Regulatory Reactions
Draft proposalChemical management

UK consults on streamlined registration requirements for chemicals already on the GB market

The UK is consulting on draft legislation for its Alternative Transitional Registration model (ATRm), which would reduce information requirements for chemicals transitioning from EU to UK REACH. Comments are due by 10 November 2026 , with registration deadlines beginning 27 October 2029 .

4 min readNhat Nguyen
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The UK government is consulting on draft legislation that would substantially reduce the information businesses must routinely submit when registering chemicals that were already on the Great Britain market before the UK left the European Union.

The Department for Environment, Food and Rural Affairs (Defra) opened the technical consultation on 29 September 2026 as the next step toward implementing its Alternative Transitional Registration model (ATRm) under UK REACH. The consultation closes on 10 November 2026.

The policy itself is largely settled. The government confirmed its approach on 30 March 2026 following an earlier consultation. The current consultation instead asks whether the proposed legal wording accurately puts that policy into effect and whether it creates any gaps, ambiguities, or unintended consequences.

Less information required upfront

The ATRm is designed for transitional substances — chemicals that were already registered under EU REACH before the UK's departure and now need to transition into the Great Britain system.

Under the proposed model, manufacturers and importers would no longer routinely have to recreate the full set of hazard information previously submitted under EU REACH. Instead, registrants would submit their conclusions about a substance's hazards, while the Health and Safety Executive (HSE) would gain powers to request additional hazard information when needed.

This addresses one of the most expensive parts of the transition to UK REACH. Defra previously estimated that applying the existing registration requirements to transitional substances could cost the industry about £2 billion by 2030, although it acknowledged significant uncertainty around that estimate.

The government is not, however, removing registration. UK REACH's principle that a substance must be registered to be placed on the market remains in place.

Additional use and exposure requirements dropped

The government has also abandoned an earlier proposal to require businesses to submit additional Great Britain-specific information on how chemicals are used and how people or the environment may be exposed.

Registrants would instead continue providing the use and exposure information already required under UK REACH. Defra said the additional requirements would create unnecessary regulatory burdens given its wider approach to chemicals regulation.

For businesses required to assess chemical safety, the ATRm would also change how that information is submitted. Registrants would provide the key hazard information used to determine whether a more detailed assessment of exposure and risk is necessary.

Companies registering the same substance would also be expected to work together in substance groups to agree on hazard conclusions, share relevant data, and, where applicable, share the costs of jointly submitting that information.

Registration deadlines already moved to 2029–2031

The ATRm legislation is not yet final, but the government has already extended the deadlines for completing transitional registrations.

The REACH (Amendment) (No. 2) Regulations 2026, which took effect on 6 August 2026, moved the deadlines to:

  • 27 October 2029 for substances manufactured or imported at 1,000 tonnes or more per year. The same deadline applies to substances that are carcinogenic, mutagenic or toxic for reproduction at 1 tonne or more per year; substances very toxic to aquatic organisms at 100 tonnes or more per year; and substances placed on the UK REACH Candidate List by 27 October 2027.

  • 27 October 2030 for substances manufactured or imported at 100 tonnes or more per year, and substances added to the Candidate List between 28 October 2027 and 27 October 2028.

  • 27 October 2031 for all remaining substances manufactured or imported at 1 tonne or more per year.

The extension gives Defra time to finalize the ATRm before businesses have to submit their transitional registration information. It does not suspend existing UK REACH obligations while the new model is being developed.

Companies have until 10 November to review the legal framework

For manufacturers, importers, and other businesses involved in transitional registrations, the immediate issue is therefore not whether the government will pursue the ATRm, but whether the draft legislation works as intended.

Defra is specifically asking stakeholders to identify drafting problems, omissions, inconsistencies, procedural gaps, or unintended consequences before the legislation is finalized. Businesses should review whether the proposed framework accurately reflects how their transitional registrations would work in practice and identify problems that could affect their ability to submit information or participate in substance groups.

Comments must be submitted to Defra by 10 November 2026.

Regulatory Status

  • Draft proposal

Topics

  • Chemical management
  • UK-Reach
  • Product registration