Three key UK REACH updates from the ATRm

The UK Government has released a short policy paper on the progress they had made and their current policy direction of the UK REACH Alternative Transitional Registration model (ATRm). The announcement reaffirms the aim of the ATRm, which is to allow UK companies who held EU REACH registrations prior to 1 January 2021 to avoid paying for the same data again for the same registrations under UK REACH. The announcement does not go into detail about how this will be achieved, however, there are three key points we can take from it:

1. The policy direction is given as ‘reducing to the essential minimum the ‘hazard’ information required for transitional registrations and intermediates’. Although what this will actually mean is not specifically stated. The bare minimum ‘hazard’ information would be the classification and labelling of the substance. While this could aid in setting regulatory targets it would not provide information in sufficient detail for the UK Health and Safety Executive (HSE) to evaluate a registration. The UK government will need to balance the cost paid by industry with its overarching commitment to high levels of protection of human health and the environment.

2. The announcement also states that ‘use and exposure’ information is critical for industry to understand and manage risks of chemicals and that ‘Great Britain regulators need to prioritise regulatory action’. Whether this statement signifies a move away from hazard based towards risk based regulatory action cannot be confirmed at this point, although it does provide a useful insight into regulatory prioritisation undertaken by the HSE.

3. The fee structure for UK REACH will be reviewed ‘to ensure a more sustainable funding model’, as the HSE operates a Fee for Intervention model (currently set at £166/hour) to recover costs of enforcement actions from companies. It is unlikely that the cost will fall drastically.

While this announcement is a welcome restatement of the commitment to the ATRm there is no real detail on how this will be implemented and industry will have to continue to wait to see what this will mean for their regulatory burden.

At Ricardo, we have strong ties within the industry, the government and the policymakers. Combined with
in-depth knowledge of the global chemical marketplace and its interactions with stakeholders, we can help you to understand what your requirements are, assist you with your REACH registrations, offer dossier improvement, evaluation support, environmental chemistry and toxicology services to help with choosing the right assessment method and help you keep abreast of upcoming changes. Find out more about our regulatory expertise here.