Chemical sector warns REACH registration will increase industry burden
The Alliance of Chemical Associations (ACA) has criticised the UK Government’s response to consultation on the UK REACH Alternative Transitional Registration model (ATRm), warning that the approach risks imposing major costs and administrative burdens on the chemicals sector while doing little to improve safety or support innovation.
Responding to the Government’s long-awaited position on ATRm, the ACA said industry still faced additional regulatory requirements almost five years after the UK’s departure from the EU chemicals framework triggered the need for a separate UK REACH system.
While the association welcomed the decision not to introduce further use and exposure requirements proposed during consultation, it argued that substantial obligations remain. Companies will still be required to submit hazard information, use and exposure data and, in some cases, chemical safety assessments and reports through substance groupings and joint submissions.
According to the ACA, the Government continues to rely on a “no data, no market” approach despite the fact that much of the relevant information is already publicly available through the European Chemicals Agency (ECHA) and safety data sheets.
The association also questioned the rationale for building a separate UK chemicals database for substances already registered under EU REACH before the end of the EU Exit transition period.
The ACA estimates the resulting data gathering and administration exercise could exceed £500 million, with costs ultimately falling on chemical manufacturers and wider downstream supply chains.
A particular concern centres on the UK’s evolving relationship with EU chemicals regulation. Defra has recently confirmed that UK REACH decisions on bans, authorisations and restrictions will largely align with EU REACH outcomes.
The ACA argues this significantly weakens the case for maintaining a parallel UK registration system.
“There is no added benefit to the high level of protection for human health and the environment,” the association stated, adding that any divergence from EU decisions is now expected to occur only in exceptional cases.
The group is instead calling for the UK to recognise EU registrations directly, describing this as the most effective route to supporting competitiveness, innovation and secure chemical supply chains while maintaining equivalent environmental and health protections.
According to the ACA, UK authorities could still maintain oversight of substances entering the GB market through a notification-based system rather than requiring full duplicate registrations.
The organisation also warned that the current approach could damage the UK’s attractiveness for innovation and scale-up activity, particularly for speciality and novel chemicals.
Under ATRm, substances registered in the EU after the end of the transition period will continue to require fully separate UK registrations, including generation of hazard data that may involve animal testing.
The association said this risks delaying market entry and increasing costs for companies developing innovative materials and products.
The issue is expected to be especially challenging for smaller businesses and downstream users importing chemicals and mixtures from EU suppliers. Under UK REACH, these firms can become first-time registrants for substances imported at volumes of one tonne or more annually, despite often lacking the resources or expertise required for complex data generation and registration processes.
The ACA also highlighted concerns over implementation timescales. Although the revised ATRm reduces some hazard-data requirements, companies will still need to comply with UK-specific registration deadlines scheduled for October 2029, 2030 and 2031.
The association noted that implementation periods are now expected to be compressed into 12-month windows rather than the 24-month periods originally anticipated, placing additional pressure on industry and laboratory testing activity.
Further uncertainty remains around the use of publicly available data. The Government response does not yet clarify whether companies will be permitted to use existing public data for UK REACH submissions without the consent of data owners.
According to the ACA, without urgent guidance on this issue, the revised ATRm may fail to deliver the cost reductions originally intended.
Pic: Marcin Jozwiak
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