Government response to UK REACH ATRm consultation released

The official government response to the feedback from the UK REACH Alternative Transitional Registration model (ATRm) consultation was released on the 30th of March 2026. The consultation requesting feedback on the ATRm proposal began 16th May 2024 and closed on 25th July 2024.

After the UK left the EU, the registration data for ~20,000 substances held by ECHA was not passed to the HSE. This presented a challenge to re-register substances already on the market, a process called ‘transitional registration’. This has created significant challenges due to the previously integrated nature of the EU and UK chemicals markets and the substantial costs to businesses submitting new registrations.

The ATRm aims to reduce these new costs, streamlining transitional registration while simultaneously upholding effective health and environmental protection.

Highlights of government response

In response to the feedback received from the consultation the government released their official statement regarding future action for UK REACH and transitional registration.

Going forward they intend to use pre-existing regulatory decisions from reputable jurisdictions to inform UK REACH decision making, including aligning more closely with the EU unless there are compelling reasons to diverge. The aim is to streamline the transitional registration process, reducing time, costs, complexity and trade barriers in a risk-proportionate manner.

Transitional substances have already been registered in other jurisdictions and are well understood. This allows transitional registrations to be submitted with a risk-proportionate decrease in upfront data requirements in comparison to novel substance registrations. However, regulators will have increased powers to request additional information when necessary.

The proposed increase to use and exposure information requirements will not go ahead in response to feedback to reduce regulatory burdens and costs.

Wider UK REACH reform commitments have been published in the Rolling Action Plan and Environmental Improvement Plan on replacing animal testing and updates to the reporting and restriction processes.

Legislative action will be brought forward in good time so that industry can meet updated registration deadlines and mitigate the negative impact of business uncertainty.

Next step for businesses

The first registration deadline in October 2029 might seem like a long way ahead, but businesses should start preparing their registration strategy now to ensure they are able to comply in good time. Key actions to take include:

1. Assign responsibility for managing the registration process

• Identify who in your organisation will lead and coordinate UK REACH registrations. 
• Assess whether they have the necessary skills, capacity and technical understanding.
• Consider whether additional training is required or whether external consultants will be needed.
• Ensure a realistic budget is in place for registration activities

2. Confirming which substances require registration. 

• Review your portfolio to determine which substances you place on the UK market and will need to register.
• If you intend to rely on another registrant (e.g., a supplier or only representative), verify that they still plan to register under UK REACH.

3. Check that classification and tonnage data are current

• Ensure that your classification, labelling, and annual tonnage information is accurate and up to date. 

4. Prepare analytical data to confirm substance identity

• Analytical data will be required for all substances to verify identity before you can submit an Inquiry. Consider how you will obtain this information: 
  • Do you already hold the data?
  • Can it be provided by your supplier?
  • Will laboratory testing be necessary?

• Remember: You cannot join a substance group to discuss joint registration until an Inquiry has been submitted.

5. Start gathering additional data that will be required to complete your registration, including use data

• Begin collecting information on uses, operational conditions, and risk management measures. 
• This data will be essential for completing your registration dossier.

6. Review high-hazard substances

• Identify any substances that may trigger enhanced regulatory scrutiny (e.g., SVHCs). 
• Assess whether continued use or import of these substances is commercially viable.

How Ricardo can help

Our expert team are here to help you though the process, from developing your strategy, training your team, authoring safety data sheets, preparing dossiers, acting as Only Representative for non-UK suppliers, to providing ad hoc consultancy support to answer your questions.

Contact our experts today

Maintaining compliance with UK REACH As part of the UK’s departure from the European Union the UK “lifted and shifted” the EU REACH regulation into UK law.  The UK has placed additional emphasis on the core pillars of REACH; to protect human health and the environment from the risks of chemical substances and to avoid testing on vertebrate animals. The regulation applies to substances which are manufactured or imported into Great Britain* at 1 tonne per year or more. Learn more