UK REACH applies to a coating whenever the coating, or any substance in it, is manufactured in or imported into Great Britain. Registration depends on tonnage, authorisation depends on the substance, and your customers will ask for evidence either way. If you buy or specify coated glass for medical, defence, aerospace, automotive or electronic products, the practical job is to know which duty sits with you, which sits with your supplier, and what paperwork proves it.
This guide is written from the glass side of the supply chain. We make custom precision glass components, and coatings (anti-reflective, anti-glare, ceramic print, functional layers) are part of almost every specification we see. The article covers what UK REACH requires, where coated glass assemblies catch teams out, how it differs from EU REACH, and what to put in your RFQ.
TL;DR
- UK REACH covers substances in coatings, as a pure substance or in a mixture, at 1 tonne or more per year per legal entity, for manufacture in or import into Great Britain.
- Authorisation of Annex XIV substances has no tonnage threshold. A coating process using one after its sunset date needs an authorisation covering that use.
- Transitional registration deadlines were extended in 2026 to 27 October 2029, 2030 and 2031, depending on tonnage and hazard profile.
- Apply the 0.1% SVHC threshold to each component article, such as a glass pane or a coating layer, never to the finished assembly.
- Ask every coating supplier for written UK REACH status and keep it in an audit-ready file.
Table of Contents
- What UK REACH actually covers
- Registration: tonnage, deadlines and the transitional model
- Authorisation: where coatings feel it most
- The article rule: why 0.1% applies to each component
- UK REACH vs EU REACH for coatings
- RoHS and coated glass: a separate regime
- What we think: treat coating compliance as a specification line
- A practical checklist for buyers of coated glass
- Related compliance duties for GB glass components
- Coated glass components from Precision Glasses
- FAQ
- Sources
What UK REACH actually covers
UK REACH is the Great Britain version of the EU regime, created when the UK left the EU. HSE says it applies to most chemical substances manufactured in or imported into England, Scotland and Wales, whether on their own, in a mixture or in an article where release is intended. Coatings and paints are mixtures, so the substances inside them are in scope.
The founding principle is “no data, no market”: a substance without the required registration data should not be on the market. HSE is the UK REACH Agency and enforces it.
Three points shape everything that follows:
- The duty sits with legal entities, not products. The 1 tonne threshold is per substance, per entity, per year.
- Registration and authorisation are separate. A registered substance can still be on the authorisation list.
- Northern Ireland is a separate case. This guide covers Great Britain. For Northern Ireland, start with the HSE Northern Ireland REACH pages.
Your role decides your duty
HSE describes three main types of dutyholder: manufacturers and importers, downstream users, and article producers or importers. A glass fabricator that buys a coating from a GB distributor is normally a downstream user. The same fabricator becomes an importer if it buys the coating directly from outside Great Britain.
That shift catches businesses that used to buy through an EU-based chain and now source direct from EU or EEA suppliers. Check your purchasing routes, not just your supplier list.
Registration: tonnage, deadlines and the transitional model
If you manufacture or import a substance at 1 tonne or more a year, you register it. Most coating formulators sit upstream of this, because the pigment, resin or solvent producer registers the raw substance. Formulators and importers of mixtures still need to know which of their ingredients are registered, and by whom.
Substances already on the GB market when the UK left the EU entered a transitional route. The government has now extended the dates. Under the 2026 instrument, submission deadlines are 27 October 2029, 27 October 2030 and 27 October 2031, depending on tonnage and hazard profile, under the Alternative Transitional Registration model. Compliance-check dates were deferred to 2030, 2032 and 2036.
If you imported EU REACH-registered substances and notified HSE through the Comply with UK REACH service, diarise the date that applies to each substance. Dates have moved several times, so check the current legislation before you plan around one.
| Duty | Trigger | Who carries it |
|---|---|---|
| Registration | 1 tonne or more per year of a substance, alone or in a mixture | GB manufacturer or importer |
| Authorisation | Annex XIV substance used after its sunset date, any quantity | The user, or a supplier holding an authorisation that covers the use |
| SVHC in articles notification | Candidate List substance in an article above stated conditions | Article producer or importer |
| Supply chain communication | Candidate List substance above 0.1% w/w | Every supplier in the chain |
Authorisation: where coatings feel it most
Authorisation is the part of UK REACH that most often changes a coating specification. HSE explains that its aim is to progressively replace substances of very high concern with safer alternatives where feasible ones exist. Once a substance is on Annex XIV, it cannot be used after its sunset date unless an authorisation covers that use.
Two details matter for coating users:
- No tonnage threshold. Unlike registration, a small-volume process still needs cover.
- Mixture concentration exemptions. For some substances, a mixture is exempt if the substance is present below 0.1% w/w. That depends on the specific entry, so read it rather than assuming.
Chromium trioxide is the example the coatings world knows best. HSE’s public consultation on an application covering chromium trioxide shows how a GB applicant must set out proposed uses and invite views on alternatives. Other published reviews show the same pattern for ethoxylated nonylphenol in a surface treatment use, held by Chemetall Limited, and for octylphenol ethoxylates, held by PPG Industries (UK) Ltd.
The lesson for buyers: authorisations belong to named holders and named uses. “Our supplier is authorised” is not enough. You need to know the authorisation number, the use it covers and whether your process falls within it.
A registered substance is not an authorised use
Because registration and authorisation are different processes, a substance can be fully registered and still need an authorisation for your coating use. Applications are multi-year efforts that depend on showing there is no feasible alternative. The British Coatings Federation notes that the UK coatings industry uses between 4,000 and 6,000 different substances across its products, so the volume of status checking is real, and many specialty coatings depend on substances that are or may become SVHCs.
The article rule: why 0.1% applies to each component
The confusion we see most often is about articles. A glass pane with a coating, a printed border and a bonded frame is not one article for REACH purposes. HSE’s guidance on notifying substances in articles sets out the duties of importers and producers when Candidate List substances are present in their articles under certain conditions.
The working rule for complex assemblies is to assess each component article as produced: the glass, the conductive layer, the ceramic print, the plastic housing. Averaging across a whole dashboard or display module hides a coating that exceeds the threshold. An assembly-level calculation is a common finding in supplier audits.
A second misconception: finished articles imported into Great Britain are not themselves subject to authorisation. But using an Annex XIV substance in the manufacture of an article inside Great Britain is regulated. A GB fabricator coating glass here has a duty that an importer of the same finished part may not. A metal fabricator’s explanation of why 0.1% and 1 tonne trip up compliance teams draws the same line between substances used in manufacturing and restrictions on imported articles, and it is a useful read for procurement teams new to the distinction.
UK REACH vs EU REACH for coatings
The two regimes began identical and are diverging. For a manufacturer selling to both markets, the differences are practical:
| Point | UK REACH (Great Britain) | EU REACH |
|---|---|---|
| Regulator | HSE as the Agency | ECHA and member state authorities |
| Registrations | Separate GB registrations or notifications | EU registrations do not cover GB |
| Candidate List | Own list, consulted on separately | Own list, updated on a different timetable |
| Authorisations | GB decisions for GB uses | EU decisions for EU uses |
| Transitional deadlines | 2029, 2030 and 2031 submission dates | Different framework |
The practical consequence is that an EU REACH certificate or SDS is a starting point, never proof of GB compliance. Your supplier may be compliant in one market and exposed in the other.
Candidate List changes also arrive on their own schedule. HSE opened a consultation on nine proposed additions, including a PFAS entry, which closed on 20 August 2026. Once a substance is on the Candidate List, supply-chain communication duties start straight away, and coatings, electronics, automotive and aerospace were all named as affected sectors. Check the HSE site for the outcome before you finalise any bill of materials.
RoHS and coated glass: a separate regime
Readers often ask about RoHS in the same breath as REACH. They are different laws. UK REACH regulates substances across the chemical supply chain. RoHS restricts hazardous substances in electrical and electronic equipment. The GB regulations restrict ten hazardous substances in EEE, with exemptions available where criteria are met. Glass frit binders are one area where exemptions for lead have been consulted on.
For coated glass in a touch display, sensor housing or instrument, this means two questions:
- Does any substance in the coating, ink or frit exceed RoHS limits in the homogeneous material, and is a valid exemption in force?
- Does any substance in it trigger UK REACH duties?
A coating can pass one and fail the other. Ask for both declarations.
What we think: treat coating compliance as a specification line
We make precision glass for medical devices, defence, aerospace, automotive dashboards, lighting and electronics. In those sectors, a coating is rarely a cosmetic choice. It sets reflectance, durability, hydrophobic behaviour or erosion resistance, and it often fixes which chemistry is acceptable.
Our view is that REACH status belongs in the RFQ beside the optical and mechanical requirements, not in a questionnaire sent after the order. A coating that meets a transmission figure but depends on a substance with a sunset date is a risk you can see coming, if you ask early.
Our positioning rests on ISO 9001 certification, traceable production, batch-level traceability and documented export compliance. Traceability matters here because a compliance question usually arrives months after delivery. If a substance status changes, you need to know which batches carry which coating and which lot of coating material was used.
We also push for two habits:
- Qualify alternatives early. Reliability-critical sectors need years to test and certify a replacement. Start before the sunset date is announced.
- Keep one file per coating. Supplier declaration, SDS, SVHC statement, authorisation reference where relevant, and the test certificates behind them.
— Alexandra
A practical checklist for buyers of coated glass
- Map your role. Are you a downstream user, an importer, or an article producer for each coating and component?
- List the substances. Request full composition against the Candidate List and Annex XIV, not just a headline statement.
- Check purchasing routes. Any direct purchase from outside Great Britain may make you an importer.
- Get written declarations. UK REACH status, RoHS status where the product is EEE, and the 0.1% position for each component.
- Record authorisation details. Holder, number, covered use and review dates.
- Set a review cycle. Candidate List and deadline changes arrive repeatedly, so review at least when HSE publishes updates.
- Tie it to batches. Link coating lot numbers to delivered parts so a status change can be traced fast.
Defence and aerospace teams have an extra reason to keep this file current: customers increasingly require certification from upstream partners, and the evidence must show ongoing awareness of substance status, not just a snapshot.
Wording for your RFQ
Short, testable clauses work better than general assurances. For example:
- “Supplier shall declare any Candidate List or Annex XIV substance in the coating above 0.1% w/w, assessed per component article.”
- “Supplier shall give written notice of any change to UK REACH status of coating materials within the contract period.”
- “Batch traceability shall link each delivered component to its coating material lot.”
Pair these with the performance tests in our guides on erosion resistant coatings and RFQ language and testable hydrophobic glass specifications. For optical layers, see optical coatings explained and the guide to coating methods, performance and applications.
Related compliance duties for GB glass components
UK REACH is one layer. Depending on your sector, you may also need to line up:
- AS9100 requirements for aerospace suppliers
- UK MDR 2002 Part 4A for medical device manufacturers
- UKCA marking for products within its scope
A supplier who can show consistent records across these frameworks makes your own audits shorter.
Coated glass components from Precision Glasses
We fabricate custom glass for demanding applications: optical windows, display glass, sensor windows, chemically strengthened and protective glass, CNC-machined technical glass, ceramic printing and coatings including AR and AG. We scale from prototype to volume, with traceability and documented quality control. See our services or contact us through our site with your specification and compliance requirements, and we will tell you what documentation we can provide with your order. For the quality system behind that, see our quality page.
FAQ
Does UK REACH apply to coatings on glass?
Yes, where the coating or its substances are manufactured in or imported into Great Britain. The coating is a mixture, so its ingredients carry registration and, where relevant, authorisation duties. Whether the duty falls on you or your supplier depends on your role in the chain.
Is an EU REACH registration enough for Great Britain?
No. UK REACH runs its own registrations, Candidate List and authorisations. EU documentation helps you gather information, but you still need GB status confirmed, including whether you have become an importer by buying direct from EU suppliers.
When do the transitional registration deadlines fall?
The 2026 instrument sets submission deadlines of 27 October 2029, 2030 and 2031, depending on the substance’s tonnage and hazard profile. Dates have moved before, so confirm your substance’s date on the current legislation.
Do I need separate RoHS and REACH declarations for coated glass?
If the glass goes into electrical or electronic equipment, yes. RoHS limits specific substances in the equipment, while REACH regulates substances across the chemical supply chain. A coating can satisfy one and not the other, so request both.
Does the 0.1% threshold apply to the whole assembly?
No. Assess each component article separately: the glass pane, the coating layer, the housing. Calculating across the assembly can mask a coating that exceeds the threshold and is a common reason supplier audits fail.
Sources
- UK REACH explained, HSE
- UK REACH authorisation overview, HSE
- UK REACH roles, HSE
- Notifying substances in articles, HSE
- Comply with UK REACH, GOV.UK
- Transitional registration deadlines instrument, legislation.gov.uk
- UK REACH, British Coatings Federation
- Chromium trioxide application AFA065-01, HSE consultation
- NPEO explanatory note, HSE consultation
- OPE explanatory note, HSE consultation
- REACH substances of very high concern, HSE Northern Ireland
- UK REACH SVHC update 2026, Certivo
- RoHS consultation on lead in glass frit binder, Defra
