The Alternative Transitional Registration Model for UK REACH Has Been Published

The Government has published its response to the consultation on the Alternative Transitional Registration Model for UK REACH — generally referred to as the ATRm. It’s a significant piece of the post-Brexit chemicals framework, and it directly addresses a problem the original transitional registration arrangements had been criticised for since they were introduced: duplicated work, high cost, and processing delays that left parts of industry effectively stuck waiting.

What problem this is solving

Substances that were already registered under EU REACH before the UK’s exit needed a separate UK registration to continue being placed on the Great Britain market, even though the underlying safety data was often identical. That duplication was expensive, slow, and fell hardest on smaller businesses without the resource to run two parallel registration processes for the same substance. The ATRm consultation, held in 2024, set out to fix that.

What the model actually does

• Less duplicated upfront data. Transitional registrations will require less hazard data upfront than originally proposed, recognising that much of it already exists from prior EU registration.
• Alignment with trusted jurisdictions. Where EU REACH has already reached a considered position on a substance, the UK intends to draw on that work as its starting point rather than repeating the assessment from scratch, only diverging where there’s a clear UK-specific reason to do so.
• “No data, no market” still applies. This isn’t a lowering of the underlying safety bar — core hazard information, use and exposure data are still required, and authorities retain the power to request further data where it’s needed for a regulatory decision.
• Extended, staggered deadlines. Transitional registration deadlines are being pushed out to 27 October across 2029, 2030 and 2031, subject to the necessary Scottish and Welsh ministerial consent, giving registrants considerably more planning time than the original timeline allowed.
• Substance groupings. Registrants will be able to participate in substance groupings similar in structure to those used under EU REACH, rather than every registrant working entirely in isolation.

What registrants still need to do

The lighter-touch data requirements don’t remove the underlying obligation. Businesses relying on transitional arrangements will still need to submit core hazard information, use and exposure data in line with UK REACH guidance, and targeted chemical safety assessments where these are triggered by the substance’s profile. The ATRm changes how much duplicated work that takes — not whether the work needs doing at all.

How we can help

We help clients work out what the ATRm actually changes for their specific substances, what data they can now carry across rather than regenerate, and how the revised deadlines fit into a realistic registration plan.

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