On 30 March 2026, the UK government published its response to the consultation on the Alternative Transitional Registration model (ATRm) under UK REACH, confirming a revised approach to transitional registrations for substances already on the GB market.
The consultation ran from 16 May to 25 July 2024 and received 241 responses from stakeholders, including industry representatives, non-governmental organisations (NGOs) and public bodies. The response outlines how registration requirements will be simplified, while also confirming that legislative changes are still required before the new model will take effect.
The ATRm is part of a wider effort to overcome challenges following the UK’s departure from the EU, such as losing access to EU REACH registration data for approximately 20,000 that were substances previously registered on the EU market. This has led to concerns over duplication of data, increased costs for industry, and slower regulatory processes. The revised approach aims to reduce administrative burdens while maintaining high levels of protection for human health and the environment. This will be achieved through greater reliance on existing hazard assessments and regulatory decisions.
Reduced Upfront Data Requirements Confirmed
Under the ATRm, companies will no longer be required to replicate full EU REACH registration dossiers. Instead, a reduced dataset reflecting that many substances have already been assessed under existing regulatory frameworks will have to be submitted at the initial stage.
Key elements of the new approach include:
- Hazard information to be submitted in the form of conclusions rather than full study reports at the initial stage.
- Chemical Safety Reports (CSRs) and Chemical Safety Assessments (CSAs) will be applied in a more targeted manner, with full assessments developed only where necessary.
- Use and exposure information will follow existing UK REACH requirements, without introducing additional GB-specific data obligations.
- Greater use of substance groupings to facilitate data sharing and joint submissions.
At the same time, the Health and Safety Executive retains the authority to request further data, including hazard or exposure information, on a case-by-case basis through transitional evaluations, including according to tonnage where necessary.
Removal of Additional Use and Exposure Requirements
A key policy adjustment involves the removal of the previously proposed requirement for additional use and exposure information. The government has confirmed that these requirements will not be pursued, in response to stakeholder concerns about their complexity, feasibility and cost.
Alignment with EU and Strategic Direction
The government also confirmed that UK REACH will take regulatory decisions from trusted jurisdictions, primarily the EU, as a starting point, aligning unless compelling reasons exist to diverge.
More broadly, the response signals a shift towards a more streamlined and risk-based system, including efforts to reduce duplication, improve regulatory efficiency, accelerate the implementation of protective measures, and reduce reliance on animal testing.
Consultation Feedback and Outstanding Questions
The consultation responses indicated broad support for a more proportionate registration model, particularly from industry stakeholders seeking to reduce duplication and compliance costs. However, respondents also raised concerns regarding regulatory clarity, the operation of case-by-case data requests, and access to underlying study data.
The shift towards hazard-based submissions is expected to reduce the need for access to full study reports, though uncertainty remains over how data requests will be managed in practice.
Legislative Changes Still Required
Importantly, the publication does not introduce legally binding requirements, but it does confirm the policy direction. The government has indicated that it will bring forward legislation to implement the ATRm and associated changes to UK REACH.
In this context, the revised transitional registration timelines remain relevant, with deadlines expected to fall in October 2029, 2030 and 2031, depending on tonnage and hazard profile.
Outlook
The ATRm represents a significant shift in UK REACH, moving towards a more proportionate and risk-based registration model. While it reduces the initial data requirements and administrative burden, the practical impact will depend on how the model is incorporated into legislation and applied by regulators.
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