As of February 24, 2026, the United Kingdom (UK) government has announced that the interim approaches to adding Substances of Very High Concern (SVHC) to the UK Candidate List no longer apply and have been replaced with a new strategic approach.
Following the UK’s exit from the European Union (EU), the 2021 interim principles facilitated a case-by-case review process for adding substances to the UK Candidate List, incorporating Regulatory Management Options Analyses (RMOA), and consideration of whether substances were a good candidate for the subsequent Authorisation List. Commentators have noted that these principles resulted in less frequent updates to the UK Candidate List, in comparison to the EU’s own version, which is routinely updated twice annually.
The new strategic approach, as set out in Commitment 40 of the Department for Environment, Food and Rural Affair’s (Defra) 2025 Environmental Improvement Plan, seeks to draw more from regulatory decision-making in other jurisdictions, particularly the EU. Substances that have been added to the EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Candidate List since January 1, 2021, and further EU additions, will be reviewed and added to the UK REACH Candidate List where appropriate. This change is expected to enable more predictable alignment between the EU and UK Candidate Lists, offer greater assurance for industry operating in both markets and result in faster protection for human health and the environment by accelerating UK candidate listing.
As a first step down this new strategic path, the UK Health and Safety Executive (HSE) has recently opened a six-week consultation on the proposed inclusion of 15 SVHCs on the UK REACH Candidate list. An additional consultation is planned for June 2026. Inclusion on the Candidate List triggers obligations, so businesses may wish to review their product portfolios now for potential impacts. The list of substances can be found on the UK Registry of SVHC Intentions.
UK manufacturers and importers should note that the UK’s ability to act independently will not be lost, however, as the HSE retains the authority to propose further potential SVHC’s specific to the UK, where necessary. Businesses should therefore continue to monitor the UK SVHC list for entries that diverge from the EU list.
