The Blog

The UK Government has launched a new technical consultation on Alternative Transitional Registration model (ATRm) for UK REACH, proposing significant changes aimed at reducing regulatory burdens while maintaining protections for human health and the environment.

Key proposals include:

1. Reduced Registration Information

Instead of submitting full study summaries and testing datasets, eligible registrants would provide:

• Classification and labelling information
• Safe-use guidance
• Relevant exposure information
• Key chemical safety assessment outcomes
• Confirmation that conclusions are consistent with EU REACH data, or explanations where they differ

2. Application to Existing and New Registrations

The ATRm would apply to:

• Existing transitional (grandfathered) UK REACH registrations
• New registrations of substances already registered under EU REACH (NRES)
• Certain registrations following Downstream User Import Notifications (DUINs)
• Some isolated intermediate registrations

3. Transitional Evaluation Powers

Because less data would be submitted initially, the Health and Safety Executive (HSE) would receive new powers to:

• Review registrations
• Request additional information where concerns arise
• Issue draft and final evaluation decisions
• Require further testing or assessment when justified

The consultation proposes:

• 30-day comment periods on draft decisions
• Appeals rights for registrants
• Completion of evaluations within 12 months after requested information is supplied

4. Substance Groups and Data Sharing

The proposal introduces formal Substance Groups for companies dealing with the same substance. Participants would be required to:

• Share information and data
• Cooperate on classifications
• Avoid duplicate testing
• Share costs fairly, transparently and non-discriminatorily

If companies cannot agree who should undertake a new study, the Agency could designate a registrant to do so.

5. Retention of Existing Exposure Requirements

The Government has decided not to introduce new use and exposure reporting requirements that were previously discussed in the 2024 consultation. Current UK REACH requirements on use and exposure information would remain largely unchanged.

6. Fee Exemptions

No additional fees would be payable for submitting outstanding information needed to complete transferred registrations under the new transitional arrangements.

Consultation Details

• Opened: 29 September 2026
• Closes: 10 November 2026
• Duration: 6 weeks

The consultation is aimed at:

• Chemical manufacturers and importers
• Downstream users
• Industry associations
• NGOs
• Other stakeholders affected by UK REACH

Main Consultation Questions

Stakeholders are asked to comment on:

• The clarity and effectiveness of the new drafting
• Reduced information requirements
• Chemical safety assessments
• New registration provisions
• Intermediate registrations
• Transitional evaluation powers
• Data-sharing and substance group arrangements
• Joint submissions
• Fee exemptions
• Any unintended legal or operational consequences

Bottom Line

The ATRm is a significant reform of UK REACH intended to reduce costs and duplication for businesses by relying more heavily on existing EU REACH registrations, while giving UK regulators targeted powers to obtain additional information when required. The consultation focuses mainly on whether the proposed legal drafting delivers those policy objectives effectively.

Should you need support or have any questions regarding UK REACH, contact us at sales@reachlaw.fi for assistance.