Defra has published a consultation on reforming the registration model of REACH to a new system called the Alternative Transitional Registration model (ATRm).
The consultation consists of 35 questions separated into ten chapters. Key proposals relevant to the tech sector include:
- The UK proposes to require registration dossiers only for the highest-risk chemicals, shifting from a hazard-based to a risk-based approach. The approach involves assessing high-risk substances using hazard information and associated exposure data to manage specific risks within Great Britain. This change responds to a post-Brexit scenario, which Defra estimates would cost firms £2 billion for substance registration. The new approach is expected to reduce these costs by 70%.
- The consultation covers four main areas: Registration Requirements (Hazard data), Substance Groups (Data sharing and joint submission), Powers and Duties (Transitional evals, compliance checks and data publication) and Registration Requirements (Use and Exposure).
- For substances with human health risks, there will be 3 levels of information required:
- Level 1: existing requirements for use and exposure.
- Level 2: percentage of substance in a mixture, its physical form, the number of sites or professional uses, number workers using the substance at an industrial site, exposure reduction methods and routes in which exposure could be regarded as ‘negligible' and why.
- Level 3: further details on potential exposure levels and total consumer use estimates. This applies only to 1-10 tonne registrations, as higher tonnage bands will have necessary information provided through CSA/CSRs.
- Unlike the EU's Substance Information Exchange Forums (SIEFs), UK REACH groups registrants into "substance groups." Defra now aims to make this grouping a requirement. These groups will manage costs, agree on hazard information, and respond to consultations, although members can still opt out of joint submissions.
- Existing hazard requirements will continue to apply to new and novel substances not registered under EU REACH before Brexit.
- Defra proposes a shortened decision-making timeline for restrictions, aiming for decisions within 24 months.
A more detailed briefing deck prepared by Defra can be found here.
Submissions and next steps
The consultation closes on 11 July 2024. techUK will be responding, and members are welcome to share their views during a scoping call that will take place on Tuesday 28 May between 3 and 4 PM. For those unable to attend, input can be sent to Craig Melson (Craig.Melson@techUK.org).
The government plans to publish its response to the consultation within 12 weeks after it ends. There will be a second consultation specifically focused on the legislation under the Environment Act. Defra aims to have legislation in place by 2025.
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