ACA’s REACH duplication warnings hint at lab testing and compliance burdens
The Alliance of Chemical Associations (ACA) has criticised the UK Government’s response to its consultation on the UK REACH Alternative Transitional Registration model (ATRm), arguing that it leaves industry facing significant costs and ongoing uncertainty.
The ACA said that, after almost five years of debate, the Government’s position still imposed additional regulatory burdens and risked slowing the introduction of new products to the Great Britain market.
While welcoming the move away from proposed additional requirements on use and exposure data, the ACA pointed out it maintained obligations to submit hazard, use and exposure information, and in some cases full chemical safety assessments, via substance groupings and joint submissions.
It added hazard and use information is publicly accessible through the European Chemicals Agency (ECHA) and safety data sheets, raising questions about the need for further UK-specific submissions.
The ACA maintained that requiring data submission for substances already registered under EU REACH offered no additional benefit to human health or environmental protection, particularly given the UK’s stated intention to align with EU decisions on bans, authorisations and restrictions.
For laboratories, the ACA’s concerns point to a potential increase in testing, data generation and compliance workloads tied to duplicate UK and EU registration requirements.
The Chemical Business Association (CBA), a leading member of the ACA warned that the continued requirement would bring costs but few benefits.
“There is no added benefit to the high level of protection for human health and the environment or logic in what is still expected to be a costly £500 million plus data gathering and administration exercise, given that we (GB) will be aligning with EU bans, authorisations and restrictions, with any divergence only in exceptional cases,” it said in a statement.
“This cost will ultimately be borne by UK businesses across the chemicals and wider manufacturing supply chains.”
The ACA occupies a pivotal position in the chemicals sector. Its member association between them account for 1,400 companies with an annual turnover of £45bn and employing an estimated 170,000 people. The CBA alone represents companies contributing £5bn, employing 10,000 people and responsible for handling 27m tonnes of chemicals annually.
The ACA went on to question the rationale behind building a separate UK chemicals database for around 20,000 substances already registered under EU REACH before the end of the EU Exit transition period.
Given that the Government is prepared to follow EU regulatory decisions in most cases, the association said it remained unclear how any additional UK-specific data would be used in practice.
It argued that the requirement to duplicate registration processes for chemicals newly registered in the EU since the end of the transition period created further barriers for companies developing novel or speciality chemicals, adding cost and administrative complexity while potentially delaying market entry.
The organisation said the alternative was to recognise EU registrations in full, in line with the UK’s broader objective of regulatory alignment. It argues this would support competitiveness and secure supply chains while maintaining equivalent levels of protection for health and the environment.
UK authorities could still track substances placed on the GB market through a notification system, which could also satisfy “no data, no market” requirements.
Further concerns related to implementation timelines and practical detail. Under the ATRm, companies will still be required to submit UK-specific registrations, even where substances are fully registered under EU REACH. Although the revised model reduces some hazard data requirements, it does not remove the need for a parallel UK system.
The ACA noted that upcoming registration deadlines—set for October 2029, 2030 and 2031—will be compressed into 12-month windows, increasing pressure on businesses.
Finally, the association highlights a lack of clarity around the use of publicly available data. Without clear Government guidance on whether such data can be used without the consent of data owners, the ACA warns that anticipated cost reductions may not materialise. It also reiterates concerns about potential duplication of animal testing requirements for new substances, adding to both ethical and financial considerations for industry.
