UK REACH ATRm Policy Adjustment: Removal of Requirement for Additional Use and Exposure Information Submission

On March 30, 2026, the UK Department for Environment, Food & Rural Affairs (Defra) published the government response to the consultation on the UK REACH Alternative Transitional Registration Model (ATRm), announcing the cancellation of the originally planned requirement for companies to submit additional use and exposure information.

Policy Background

UK REACH is the primary UK regulation governing the manufacture, supply, and use of chemicals. Registration serves as its core function, following the "no data, no market" principle. Prior to Brexit, approximately 20,000 substances had been registered under EU REACH, but this data was not transferred to the UK regulatory authority (HSE), necessitating "transitional registration." From May 16 to July 25, 2024, Defra conducted a consultation with stakeholders regarding the UK REACH ATRm, receiving a total of 241 responses.

Core Adjustments to ATRm

1. Hazard Information Requirements
• Registrants are only required to submit hazard conclusions, rather than complete hazard datasets
• Introduction of a transitional evaluations mechanism, allowing regulatory authorities to request hazard data by tonnage band when necessary
• Status: Maintained – Consistent with the proposals in the consultation document
2. Use and Exposure Information
• Significant Adjustment: The additional use and exposure information requirements proposed in the consultation will not proceed
• Registrants are only required to submit use and exposure information in accordance with existing UK REACH regulations (primarily Annex VI)
• Rationale: Considering the future direction of UK REACH, the additional requirements would impose unnecessary regulatory burdens
3. Chemical Safety Assessment (CSA) and Chemical Safety Report (CSR)
• The CSR presents the substance's hazard information, thereby determining whether the registrant needs to conduct exposure and risk assessments
• It includes both hazard assessment conclusions and the data required for exposure assessment and risk characterization
• Status: Maintained – Consistent with the proposals in the consultation document
4. Substance Groups, Data Sharing, and Joint Submission
• Registrants should join substance groups to facilitate agreement on hazard conclusions, data sharing, and joint submissions
• Operates similarly to the EU's "Substance Information Exchange Forums" (SIEFs)
• Status: Maintained – Consistent with the proposals in the consultation document

Summary of Key Changes

Strategic Direction

The government has clarified that UK REACH will in the future:

• Align with EU decisions: Use regulatory decisions from the EU and other trusted jurisdictions as the starting point, unless there is compelling reason to deviate
• Accelerate protective measures implementation: Apply new protective measures more quickly and efficiently by leveraging EU assessments
• Reduce trade barriers: Address issues arising from UK REACH operating slower than EU REACH post-Brexit
• Reduce animal testing: Accelerate the development and application of alternative methods through a cross-government strategy

Next Steps

• The government will proceed with legislation at the appropriate time to ensure industry can meet the updated registration deadlines
• Proposals regarding improvements to restriction procedures and optimization of reporting processes will be incorporated into a broader UK REACH reform package in 2026
• The government acknowledges the uncertainty faced by businesses awaiting confirmation of final requirements and commits to providing clarity as soon as possible

About CIRS

Further Information

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