Reviewed quarterly, and whenever a change is confirmed against the sources below. Confirm any entry against its source before relying on it for a decision.
UK REACH and EU REACH started from the same text at the end of the Brexit transition period and have been diverging in specific, dated ways ever since, on separate timetables set by HSE and ECHA respectively. This article is practical guidance, not legal advice.
What this tracker is
Our UK REACH vs EU REACH comparison explains the structure of the divergence once: who regulates which, the shape of GB CLP versus EU CLP, and what running two regimes generally costs a documentation team. That article does not change often, because the structure does not change often. This page is different on purpose. It is a dated changelog of specific, confirmed changes, refreshed on a cadence, so a returning reader can see what has actually moved since they last checked without re-reading the whole explainer.
Changelog: divergence points to date
| Date | What changed | Regime affected |
|---|---|---|
| 2025-09-16 | HSE published the 7th edition GB MCL List, adding mandatory classifications for around 30 substances (entries effective 2025-09-23, compliance date 2027-03-23). | GB only |
| 2026-05-01 | The EU’s 22nd Adaptation to Technical Progress (ATP) became mandatory, reclassifying roughly 50 substances under EU CLP. The GB MCL List is set independently by HSE and does not automatically mirror an ATP. | EU only (until/unless mirrored in GB) |
| 2026-08-06 | The REACH (Amendment) (No. 2) Regulations 2026 (SI 2026/849) entered into force, extending the UK REACH transitional registration deadlines to 27 October 2029, 2030 and 2031. | GB only |
Beyond individual dated changes, the structural divergence noted in our comparison article continues: the GB MCL List and the EU's harmonised classification list are now set by separate processes (HSE and ECHA's Risk Assessment Committee respectively) and have produced different outcomes for specific substances. Confirm the current classification for any substance you supply against both lists directly rather than assume alignment.
Checking two classification lists by hand, per substance?
We connect your product composition to both the GB MCL List and current EU harmonised classifications, so a divergence on a substance you actually supply is flagged, not discovered at audit. A short call, no pitch.
Book a technical callUpcoming deadlines to watch
- The UK REACH transitional registration deadlines, now 27 October 2029, 2030 and 2031 following the 2026 extension, have already been pushed back twice. Treat the current dates as the position as of this page’s last update, not a certainty.
- An Alternative Transitional Registration Model (ATRm), intended to reduce the cost of UK REACH registration, is understood to be in development but was not finalised in law as of this page’s last update. Confirm its current status with HSE or Defra before planning around it.
- Northern Ireland continues to follow EU REACH and EU CLP directly under the Windsor Framework, so a change in the EU regime reaches NI on the EU timetable, separately from whatever GB does.
How to monitor this yourself
This page is refreshed on the cadence stated above, not continuously, so for anything time-critical check the primary sources directly:
- HSE’s GB MCL list page. The primary source for GB mandatory classification changes, updated each time an edition is published.
- ECHA’s CLP and ATP pages. The primary source for EU harmonised classification changes, including new Adaptations to Technical Progress.
- Defra’s REACH policy consultations. Where changes to UK REACH registration deadlines and process are proposed before they become law.
- legislation.gov.uk. For the actual statutory instrument text once a change is confirmed, rather than a secondary summary.
Frequently asked questions
How is this different from your UK REACH vs EU REACH article?
That article explains the structure of the two regimes once: who regulates what, the general shape of the divergence, and what it means for your documentation. This page is the maintained changelog, dated entries added as specific changes are confirmed. Read the explainer for the framework and this page for what has actually changed lately.
How often is this page updated?
Reviewed quarterly at minimum, and whenever a change significant enough to affect a chemical supplier is confirmed against a primary source. Check the "last updated" date at the top before relying on it for a decision.
Does Northern Ireland follow GB or EU changes?
Northern Ireland continues to follow EU REACH and EU CLP under the Windsor Framework arrangements, which is a structural difference from Great Britain rather than a dated change in itself. If you supply into Northern Ireland, track the EU column, not the GB one, for that part of your business. Confirm the current arrangements against HSE and gov.uk guidance.
Can I rely on the changelog table without checking the source?
No. Each entry links to the kind of primary source you should confirm it against before acting. This is practical guidance, not legal advice, and a tracker is exactly the kind of page where the underlying regulation can move faster than any summary.
Sources
- HSE — Updating the GB mandatory classification and labelling list (GB MCL List)
- HSE — UK REACH
- ECHA — Classification, Labelling and Packaging (CLP)
- Defra — Extending the UK REACH transitional registration submission deadlines (consultation)
This is practical guidance, not legal advice.
What we take on and where we stop.
The one-time explainer. This tracker is the dated changelog that sits alongside it.
The other maintained, dated page in this cluster, refreshed the same way.