The Alliance of Chemical Associations (ACA) has dismissed the government's latest proposals for UK REACH as a "missed opportunity" that will continue to burden industry with duplicative costs despite recent concessions on data requirements.
The ACA's response follows the publication of the government's consultation response on the Alternative Transitional Registration model (ATRm), which has been under debate for almost five years since Brexit.
Whilst the government has dropped the additional use and exposure requirements originally proposed - a move the ACA welcomed - the alliance argues that remaining obligations for hazard data, use and exposure information, and chemical safety assessments will still impose costs of over £500 million on UK businesses.
"Our position on providing data for the registration of substances already registered under EU REACH is and has always been clear," the ACA stated. "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."
The criticism comes despite the government's recent commitment to align UK REACH regulatory decisions with EU REACH for bans, authorisations, and restrictions, with divergence only in exceptional cases.
'No data, no market' questioned
The ACA challenged the government's "no data, no market" principle, arguing that hazard and use and exposure data is already publicly available on the ECHA website and in substance safety datasheets.
The alliance questioned the logic of building a separate UK chemicals database for potentially up to 20,000 substances already registered under EU REACH before the end of the EU Exit Transition Period, particularly when the government has indicated it will accept EU regulatory decisions.
For new or novel chemical innovations registered in the EU since the transition period ended, the ATRm approach maintains fully duplicative UK and EU REACH registration requirements, including hazard data generation that may involve animal testing.
"By insisting on fully duplicating UK and EU REACH registration requirements for new or novel chemical innovations registered in the EU since the end of the EU Exit Transition Period, the approach undermines yet again the UK's attractiveness as a location for innovation, investment and scale-up," the ACA said.
Implementation timeline concerns
Under the revised ATRm proposals, businesses will face compressed implementation timelines with registration deadlines squeezed into 12-month periods (27 October 2029, 27 October 2030, and 27 October 2031), rather than the originally expected 24-month periods.
The situation is particularly challenging for distributors and downstream users - frequently SMEs - who import chemicals from EU suppliers as mixtures and will be forced into the role of first-time registrants for substances imported at one tonne or more per year.
Alternative approach proposed
Instead of the ATRm model, the ACA has called for the UK to recognise all EU registrations, which it argues would align with the government's stated objective of following EU decisions on chemical regulation.
"There is already a clear approach the UK could adopt: recognise all EU registrations, in line with the overarching UK objective to align with the EU," the alliance stated. "Extending this logic to UK REACH registrations would be the most effective way to support innovation, competitiveness and secure supply whilst maintaining the same robust health and environmental protections as the EU."
The ACA suggested that UK authorities could maintain market visibility through a notification process requiring information on which substances are placed on the GB market and in what quantities, which could satisfy the legislation's "no data, no market" requirement.
Outstanding issues
The government response has not yet provided clarity on the use of publicly available data for UK REACH registration purposes. The ACA warned that without urgent official guidance on whether public data can be used for UK submissions without data owners' consent, the ATRm risks failing to deliver intended cost reductions.
The Alliance of Chemical Associations represents 15 trade associations covering approximately 1,400 companies, the majority of which are SMEs operating across the chemical industry supply chain from manufacturing and distribution to end-use applications including plastics, paint, and cosmetics.
The response represents another challenge to government claims of commitment to growth and regulatory streamlining, as costs of doing business in the UK continue to rise due to energy, employment, and raw material pressures.
Chemical associations criticise UK REACH alternative model despite government concessions
