UK REACH Alternative Transitional Registration Model (ATRm)

Delays with UK REACH have been causing frustruations in industry for some time but the long anticipated UK REACH Alternative Transitional Registration model (ATRm) consultation is now open for comments until 11th July 2024. Another consultation on UK REACH fees is expected in the near future. 

The ATRm only applies to "existing substances", ie. substances that have been EU REACH registered by anyone by the time of the UK exit from the EU.

The costs associated with UK REACH (which applies in England, Wales and Scotland) have been estimated as £2 billion and the ATRm aims to reduce the costs to industry by simplyifying the registration process. The Department for Environment, Food and Rural Affairs (DEFRA) believes costs assosicated with submitting a registration dossier under UK REACH could be reduced by 70% against current UK REACH baselines.

The way costs have been reduced is by recognising that hazards of registered substances have already been identified under EU REACH and not requiring UK REACH registrants to obtain access to the studies that generated the respective substance hazard classifications under EU REACH. Repeating the same hazard information concerning the intrinsic properties of a substance would not lead to different hazard conclusions in UK REACH compared to EU REACH. Previously, obtaining the data from EU companies needed to register substances for the UK market was a large financial burden. 

Now, only hazard classification and labelling information will be needed in the substance registration dossier. The regulator will have the power to ask for further data if required and the classifications that will trigger additional data requests can be found in Article 14(4) of UK REACH, for substances at >10 tonne per year. Study summaries, testing proposals and chemical safety reports (CSR) are no longer needed unless the regulator requests them. This indicates that risks associated with the substances will be the key regulatory driver, rather than the intrinsic hazard of substances.

There will be a public register of UK REACH certified substances (owned by HSE) which will include hazard, use and exposure information (similar to existing ECHA database). The ATRm approach will reduce the need to repeat animal tests that were conducted to meet the information requirements of EU REACH, given the requirement to provide summaries of hazard study reports is removed from registration for all but new substances.

The consultation also outlines changes to the restriction proposal so that only one consultation will be required to restrict substances and the public will now only have three months to comment on proposed restricted substances. 

The BPF's response to the government announcement can be seen here. 

You can see the government consulation here. 

If you have any questions or comments, please contact Mary Aiken-Wood ([email protected])