The UK Just Proposed Its First New SVHCs Since Brexit – Why This Matters

On March 11, 2026, the UK Health and Safety Executive (HSE) launched its first public consultation on adding Substances of Very High Concern (SVHCs) to the UK REACH Candidate List since Brexit.

The consultation includes 15 proposed SVHCs, and companies have until April 20, 2026, to submit comments or supporting information.

For companies placing chemicals on the market in Great Britain, this is a meaningful signal of how UK REACH is evolving.

Why This Update Matters

When the UK left the EU, and UK REACH came into force on January 1, 2021, the UK REACH Candidate list mirrored the EU REACH Candidate List.

Since then, the EU has added 42 substances, while the UK has not made any additions, creating uncertainty about how the UK would develop its own regulatory pathway.

This consultation demonstrates that the UK is now actively building and updating its own SVHC framework.

The Proposed Substances

All 15 substances in this first consultation already have mandatory harmonized classifications under GB CLP, particularly for:

• Carcinogenicity
• Mutagenicity
• Reproductive toxicity

This suggests the UK is taking a structured, risk-based approach, starting with substances where hazard profiles are already well established.

Companies have until April 20, 2026, to submit technical comments, supporting data, and feedback on hazard properties.

After the consultation closes:

• If no comments are submitted, the substance will be added automatically
• If comments are received, the HSE will review them and make a decision within 45 days.

What Being on the Candidate List Means

It is easy to underestimate the impact of the Candidate List, especially for companies not directly involved in REACH registration.

However, once a substance is included, it can trigger:

• Additional communication requirements in the supply chain
• Obligations for substances in articles
• Increased regulatory scrutiny

It can also be the first step towards future authorization requirements and stricter regulatory control.

Part of a Bigger Regulatory Shift

This consultation also reflects a broader strategic shift in how the UK approaches SVHC identification. A recent notice from the HSE indicated that it intends to:

• Draw more from regulatory decisions in other jurisdictions;
• Maintain closer alignment with major trading partners, especially the EU; and
• Reduce unnecessary complexity for industry.

At the same time, the UK retains the ability to propose additional SVHCs independently when a substance meets regulatory criteria.

A second SVHC consultation is expected in June 2026, and substances have already been listed in the UK Registry of Intentions, giving companies an early indication of what could be coming next. So, rather than a one-off event, this suggests that it will become a more regular process.

What Companies Should Be Thinking About

As the UK begins to actively update its Candidate List, companies may need to reassess how they manage substance compliance across their portfolios and supply chains.

In particular, companies should consider:

• Whether any of the proposed substances are in their portfolio
• Whether comments or technical input should be submitted
• What potential Candidate List inclusion could mean for supply chain obligations.

Supporting activities might include:

• Evaluating SVHC notification requirements;
• testing articles for the presence of SVHCs; and
• Preparing and submitting SVHC notifications where required.

Even if none of these 15 substances are directly relevant to your business, this consultation is still important. It signals how quickly the UK may begin updating its Candidate list and how supply chains will need to respond in the future.

If you would like to discuss how these developments may affect your products or supply chain, feel free to contact the team via service@cirs-group.com