Everything you need to know about the latest UK REACH revisions

For the UK market, the most significant change in the industry in recent years was the adoption of UK REACH legislation. We’ve previously provided a breakdown of UK REACH and what it means for the chemical supply chain, but the (very) short version is that UK REACH replaced the old EU REACH legislation following Brexit. Now, UK REACH is undergoing its first major policy revision – here’s what it means for the chemical industry.

An end to uncertainty…?

Since we wrote that blog – and indeed, since UK REACH first came into effect – Defra has undergone several major changes itself. A revolving door of Secretaries of State – including a brand new government – means that uncertainty has been rife. These changes could be seen as an attempt to clear up some of that uncertainty and answer the questions that the existing policy could not.

After the changes were announced, they were subject to an extended public consultation that ended in July. While some details may change slightly as a result of that consultation, it’s expected that the policy revision will include the following;

The introduction of the Alternative Transitional Registration model (ATRm)

The ATRm aims to reduce the costs of transitioning to UK REACH – estimated to cost the industry around £2bn – by streamlining the data requirements of transitional registrations. ATRm will reduce the ‘hazard’ information required for these registrations down to the essentials, removing the need for companies to pay for access to EU datasets.

The new model also aims to take a more targeted approach to data collection and reporting, focusing on understanding the use and exposure of chemicals in the UK. The end goal is to make chemical regulations more flexible, enabling regulators to respond more effectively to new risks as they emerge without placing unnecessary burdens on the industry.

Prioritisation of substances

The new policy establishes five priorities for managing chemical risks. This outlines key risks and actions for PFAS chemicals, formaldehyde and formaldehyde releasers, bisphenols in thermal paper, hazardous flame retardants, and microplastics.

These priorities were agreed with industry stakeholders from the UK Chemicals Stakeholder Forum and built in alignment with environmental policy.

Extended deadlines

Everyone, in every walk of life, appreciates an extended deadline. And, while they were announced in 2023, it’s worth reiterating that the UK REACH revision includes several;

• For substances included on the UK candidate list by December 31, 2023, and for substances classified as carcinogenic, mutagenic, or toxic for reproduction (CMRs) with an annual volume over 1,000 tonnes, the deadline is now October 27, 2026

• Substances classified as aquatic chronic 1 or aquatic acute 1 and manufactured or imported in quantities reaching 100 tonnes per year also have a deadline of October 27, 2026

• For substances manufactured or imported over 100 tonnes per year, the deadline has been extended to October 27, 2028. This deadline also applies to substances added to the candidate list between January 1, 2024, and October 27, 2026

• All remaining substances with volumes equal to or over 1 tonne per year must be registered by October 27, 2030

The reason for the extension is simple – it aims to reduce the financial and admin burdens businesses face while transitioning.

Fee structure review

Defra has announced a review of the fee structure of UK REACH, with the aim of developing a more sustainable funding model that is proportionate to the UK’s size as a market.

The review will retain the SME discount, which offers fee reductions of up to 90% on some charges, and includes the possibility of reducing the current fee levels across the board. In doing so, the review aims to improve access to the UK market for foreign businesses.

A work in progress

The chemical industry never stops – and neither does the evolution of regulations. A second consultation is already planned for an as-yet undetermined future date. This will be supported by a statutory instrument and a final impact assessment that should ensure the final policy revision meets the needs of the industry, the many stakeholders who rely on it, and the environment.

At ACI Group, we can help connect your business to some of the world’s leading chemical suppliers, bolstering your supply chains when you need it most. Most importantly, we possess the flexibility and agility to help you quickly adapt to any regulatory changes around the world. Get in touch today to learn more about our extensive portfolio and the services we offer.