UK REACH compliance: what vape businesses need to know

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is the EU’s core chemicals regulation (EC No 1907/2006), built on the principle “no data, no market” to protect human health and the environment while supporting the development and competitiveness of the EU chemicals industry. Following Brexit, EU REACH was brought into UK law on 1 January 2021 and is known as UK REACH. While based on the same framework, EU REACH and UK REACH now operate as separate and independent regulatory systems.

Some companies still operate “as before” and assume an EU REACH registration is enough for the UK, often without realizing the risk. But the transition period is ending. So, a simple question matters more than ever: Are you sure you can legally place your products on the UK market?

From this article, you will learn:

• What is UK REACH?
• Key dates
• What does it mean for the NGP industry in the UK?
• Practical example: how UK REACH can affect an e-liquid manufacturer in the United Kingdom
• Key Obligations
• Consequences of non-compliance with UK REACH
• UK REACH at Chemnovatic
• UK REACH: preparing in time to maintain market access
• Important links

UK REACH is UK’s system for controlling the import and placing on the market of chemical substances in England, Scotland, and Wales

It applies to most substances manufactured in or imported – whether sold as a substance on its own, in a mixture or as part of articles. If a substance is manufactured or imported into UK in quantities of 1 tonne or more per year (unless an exemption applies), it must usually be registered in the UK system managed by the HSE.

In practice, UK REACH affects companies that place chemicals on the UK market, including:

• UK’s manufacturers
• Importers (including importing from the EU into UK)
• Downstream users and distributors

A critical point for many businesses is the transition from EU REACH-linked arrangements (e.g., grandfathering/DUIN pathways) to full UK REACH requirements. The required UK REACH dossier information must be submitted by the legal deadlines. Those deadlines were extended by three years and now fall on three fixed dates, depending on tonnage and toxicity.

For manufacturers and distributors of e-liquids, nicotine pouches and other next-generation products (NGPs), UK REACH is more than a formal regulatory requirement. It can directly determine whether products may be legally imported, supplied and sold in the UK market.

Companies should verify whether the substances used in their products – including nicotine, propylene glycol, glycerine and other chemical components – are properly covered under UK REACH by their suppliers. They should also assess whether their own position in the supply chain creates separate compliance obligations.

This has become particularly relevant after Brexit. Businesses that previously operated as downstream users under EU REACH may now be classified as importers under UK law when sourcing substances from the EU. This change can significantly alter their compliance responsibilities.

As a result, every company should ask two key questions:

• Is UK REACH properly implemented within the business?
• And are suppliers equally compliant with UK REACH requirements?

Imagine a UK-based company manufacturing e-liquids and importing glycerine, propylene glycol and pure nicotine from an EU supplier. Before Brexit, such a business could often operate as a downstream user under EU REACH.

Under UK REACH, however, the same company may now act as an importer in the UK when sourcing these substances directly from the EU. This change can significantly alter its legal obligations.

This is because UK REACH registration applies to individual substances rather than to the final e-liquid mixture itself. If the company imports glycerine, propylene glycol or nicotine in quantities of 1 tonne or more per year per substance, it must determine whether each substance is properly covered under UK REACH. If appropriate coverage is not in place, the company may need to take its own steps to continue importing and placing products on the UK market lawfully.

In practice, this means the manufacturer cannot rely solely on commercial continuity with its EU supplier. It should verify whether the supplier has ensured UK REACH coverage, confirm its own role in the supply chain, and check whether any notification or registration steps are required. This is particularly relevant for businesses that have continued importing into the UK market since 1 January 2021, as transitional mechanisms such as DUIN were introduced for this situation.

The company should also ensure that relevant compliance documentation is in place and up to date, including safety information required for customers and downstream users. Under UK REACH, businesses placing substances on the UK market must understand associated hazards and assess risks. They must also communicate appropriate risk management measures across the supply chain, commonly through Safety Data Sheets where required.

When you place chemicals on the UK market, the first step is to confirm whether UK REACH applies and what role you have in the supply chain. Legal duties depend on that role. Even so, the core expectation remains consistent: you must identify and manage risks, demonstrate safe use, and communicate appropriate risk management measures.

Under the “no data, no market” principle, a substance that requires registration cannot be legally placed on the market without the required information being submitted in the UK system.

Businesses must understand the hazards and risks linked to the substances being placed on the UK market and ensure that safe-use measures are identified and applied.

UK REACH depends on effective information exchange across the supply chain. This includes providing customers with clear, accurate safety information and ensuring documentation supports safe handling and use (commonly through Safety Data Sheets (SDS) where relevant).

Obligations change depending on whether an entity is acting as a manufacturer, importer, distributor, or downstream user. After Brexit, some supply chains changed legally (for example, a UK “downstream user” buying from the EU can become a UK importer), which can shift duties significantly.

Submissions and key interactions are handled via the UK government service “Comply with UK REACH”, used for notifications and registrations.

UK REACH is enforceable legislation. Where obligations apply, failure to comply can have direct commercial and legal consequences for businesses placing chemicals on the UK market.

• Loss of market access Where registration or notification is required, missing UK REACH coverage can block legal access to the UK market. This may stop imports and sales until the business achieves compliance.
• Regulatory enforcement and sanctions Identified breaches may lead to regulatory action, including orders to stop sales, product withdrawals from the market, financial penalties, or other legal measures under UK enforcement rules.
• Supply chain disruption Non-compliance can cause delays, halted shipments, or terminated contracts. These disruptions may affect the entire supply chain, often beyond the UK market.
• Reputational risk Failure to meet regulatory obligations, or incidents involving unsafe use of chemicals, can damage brand credibility and undermine trust with customers, partners, and authorities.

In practice, UK REACH requires companies not only to manage chemical risks, but also to demonstrate and document compliance. Recent enforcement trends show that proactive compliance is essential to protect business continuity and long-term access to the UK market.

UK REACH aims to strengthen the assessment and control of chemical substances and their impact on human health and the environment. It sets a high standard of protection and places responsibility on manufacturers and importers to understand and manage the risks associated with the chemicals they place on the market. In practical terms, this creates clear accountability across the market.

As an international company operating across multiple markets, Chemnovatic ensures full regulatory compliance wherever its products are supplied.

Following Brexit, our Polish headquarters has continued to operate under EU REACH requirements since 2021. At the same time, our UK entity – Chemnovatic UK – has aligned with UK REACH requirements, with full implementation completed in 2025.

These requirements are embedded in our internal processes to ensure the lawful placing of substances on the UK market, continuity of supply, and a consistently high level of safety for customers and downstream users. As a result, partners working with Chemnovatic can operate with confidence. UK REACH obligations are handled upstream as part of Chemnovatic’s regulatory framework – so customers receive compliant products and reliable supply.

UK REACH directly impacts market access, supply continuity, and business risk.

For manufacturers and distributors of e-liquids and nicotine pouches, it determines whether key raw materials can be legally imported and whether products can remain on the UK market. Delays in compliance or gaps in supplier coverage may lead to supply disruptions, blocked imports, and loss of market access – making early action critical.

However, compliance is not immediate. Preparing dossiers, verifying supplier coverage, and aligning internal processes all take time, while deadlines remain fixed. With additional regulatory changes expected later in the year, including potential excise updates, businesses may soon face multiple compliance challenges at once. Starting early with UK REACH helps reduce risk and ease operational pressure.

Feel free to contact us in advance at sales@chemnovatic.com to discuss compliance and secure uninterrupted access to the UK market.