list for SVHC has included 247 substances with many latest additions reflecting the increased attention to chemicals that are persistent in the environment or accumulation in living organisms. The UK REACH SVHC list reflects the EU’s many respects but includes some differences due to the UK”s independent regulatory process. 

Key Differences

Total Number Of SVHCs Listed

  • EU REACH (ECHA): There are 247 SVHC listed on the EU REACH list as of January 2025. These listed chemicals include the recent updates such as O,O,O-triphenyl phosphorothioate and Octamethyltrisiloxane which are included due to their increased persistence, bioaccumulation and toxicity.

  • UK REACH (HSE): The UK REACH list contains around 219 SVHC as of March 2022 which is close to the EU list. However, it does not include the latest chemicals which are made by the EU after Brexit. 

Recent Additions To The SVHC List

  • EU REACH:  The EU’s SVHC list has been updated recently with five new substances as of January 2025. The substances that are included are Octamethyltrisiloxane and Perfluamine known for its toxicity and environmental persistence.

  • UK REACH: It is important to know that the UK’s SVHC list has not added any new substances since January 2021. Hence, as a result the substances that are newly added to the EU REACH list after this time are not automatically included in the UK list unless they are reviewed and adopted by the UK authorities.

Regulatory Authorities And Processes

  • EU REACH (ECHA): The EU REACH list maintained by the European Chemicals Agency or ECHA which is responsible for updating the list based on the scientific assessments and public consultations. Also, ECHA follows a strict and transparent process for the scientific evaluation to ensure that all substances are adequately assessed before being added to the SVHC list.

  • UK REACH (HSE): The UK’s REACH list is maintained by the Health and Safety Executive (HSE) and the Environment Agency (EA).  It is after Brexit, the UK has established its own regulatory criteria and timeline for adding SVHC which completely diverges from the EU process. The UK initially mirrored that EU REACH SVHC list but at the end of the Brexit transition period the UK continued to independently assess the substances.

Alignment With EU REACH

  • EU REACH: The EU continues to make regular updates to its SVHC list which includes the scientific assessments and public consultation. These updates reflect the EU’s commitment to environmental safety and public health aligning perfectly with its regulation.

  • UK REACH: Earlier, the UK REACH was first aligned with the EU REACH but since the end of the Brexit transition period, these two listings began to diverge. The UK has not automatically adopted the EU’s latest addition and any substance added to the EU list after Brexit they must undergo separate assessment by the UK authorities before including them in the UK REACH list.

While both the EU and UK REACH lists serve similar functions in protecting human health and the environment by regulating hazardous chemicals, the main difference between them lies in their regulatory authorities, the pace of updates, and the processes by which substances are added to their SVHC lists. The EU continues to update its list with new substances based on scientific evidence, whereas the UK, having diverged from the EU post-Brexit, independently manages its list and may prioritize substances differently. As such, businesses operating in both jurisdictions must stay informed about the latest updates to both lists to ensure compliance.

Sunstream compliance group can support in your process to comply to REACH regulation in EU or UK. Talk to us to discuss your challenges in complying to REACH Compliance regulations.