Summary of responses and government response
Updated 30 March 2026
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1. This document sets out the government response to a consultation on the UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation (UK REACH), including the proposed alternative transitional registration model (ATRm). It also provides a summary of the feedback received by the Department for Environment, Food and Rural Affairs (Defra) to the consultation questions. The consultation began on 16 May 2024, under the previous government, and concluded on 25 July 2024.
2. A total of 241 responses were received, and Defra is grateful to everyone who took the time and effort to respond. The responses have been analysed by Defra staff dealing with the consultation proposals.
Government response
3. UK REACH is one of the main pieces of legislation overseeing chemical manufacture, supply and use in Great Britain (England, Scotland and Wales). Registration is a key function of this regulation and built into its overall framework. Registration drives producer accountability and provides regulators with critical data. Unlike an approval regime, UK REACH does not require substances to be pre-approved for market entry. Instead, the information collected through registration enables regulators to assess risks and, where necessary, take action in due course by adding substances to the UK REACH:
- candidate list (which classes a substance of being ‘of very high concern’)
- authorisation list (which requires a business to secure regulatory approval to use a substance)
- restriction list (which bans or otherwise restricts a substance for all users)
4. Before EU exit, about 20,000 on the GB market were already registered with EU REACH. This data was not passed to the UK REACH regulator, the Health and Safety Executive (HSE), when we left. As a result, UK REACH requires businesses to re-register key information with the HSE to ensure transparency about the chemicals on the market. This process also maintains confidence that these chemicals can be used safely in GB. This is known as ‘transitional registration’ and was the focus of this consultation on the alternative transitional registration model (ATRm).
5. Going forward, our intention is for UK REACH to take regulatory decisions made by other trusted jurisdictions, especially the EU, as the starting point for our own, and to align our regulatory decisions with EU decisions unless there are compelling reasons to diverge. This is set out in the UK REACH: rationale for priorities 2025 to 2026 (RAP) and the Environmental Improvement Plan (EIP) 2025 which outline a clear path forward for UK REACH overall. This will enable new protections to be applied more quickly and efficiently. This commitment also affirms our determination to protect people and the environment, and to reduce the business complexity and trade barriers. Particularly those that have emerged following EU exit as a result of UK REACH operating much more slowly than EU REACH. This unintended divergence has been detrimental to our sector given our close integration with the EU sector.
6. The substances which are subject to transitional registration were registered previously with the EU REACH regulator and are already well understood and managed internationally. Consequently, transitional registrations should require less information to be registered with the HSE than for a substance being placed on the GB market for the first time. In line with our better regulation principles, we are adopting a more proportionate registration approach that reduces the upfront data requirements. To balance this, we will also strengthen our ability to request additional information later from individual businesses, should this be necessary to support regulatory activity.
7. Our new transitional registration requirements relate to the minimum amount and type of information that needs to be registered upfront, consistent with the ‘no data, no market’ principle that is the bedrock of UK REACH. The registration requirements do not vary according to the type and size of business. Instead, the obligations vary according whether a substance is being supplied at above or within 1 to 10 tonnes a year and according to its hazard classification.
8. We will not introduce additional registration requirements relating to the ‘use’ of chemicals and to the ‘exposure’ they generate. Given the future path of UK REACH, applying additional requirements would be unnecessary and would create new regulatory burdens for GB-registered businesses. This decision reflects the responses we received to the consultation proposals to apply these additional requirements. We will also be retaining the hazard baseline approach outlined in the consultation, as well as supporting policy elements. Additionally, we will be introducing the proposed changes to the chemical safety assessment, to the chemical safety report, and to the treatment of substance groups.
9. The consultation also encompassed questions on improvements to the UK REACH regime itself. This included proposals on reporting, on the processes applying to adding substances to the UK REACH Restrictions List, and on the use of animal testing. These proposals were designed to make UK REACH smarter, more agile and more functional. We have since published commitments in the RAP and EIP, in light of which we are revisiting these proposals and integrating them into an overall package of broader reforms on UK REACH. These reforms seek to enable protections that address chemical pollution to be applied more quickly, efficiently and in a way that is more aligned with the EU. This work will be informed by the consultation responses we have received.
In regard to animal testing, the Department for Science, Innovation and Technology published Replacing animals in science: A strategy to support the development, validation and uptake of alternative methods on 11 November 2025. This cross-government strategy will accelerate the roll-out of safe and effective alternatives to animal testing.
10. We recognise the impacts of business uncertainty stemming from the wait for confirmation of the final transitional registration requirements. We will bring forward legislation in good time to ensure industry can meet the updated registration deadlines.
The ATRm at a glance
11. The government’s approach to regulating chemicals in a way that draws more from EU regulatory assessments and decisions, supports more streamlined overall regulation in a way that keeps trade moving while protecting human health and the environment.
12. This means we have adjusted the transitional registration requirements proposed in the consultation so that less information needs to be registered with the UK REACH regulator. We will still apply the ‘no data, no market’ principle as part of a clear framework that supports robust environmental protections. The ATRm will therefore involve actions required for each of the following registration requirements:
- hazard information
- use and exposure information
- chemical safety assessments (CSA) and chemical safety reports (CSR)
- substance groups, data sharing and joint submission of data
Hazard information: action required
Registrants will submit hazard conclusions. We will introduce transitional evaluations to ensure the regulator has powers to request hazard data, if necessary, in line with the tonnage of the substance. This approach remains the same as set out in the consultation.
Use and exposure information: action required
Registrants will submit ‘use’ and ‘exposure’ information in line with the existing UK REACH regulations (primarily detailed in Annex VI). This marks a departure from the proposals in the consultation, which involved registering additional ‘use’ and ‘exposure’ information.
Chemical safety assessments and chemical safety reports: action required
The full CSA or CSR process asks relevant registrants to provide detail on exposure scenarios and risks associated with the use of the substance. Under the ATRm, the CSR will report the key hazard data that determine whether the registrant has to proceed to the exposure and risk parts of the CSA. This will be alongside the hazard assessment conclusions and the data needed to undertake exposure assessment and risk characterisation (if triggered). This approach remains the same as set out in the consultation
Substance groups, data sharing and joint submission of data: action required
Registrants should join substance groups to facilitate agreement of hazard conclusions, the sharing of data and, if relevant, any costs associated with the joint submission of that data. These will operate in a similar way to the EU’s ‘Substance Information Exchange Fora’ (SIEFs), which group relevant stakeholders for a substance to facilitate cooperation and better read-across. This approach remains the same as set out in the consultation.
Background to the consultation
13. UK REACH is one of the main pieces of legislation overseeing chemical manufacture, supply and use in GB. Under the terms of the Windsor Framework,Northern Ireland continues to apply EU REACH to preserve its unique dual market access to both the EU market and the UK internal market.
14. Both EU REACH and UK REACH operate under the principle of ‘no data, no market’ which states that substances should not be placed on the market unless they have been registered. Without the ATRm, the current registration requirements which apply to substances which are being placed on the GB market for the first time would also apply to transitional registration. This could generate one-off costs of approximately £2 billion for industry by 2030 (this figure is uncertain and is the midpoint of a range £1.3bn to £3.3bn, with the final figure depending on how businesses meet the requirements). Recognising industry concerns about disproportionate burdens, the ATRm was developed.
15. Defra, the HSE and the Environment Agency (EA), in cooperation with the devolved governments, have developed the ATRm within the framework of UK REACH that aims to reduce the costs to industry of transitional registration. The ATRm will be implemented using the powers to amend UK REACH that are contained in the Environment Act 2021, as well as powers contained in UK REACH. This approach is in line with the aim and purpose of UK REACH to ensure a high level of protection for human health and the environment.
Purpose of consultation
16. The consultation aimed to gather stakeholders’ views on policy options regarding the UK REACH ATRm, applicable to UK REACH registrants of transitional substances. The consultation also sought feedback from stakeholders on some proposed UK REACH improvements, including potential changes to restrictions, reporting processes, and measures to strengthen protections against unnecessary animal testing. While the latter set of proposals will now be taken forward separately, we have included analysis of the responses to those questions as part of our overall consultation response.
Period of consultation
17. The consultation ran for 10 weeks between 16 May and 25 July 2024 and was live on the Citizen Space website. Email and postal responses were also accepted during this period.
Consultation process
18. Defra met a range of interested parties including industry, trade organisations and non-governmental organisations to discuss the proposals before the period of the consultation. Many of those who took part subsequently responded formally to the written consultation. To increase awareness, especially among the target audience, the consultation was publicised on HSE’s website and via the HSE e-Bulletin. Pre-election period rules prevented further engagement on the consultation during the election period.
Overview of the respondents
19. A total of 241 responses were received, 215 of which were submitted via the Citizen Space website, 25 via email and one response was received by post. Some respondents who used the Citizen Space website also sent in additional comments by email and post. These additional comments were considered but not counted twice. Questions did not necessarily receive a 100% response rate. A breakdown of the responses is represented in Table 1 below.
Breakdown of consultation respondents by type
Table 1: Respondents by organisation type
| Respondent type | Number of respondents |
|---|---|
| A government body | 2 |
| Non-governmental organisations (NGO) | 9 |
| Local authority | 0 |
| Charity | 3 |
| Consultancy | 25 |
| Small or micro business (Less than 50 employees, including any global operations) | 21 |
| Medium business (50 to 249 employees, including global operations) | 29 |
| Large business (250 or more employees, including global operations) | 99 |
| Industry association | 35 |
| Other | 17 |
| Not answered | 1 |
| Total | 241 |
20. Question 7 of the consultation asked respondents about their legal responsibilities and roles under UK REACH. Respondents could select more than one role. The responses received (Table 2) demonstrate that a significant number of respondents were importers of substances and mixtures from the EU and European Economic Area (EEA). There was also a high number of respondents who identified as downstream users.
Table 2: Responses by role
| Role of respondent | Number of respondents |
|---|---|
| Only Representative (OR) | 65 |
| Manufacturer of substances | 70 |
| Importer of substances and mixtures from the EU or EEA | 128 |
| Importer of substances and mixtures from Northern Ireland | 33 |
| Importer of substances and mixtures from Rest of the World (RoW) | 115 |
| Exporter of substances from GB to the EU or EA | 93 |
| Exporter of substances from GB to RoW | 86 |
| Downstream user of chemical substances (companies who directly handle chemical substances in the course of their business activities and are not themselves the GB-based manufacturer or importer of the substances) | 100 |
| Not applicable | 56 |
| Other | 25 |
| Not answered | 1 |
Methodology
21. Most of the consultation questions provided respondents with a “yes”, a “no” or a “don’t know” option. To measure the strength of feeling, respondents were also presented with “strongly agree”, “agree”, “neither agree nor disagree”, “disagree”, “strongly disagree”, “I don’t know” and “prefer not to say” options. Respondents were also given the opportunity to provide written comments to most of the questions. The “yes”, “no” and “don’t know” responses, as well as the strength questions, have been quantified in the summary of responses by question below. In parallel, any written comments provided by respondents (qualitative responses) have been analysed and fully considered by Defra. The summary of responses to each question combines both the quantitative and qualitative analysis of the responses received.
22. Any percentages (%) present in this document have been rounded to the nearest 1%. As a result, some percentage totals may not add up to 100%.
Summary of responses
23. This summary is an overview of the main messages from the consultation responses, reflecting the views offered. It does not provide any detailed analysis or a government response to the consultation responses on a question-by-question basis.
24. There were 35 questions in the consultation document. Seven of these were background questions about the respondents, providing important contextual information. The responses received in relation to the specific policy questions (question 8 to question 35) raised in the consultation paper are summarised below.
Summary of responses: ATRm policy proposals
Hazard requirements
Question 8: To what extent do you agree that the removal of the more detailed elements of the hazard information requirements from UK REACH registrations would not compromise high levels of protection of human health and the environment?
Table 3: Responses to question 8
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 88 | 37% |
| Agree | 93 | 39% |
| Neither agree nor disagree | 22 | 9% |
| Disagree | 15 | 6% |
| Strongly disagree | 11 | 5% |
| I don’t know | 4 | 2% |
| I’d prefer not to say | 7 | 3% |
25. The distribution of responses to question 8 varied between respondent groups. Whilst just under 90% of both large and medium businesses (and 77% of Small or micro businesses) agreed or strongly agreed with this statement, 55% of NGOs and 66% of charities disagreed or strongly disagreed.
26. Respondents were also given an opportunity to provide additional qualitative information to support their responses to this question. The main themes that emerged from the information provided by respondents who agreed or strongly agreed with the proposition in question 8 were:
- understanding of hazards: Respondents suggested that, as transitional substances had already been assessed under their EU REACH registration, there is already a high level of hazard understanding.
- availability of hazard data: They also noted that hazard information for these substances is readily available from EU REACH and other sources.
- avoiding duplication: Many believed that the proposal would prevent unnecessary repetition of steps already completed under EU REACH.
27. The main themes that emerged from the information provided by respondents who disagreed or strongly disagreed with the proposition in question 8 were:
- concerns about limited data: Respondents felt the data required under the ATRm would be insufficient for effective hazard assessment.
- introduction of hazardous substances: Some organisations, particularly NGOs, expressed concerns that the model could result in more hazardous substances entering the UK market compared to the EU.
- call for EU alignment: Advocacy for aligning with the EU approach to ensure stronger protection of human health and the environment.
28. A common concern among respondents, regardless of their stance on the question, was data accessibility and the risk of infringing intellectual property rights linked to the proposed approach to hazard data (see question 10 for more details).
Question 9: What are your views on our assessment that the regulator does not need to hold a replica set of hazard data (the same used for EU registration dossiers) to inform prioritisation of regulatory actions?
29. This was an open text response question, so the nature of responses varied. However, in general terms, those who agreed or strongly agreed in their reply to question 8 supported this assessment and those who disagreed or strongly disagreed did not- leading to similar themes in responses overall.
Question 10: Please comment on the extent to which you expect the revised hazard data requirements will reduce costs to business. Where possible, please provide supporting quantitative evidence.
30. Half of respondents to this question expected costs to fall as a result of this measure. However, there was some concern that this reduction may be less than forecasted in the impact assessment due to what they saw as potential legal issues associated with intellectual property rights.
31. A large proportion of responses indicated uncertainty about how costs might change. For example, many said that it would be dependent on costs of data access or would vary from substance to substance and so could not indicate an overall direction. Very few expected costs to increase.
32. Respondents expect costs to fall as a result of:
- reduced costs of testing: no longer having to either pay for the rights to tests, or pay to replicate tests, should save a substantial amount for many firms
- reduced administrative costs: reduced information requirements are expected to carry over into reduced labour costs when completing the registration dossier
- simplification of compliance processes: less expert information should be required to complete the dossier
33. Respondents who did not expect this measure to save money gave explanations including:
- already owning the data that would no longer be required, meaning that even under the standard UK REACH registration model they would already have minimal costs
- worries about legal risk from taking hazard data from the European Chemicals Agency (ECHA) website without paying a data access or copyright licence fee to the owner of the study. In particular data on ‘predicted no effect concentration’ (PNEC) and ‘derived no effect level’ (DNEL).
Use and exposure information
34. As noted at the start of this consultation response, the proposals for ‘use and exposure’ data will not be taken forward. However, we felt it was important to include the analysis of responses for transparency.
Question 11: To what extent do you agree that requesting more detailed, Great Britain-specific use and exposure information will meet the aims of improving industry’s risk management of chemicals and the regulatory capability for the regulators?
Table 4: Responses to question 11
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 12 | 5% |
| Agree | 36 | 15% |
| Neither agree nor disagree | 63 | 26% |
| Disagree | 73 | 30% |
| Strongly disagree | 30 | 12% |
| I don’t know | 21 | 8% |
| I’d prefer not to say | 6 | 2% |
35. There was no requirement for respondents to provide any qualitative information under this question. Nevertheless, some respondents did provide qualitative input on the issue, either elsewhere in the consultation document or by written responses.
36. Nearly all respondents who provided qualitative feedback to question 11 were those who disagreed or strongly disagreed with the proposition. The main themes were:
- cost and burden: Many cited the cost and effort that would be required to obtain the requested information as a primary reason for their disagreement. More detailed information about these factors can be found under questions 13 and 14, which directly address the costs of this measure.
- effectiveness of additional data: Concerns were raised that the additional data being requested under the ATRm on use and exposure may not necessarily result in improved risk management outcomes.
- alternative approaches: Several respondents suggested that the regulators should leverage existing data sources, such as information available in e-safety data sheets, Control of Substances Hazardous to Health (COSHH) risk assessments, and Occupational Exposure Limits, to enhance risk management and Dangerous Occurrence Regulations (RIDDOR Regulations)
Question 12: To what extent do you agree with the proposed trigger points and corresponding information requirements for registrants outlined in Annex B of the consultation?
Table 5: Responses to question 12
| Number of responses | Percentages of respondent | |
|---|---|---|
| Strongly agree | 3 | 1% |
| Agree | 29 | 12% |
| Neither agree nor disagree | 56 | 23% |
| Disagree | 97 | 40% |
| Strongly disagree | 33 | 14% |
| I don’t know | 15 | 6% |
| I’d prefer not to say | 8 | 3% |
37. The responses to question 12 showed variation across different respondent groups. Among the 32 respondents who agreed or strongly agreed with the proposition, 47% identified as large businesses, nearly 20% as consultancies, 12% as small or micro businesses, and 9% as industry associations.
38. Almost 80% of those who disagreed or strongly disagreed were businesses (small, medium and large). Industry associations accounted for 11%. All the NGOs who engaged with this question were neutral (neither agreed or disagreed), didn’t know or preferred not to say.
39. The key themes were:
- challenges in generating use and exposure information upstream: A significant number of respondents highlighted the difficulties registrants would face in generating upstream information, particularly through complex supply chains, and the challenges of transmitting commercially sensitive downstream information.
- cost or burden: in keeping with answers to question 11, cost and effort were highlighted as particular concerns.
- perceived disproportionality: Several respondents to this question felt that the trigger levels were disproportionate. Several respondents questioned the need for Level 2 information for non-hazardous substances above 10 tonnes (for human health).
Question 13: What is your estimate for the length of time it will take to complete the necessary tasks for the registration process under UK REACH? Particularly, considering the revised ATRm requirements for use and exposure information? Please first tick the level of use and exposure information you understand you will need to provide [if you envisage registering multiple chemicals at different levels, please try to provide separate answers for the relevant levels using the text box to specify].
40. This was an open text response question, so the types of responses varied. Some gave only qualitative answers, some gave times in hours, and some gave times in calendar scales (weeks, months, years).
41. Overall, respondents expected the process of registration, particularly collecting use and exposure information, to take a longer time than was estimated in the impact assessment. Firms who responded with a time in hours gave an average of around 100 hours. Other firms responded in terms of months, with an average of around 16 months.
42. Some of the responses, who gave times measured in years, said that the long timescales are due to demand for consultant labour, which is expected to outstrip supply. Some respondents also shared concern over the October 2026 deadline, suggesting an extension may be needed to allow adequate time for firms to collect the required data.
43. Respondents were asked to provide the tonnage levels of the chemical(s) they were expecting to register, but this did not significantly affect the time they expected registration to take.
Table 6: The table below shows averages separated into responses given in hours, and responses given in calendar scales. Where a range was given, the midpoint was used to calculate the average.
| Average calendar scale answer | Average hours answer |
|---|---|
| 16 months | 99 hours |
Question 14: Please comment on the extent to which you expect the revised use and exposure data requirements will increase costs to business. Where possible, please provide supporting quantitative evidence.
44. This was an open text response question. The overwhelming theme emerging from the responses is that revised use and exposure information would significantly increase costs.
45. The responses highlighted several key themes relating to this significant expected increase in costs, including:
- reliance on consultants: this was highlighted by nearly a third of respondents. Respondents report that they would have expected to need to hire consultants in order to meet increased information requirements. This was emphasised by some small businesses who would not have the spare capacity to gather the data in-house.
- cost of consultants: as well as mentioning reliance on consultants, responses discussed the high cost of consultants. The impact assessment used the average industry wage cost (£32 per hour) for all business hours, but responses consistently indicated that consultants charge between £100 and £150 per hour.
- communication up or down the supply chain: industry reported that from their experience they would expect difficulties gathering information from down the supply chain.
46. One limitation of the responses to this question is that some answers compared the ATRm to a no-REACH baseline, rather than to the current legal situation. For example, some mention the cost of chemical safety reports, which would need completing in any registration scenario.
Chemical safety reports (CSRs)
Question 15: To what extent do you agree that the proposed reduction in hazard assessment data will not negatively impact a registrant’s ability to undertake exposure assessment and risk characterisation in their CSA and communicate the exposure scenarios and risk control measures downstream (where Article 14 (4) of UK REACH applies – classified as dangerous in accordance with GB CLP or assessed to be a PBT or vPvB.)?
Table 7: Responses to question 15
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 31 | 13% |
| Agree | 97 | 40% |
| Neither agree nor disagree | 58 | 24% |
| Disagree | 25 | 10% |
| Strongly disagree | 7 | 3% |
| I don’t know | 14 | 6% |
| I’d prefer not to say | 9 | 4% |
47. The distribution of responses to question 15 varied between respondent groups. Between 55% and 62% of industry association, consultancy and business (small, medium and large) respondents agreed or strongly agreed with this statement. The other respondents in these groups mostly responded that they neither agreed nor disagreed, although 24% of consultants disagreed or strongly disagreed. All the NGOs who expressed an opinion disagreed or strongly disagreed with the statement in question 15.
48. Respondents were also given an opportunity to provide additional qualitative information to support their responses to this question. Respondents who agreed or strongly agreed with the proposition in Question 15 confirmed their agreement that the hazard assessment data referred to in the consultation is sufficient to undertake exposure assessment and risk characterisation as part of a chemical safety assessment (CSA), as well as to communicate exposure scenarios and risk management measures downstream.
49. NGOs and charities (together with some consultancy respondents) expressed the view that those undertaking exposure assessment and risk characterisation need to have access to the full underlying data. They argue that if the headline hazard assessment data used is based on incorrect assumptions it may lead to poorer quality, less robust CSAs and chemical safety reports (CSRs).
Question 16: To what extent do you agree with our assessment of which aspects of information should be required or should no longer be required for CSRs (see paragraphs 54 to 59 of the consultation)?
Table 8: Responses to question 16
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 32 | 13% |
| Agree | 102 | 42% |
| Neither agree nor disagree | 56 | 23% |
| Disagree | 16 | 7% |
| Strongly disagree | 4 | 2% |
| I don’t know | 19 | 8% |
| I’d prefer not to say | 12 | 5% |
50. The distribution of responses between respondent groups for question 16 generally followed the same pattern as responses for question 15. However, the total number who disagreed or disagreed strongly was lower for both consultancy (8%) and NGO respondents (44%). This is the same proportion of NGOs who responded “I’d prefer not to say”).
Summary of responses: Proposals on the ATRm regulatory powers and duties
Transitional evaluations
Question 17: To what extent do you agree that the introduction of powers for transitional evaluations is an appropriate way for regulators to request supporting information on an “as and when needed” basis?
Table 9: Responses to question 17
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 20 | 8% |
| Agree | 110 | 46% |
| Neither agree nor disagree | 55 | 23% |
| Disagree | 20 | 8% |
| Strongly disagree | 11 | 5% |
| I don’t know | 17 | 7% |
| I’d prefer not to say | 8 | 3% |
51. There was general support amongst the various response groups for transitional evaluation. Respondents who agreed or strongly agreed described the proposed mechanism as “sensible,” “pragmatic,” and “appropriate” for enabling regulators to obtain necessary supporting information.
52. The key themes for those who agreed or strongly agreed were:
- bridging information gaps: They emphasised that the proposed powers would allow registrants to provide information as needed to address potential gaps and support the policy’s implementation.
- reduction in animal testing: A common sentiment was that evaluating transitional evaluations would help minimise additional or duplicated animal testing.
The key themes for those who disagreed or strongly disagreed were:
- concerns about timelines: Respondents expressed concerns that the suggested timeline for responses to transitional evaluations might be insufficient.
- challenges with information access: Some highlighted potential difficulties in accessing the required information within the proposed framework.
- clarity of policy: Respondents wanted further clarification on how the proposed policy would operate.
Other concerns raised include:
- practicalities: While recognising the importance of a mechanism for regulators to request supporting information, some respondents sought greater understanding of its practicality and the conditions for triggering the process.
- potential drawbacks: Concerns included the possibility that the transitional evaluation power might undermine the benefits of reduced alternative requirements.
- cost burden: There was apprehension about the additional financial burden on registrants to meet regulators’ requests for information.
Publication of data
Question 18: To what extent do you agree that the information contained in the public register should be adapted in the manner set out in the policy proposal in paragraph 69 of the consultation?
Table 10: Responses to question 18
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 39 | 16% |
| Agree | 67 | 28% |
| Neither agree nor disagree | 71 | 29% |
| Disagree | 21 | 9% |
| Strongly disagree | 12 | 5% |
| I don’t know | 20 | 8% |
| I’d prefer not to say | 11 | 5% |
53. Respondents were given an opportunity to provide further information and reasons in support of the above answers. Whilst this was not a requirement almost all respondents provided further information.
54. Although the number of respondents who disagreed or strongly disagreed with the proposed approach was low, the issue most often raised in these further comments was concern about publication in the Public Register of the more detailed use and exposure information proposed in the consultation. This issue was raised by respondents in all categories of business, industry associations and consultancies but not by any NGOs, charities or government bodies.
55. The main reason for this concern was the view that uses of chemicals within supply chains and specific exposure information is confidential business information and publishing all this information would be commercially damaging. Respondents made a number of suggestions as to how this concern might be addressed which included that the Public Register only include generic or anonymised information or the same use and exposure information published by the ECHA.
Proposal on substance groups, data sharing and joint data submission
Question 19: Do you have any concerns with substance groups operating in the manner proposed in this consultation?
Table 11: Responses to question 19
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Yes | 99 | 41% |
| No | 106 | 44% |
| Don’t know | 36 | 15% |
56. Respondents were given an opportunity to provide further information and reasons in support of the above answers. Most respondents chose to leave comments here about their specific areas of concern with less than a quarter of respondents either expressing no concerns or giving no reasons to support their answer to the first part of the question. The key themes were:
- general support for the substance groups proposal: 44% of respondents received the proposal to put substance groups on a statutory footing positively. Those who voiced concerns mainly focused on details and implementation rather than the overall approach.
- encouragement of data sharing: Around a third of respondents felt that the proposals would promote data sharing, provided costs were shared fairly.
- need for clarity and guidance: A similar proportion of respondents highlighted the need for further guidance to fully understand the implications and nuances of the proposal.
- concerns about data sharing: A small number of respondents raised concerns about the sharing of use and exposure data.
- potential burden of the process: Some respondents questioned whether the proposals for substance groups and data sharing could become more burdensome under the proposed ATRm, given the reduced need to share hazard data.
Question 20: Whilst the actual operation of substance groups will be for members to work together and cooperate on independently of the Regulator (similar to substance information exchange forums (SIEFs)), are there any areas for improvement from the EU legislation on SIEFs which should be considered for UK REACH legislation?
57. A third of respondents gave no suggestions in this area, with a number stating that they lacked the necessary experience to do so.
58. The most frequent answers, each given by around 20% of respondents, were that more guidance was needed on data-sharing responsibilities and that substance groups should have greater control over the identity of their lead registrant. Other suggestions included strengthening dispute resolution processes and requests for independent authorities to be placed in charge of each substance group.
59. Respondents also called for further guidance around the roles and responsibilities of substance group members Around 10% of respondents suggested that improvements would need to be made to IT processes.
Question 21: If you would like to comment on the analysis of the ATRm policy proposals in the accompanying Impact Assessment or provide relevant data or evidence to support improving that analysis, please do so here.
60. Around two thirds of respondents did not provide any answer to this question. Those that did generally focused on the underestimation of costs in the impact assessment and issues with data access, as also highlighted in analysis of previous questions.
61. Respondents mentioned the underestimation of costs resulting from assumptions made about labour costs. (See question 14 for further discussion of this). Notably, respondents questioned the assumed labour cost of £32 per hour and contended this should be much higher due to the use of consultant labour (£100 to £150 per hour according to some respondents).
62. Another issue raised was that the impact assessment did not make any allowance for possible legal issues arising from asking firms to provide certain hazard data, without the requirement to own the study. Some responses believed they would still need to pay for the data, to avoid infringing property rights, significantly increasing costs compared to the impact assessment. Others expressed concerns that costs may result from legal action taken by the EU or ECHA against UK REACH registrants.
63. However, some respondents held contrasting views – noting that they did not expect to have to pay anything extra for hazard information, since their consortia had agreed to allow data acquired for EU REACH registration to be used at no extra cost for UK REACH. This would reduce the cost of the current model of REACH and consequently reduce the cost savings produced by the ATRm.
64. Some responses also requested more details on the calculations used in the impact assessment to be released, requesting, for example ‘a clearer breakdown of the costs’.
UK REACH improvement policy proposals
65. We are grateful to respondents for their feedback on REACH improvement policy proposals. We will be exploring these proposals holistically as part of our wider work on REACH reform. We intend to update further on this in 2026.
Proposals to improve the restrictions process
Question 22. In your view or experience, what actions must a manufacturer, importer or affected stakeholder of a chemical proposed for restriction take in order to draft a response to the first consultation?
66. The most common response to Question 22 was that the actions required to draft a response to the first consultation in the current UK REACH restrictions process would take longer than three months. This was the most common theme from industry-associated respondents (businesses and industry associations).
67. The most common actions and timings raised by respondents were:
- review of the proposal, assessment of impact on business (meaning assessing if it is necessary or appropriate or useful to submit a response to the consultation): 2 weeks to 1 month.
- collecting information from internal sources (for example production processes, supply chain, cost effects, market effects): 2 to 4 months
- involving external experts and commissioning of further studies, reports. (for example legal statements, scientific data, socio-economic assessments reports): 1 month
- alignment with other stakeholders (for example business or trade associations)
- drafting and publishing a response: 3 weeks
Question 23: In your view or experience, is there any SEA [socio-economic analysis] information you would usually provide in the second consultation that you would not or cannot provide in the first consultation? If so, why can this information not be provided in the first consultation?
68. In response to question 23, the most common theme was that the second consultation gave respondents an opportunity to spot and correct unintended conclusions reached after the first consultation. The second most common theme was that respondents felt there was not always enough time to gather information required for the first consultation and therefore, provide this information in this consultation. Both themes were reported by industry-associated respondents. Overall, NGOs provided no further opinion to this question.
69. Respondents also felt the second consultation played a fundamentally different role to the first, as they considered it to be on a final risk assessment opinion as well as the draft socio-economic analysis opinion. Respondents felt the second consultation provided an important safety net that could allow correction of significant errors or assumptions made in the above opinions.
Question 24: What information and engagement from the UK Government or the Agency would be helpful ahead of the publication of the restriction dossier that may allow for a shorter, consolidated consultation period?
70. In response to question 24, the most common theme was that a shorter consultation should be supported by greater engagement between the UK REACH regulator, the government and industry on the scope and justification for a restriction proposal. The second most common theme was that a shorter consultation would need to be supported by greater allocation of resource to a helpline, webchat, webpage, and webinar on each restriction proposal. These themes were reported by industry-associated respondents. Overall, NGOs raised that they desired greater engagement and alignment with the EU.
Question 25: If the consultations are consolidated, are there any potential consequences you expect or concerns you have? If so, are there any ways in which these concerns could be overcome?
Table 12: Responses to question 25
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Yes | 141 | 59% |
| No | 12 | 5% |
| Don’t know | 88 | 36% |
71. In response to question 25, the most common theme was that the proposed period of three months for consultation on a potential restriction would be too short to collect and provide sufficient relevant information or to consider implications from a potential restriction. This theme was raised by industry-associated respondents. The second most common theme was that the proposed consolidation of consultations would result in poorly formed conclusions which would go uncorrected, as there would not be a second consultation to provide additional information. This theme was raised by almost all respondent types.
72. 59% of respondents stated there were potential consequences of concern if the current UK REACH restrictions process consultations were consolidated. This included 46% of industry-associated respondents and 44% of NGOs. The most common theme from those that responded “Yes” to question 25 was that the period proposed under the consultation would be too short to provide the relevant information. They also stated that it would be too short to consider the implications from the conclusions and or suggested restrictions reached in the dossier.
73. 5% of respondents did not think there would be consequences of concern resulting from this consolidation. This accounted for about 7% industry-associated respondents but 0% of NGOs. The most common theme from those that responded “No” to question 25, except for those that had no further opinion, was that consolidating and condensing consultations is manageable if certain conditions were met, such as those included in response to question 24.
Question 26: If greater information is provided by the UK Government or the Agency before the consolidated consultation and informal consultations are considered before final opinions are published, to what extent do you agree with the recommended approach is a reasonable amendment to the current UK REACH restrictions process?
Table 13: Responses to question 26
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 4 | 2% |
| Agree | 31 | 13% |
| Neither agree nor disagree | 95 | 39% |
| Disagree | 103 | 43% |
| Strongly disagree | 8 | 3% |
74. In response to question 26, the most common theme was that a longer period than that proposed would be necessary to provide relevant and sufficient information required for potential restrictions. This theme was raised by NGOs and industry-associated respondents. The second most common theme was that our consultation document on UK REACH improvement proposals did not provide enough information on the proposed change. This theme was raised by industry-associated respondents.
75. 15% of respondents strongly agreed or agreed that the recommended amendment to the UK REACH restrictions process would be reasonable if the government or UK REACH regulator provided more information ahead of the consolidated consultation and considered informal consultations before publishing final opinions. This accounted for about 19% of industry-associated respondents but 0% of NGOs. The most common theme from those who strongly agreed or agreed with question 26 was simply reinforcing that they felt the approach was reasonable.
76. 46% of respondents stated they either strongly disagreed or disagreed that the approach proposed in this UK REACH consultation for improvement of the UK REACH restriction process was reasonable. This accounted for about 49% industry and 33% of NGOs. The most common theme from those that strongly disagreed or disagreed to question 26 was that a longer consultation period was necessary to provide relevant and sufficient information into potential restrictions considerations.
Proposals to improve the reporting process
Question 27: Do you agree with the proposed reporting changes outlined in paragraphs 81 to 86 of the consultation [which amend the requirements for the reports the Agency provides annually and every 5 years]?
Table 14: Responses to question 27
| Number of responses | Percentage of responses | |
|---|---|---|
| Agree with all of the proposed changes | 108 | 45% |
| Agree with some of the proposed changes | 33 | 14% |
| Do not agree with any of the proposed changes | 6 | 2% |
| No view on the proposed reporting changes | 94 | 39% |
77. In response to question 27, the most common theme was that the changes proposed removed red tape or reduced administrative burden, or both on the UK REACH regulator. This theme was raised by industry-associated respondents.
78. The second most common theme was that the proposed changes would streamline the reporting process for the UK REACH regulator. This theme was also raised by industry-associated respondents. NGOs raised that reporting should ensure and encourage the use of non-animal methods to attain UK REACH registration requirements.
79. 59% (aggregate) of respondents stated they either agree with all or agreed with some of the proposed changes. This accounted for about 63% of industry-associated respondents and 56% of NGOs. The most common theme from those that agreed with question 27, beyond a general agreement that the changes were reasonable, was that they removed red tape and reduced administrative burden on the UK REACH regulator.
80. 3% of respondents stated they disagreed that the changes proposed to the UK REACH reporting process were reasonable. This accounted for about 33% of NGOs but 1% industry-associated respondents. Apart from respondents who stated a general dissatisfaction with the proposal, the most common theme amongst those who disagreed with question 27 was that certain reports proposed for removal should be retained. In particular, some respondents felt that removing the proposed reports on annual accounts and forecast budget would reduce transparency.
Further protections against unnecessary animal testing
Question 28: To what extent do you agree that the legislative approach (paragraph 94 of the consultation) will reduce unnecessary testing on vertebrate animals?
Table 15: Responses to question 28
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 13 | 5% |
| Agree | 49 | 20% |
| Neither agree nor disagree | 82 | 34% |
| Disagree | 44 | 18% |
| Strongly disagree | 6 | 3% |
| I don’t know | 41 | 17% |
| I’d prefer not to say | 6 | 3% |
81. In response to question 28, the most common theme was that respondents believed this approach would reduce unnecessary animal testing, but that this reduction would be small. This theme was raised by industry associations, large business, consultancies as well as those that defined themselves as ‘other’. The second most common theme was that the proposed legislative approach would reduce unnecessary animal testing (with no mention of the magnitude). This theme was raised by non-governmental organisations (NGOS), small and medium sized enterprises (SMEs) and consultancies.
82. 25% of respondents stated they either strongly agreed or agreed that the proposed legislative approach would reduce unnecessary testing on vertebrate animals for UK REACH registration requirements. This included about 56% of NGOs and 23% of industry-associated respondents. The most common theme from those who strongly agreed or agreed with question 28, beyond a general agreement with this approach, was that the proposed legislative approach would reduce unnecessary animal testing.
83. 21% of respondents of respondents stated they either strongly disagreed or disagreed that the proposed legislative approach would reduce unnecessary testing on vertebrate animals for UK REACH registration requirements. This accounted for about 23% industry-associated respondents but 0% of NGOs. The most common theme from those that strongly disagreed or disagreed to question 28 was that this legislative approach could or would cause a delay to registration.
Question 29: To what extent do you agree that the non-legislative approach (paragraph 97) will reduce unnecessary testing on vertebrate animals?
Table 16: Responses to question 29
| Response | Number of responses | Percentage of responses |
|---|---|---|
| Strongly agree | 16 | 7% |
| Agree | 115 | 48% |
| Neither agree nor disagree | 46 | 19% |
| Disagree | 14 | 6% |
| Strongly disagree | 3 | 1% |
| I don’t know | 41 | 17% |
| I’d prefer not to say | 6 | 2% |
84. In response to question 29, the most common theme was the need to ensure that the guidance is clear for all users. This theme was raised by industry-associated respondents, consultancies and those that defined themselves as ‘other’. The second most common theme was that regulators should work with industry and be more transparent about what is acceptable for alternatives to animal testing to meet UK REACH registration requirements. This theme was raised by NGOs, industry-associated respondents and consultancies.
85. 55% of respondents stated they either strongly agreed or agreed that the proposed non-legislative approach would reduce unnecessary testing on vertebrate animals for UK REACH registration requirements. This accounts for about 60% of industry-associated respondents and 11% of NGOs. The most common theme from those who strongly agreed or agreed with question 28, following general agreement with this approach, was the requirement for clear and enhanced guidance.
86. 7% of respondents stated they either strongly disagreed or disagreed that the proposed non-legislative approach would reduce unnecessary testing on vertebrate animals for UK REACH registration requirements. This accounted for 22% of NGOs and about 5% industry-associated respondents. The most common theme from those that strongly disagreed or disagreed to question 29 was that a legislative approach was more likely to force action and incentivise development of alternatives, compared to non-legislative means.
Question 30: Do you think either of the above approaches would promote the development of non-animal alternatives to testing, and if so, how might it direct this development?
Table 17: Responses to question 30
| Answers | Number of responses | Percentage of responses |
|---|---|---|
| Yes | 93 | 38% |
| No | 40 | 17% |
| Don’t know | 108 | 45% |
87. In response to question 30, 38% of respondents thought that at least one of the approaches would promote development of animal testing alternatives to meet UK REACH registration requirements. This accounted for 37% of industry-associated respondents and 33% of NGOs. The most common theme overall was that the development of animal testing alternatives would require action from the UK REACH regulator to be more insistent on requiring and accepting animal testing alternatives to meet UK REACH registration requirements. This theme was raised by NGOs and industry-associated respondents. The second most common theme was that, with a non-legislative approach, clear guidance would be necessary to promote development of further animal testing alternatives. This theme was raised by medium business, industry associations and consultancies.
88. 17% of respondents did not think that at least one of the approaches would promote development of animal testing alternatives to meet UK REACH registration requirements. This accounted for 33% of NGOs and about 17% industry-associated respondents. The most common theme from those that responded “No” to question 30, was that promoting the development of animal testing alternatives would require action from the UK REACH regulator to be more insistent on requiring and accepting animal testing alternatives to meet UK REACH registration requirements.
Question 31: Are there alternative or supplementary measures (in particular for substances currently without appropriate alternatives to vertebrate testing) that could support and further ensure that unnecessary vertebrate animal testing does not occur to fulfil the requirements of UK REACH?
Table 18: Responses to question 31
| Answers | Number of responses | Percentage of responses |
|---|---|---|
| Yes | 108 | 45% |
| No | 5 | 2% |
| Don’t know | 128 | 53% |
89. In response to question 31, the most common theme was that greater data sharing, interoperability, and weight of evidence could help as a supplementary measure to support ensuring that unnecessary animal testing does not occur in fulfilling the registration requirements of UK REACH. This theme was raised by NGOs, consultancies and industry-associated respondents. The following most common theme was that there could be support and engagement between the UK REACH regulator and or the government with industry to support ensuring that unnecessary animal testing does not occur. This theme was raised by medium-sized businesses, and those that defined themselves as ‘others’.
90. 45% of respondents thought there were measures supplementary to those proposed in this section that could support ensuring that unnecessary animal testing does not occur. This included 89% of NGOs and 46% of industry-associated respondents. The most common theme from those that responded “Yes” to question 31 was that greater data sharing, read across and weight of evidence could act as supplementary measures to support the goal.
91. 2% of respondents did not think there were supplementary measures to support ensuring that unnecessary animal testing does not occur. The most common theme from those that responded “No” to question 31, was that the question was not relevant to them, or they had no opinion or further comment.
Question 32: If you would like to comment on the analysis of protecting against unnecessary animal testing in the accompanying impact assessment or provide relevant data or evidence to support improving that analysis, please do so here.
92. Most respondents (85%) chose not to give an answer for this question. Those that did respond expressed a wish for the UK to take an active role in developing suitable non-animal methods (NAMs) and next generation risk assessments (NGRAs).
93. Three respondents pointed out that some animal testing would still be required under some circumstances (for example chemicals involved in pharmacology). This is acknowledged in the impact assessment. Some concern was reported over how this will impact international trade, if requirements diverge.
UK REACH and trade
Question 33: Do you anticipate any impact on trade from the ATRm policy proposals, and if so, what do you think this impact will be?
94. A complication in interpreting these results is that many respondents treated pre-EU Exit or no REACH as the baseline, rather than treating the current model of UK REACH, as in law, as baseline. These responses were also given under the expectations of new use and exposure requirements, which would have increased consultancy costs.
95. In that context, respondents generally anticipated a negative impact on trade. In particular, respondents expected products to be withdrawn from the market. They attributed these concerns to high fees for small businesses, high costs of maintaining two registrations, possible disruption to supply chains and very high costs of registering new and novel substances.
96. Most of those who expect a negative impact on trade expressed concerns about their supply chain and product portfolio – anticipating difficulties in sourcing materials due to firms exiting the GB market. They also noted that potential administrative delays could cause similar problems on a temporary basis.
97. Another theme raised was on the impact on innovation and competition, in particular for companies registering new and novel substances which would have to provide more hazard information compared to transitional registrants.
98. Some responses to this question highlighted the issue of the size of the GB market compared to the EU market. They emphasised that the costs (administrative costs of registration as well as fees) are high, relative to the value of access to the GB market in comparison to access to the EU market.
Question 34: Do you anticipate any impact on trade from the REACH Improvement policy proposals, and if so, what do you think this impact will be?
99. Close to half of all respondents did not respond to this question or answered, ‘not applicable’. Of those that did answer, the majority noted that they expected negative impacts from the REACH Improvement proposals, reasons included issues caused by a reduced restriction timetable, withdrawal of products from the market, and rising costs.
100. Some respondents expressed concerns that the reduced restriction timeline could mean firms would not have time to prepare or provide adequate information resulting in poorly informed decisions with negative impacts. Some respondents felt that removing the second consultation could result in reduced stakeholder input and poorly informed decision making.
101. There are also concerns that divergence could lead to reduced competitiveness and reduced attractiveness of the GB market for potential entrants.
Question 35: If you would like to comment on the analysis of UK REACH and Trade in the accompanying Impact Assessment or provide relevant data or evidence to support improving that analysis, please do so here.
102. Most respondent chose not to answer this question. Of those that did, the key issues raised were an underestimation of costs by the impact assessment, concerns about existing products being withdrawn and a lack of innovation to create new products or uses. A few also highlighted concerns about divergence.
103. Less than a third of respondents answered this question, and most of the issues raised in this question emerged as themes in earlier questions as well.
The key themes from this question were:
- competitiveness and innovation – particularly relating to the full data requirements for novel substances, and the burden on SMEs.
- underestimated costs – responses indicated concerns that the labour costs of consultants had not been accounted. They also suggested that costs for SMEs would still be substantial, even with the cost saving measures.
- increased use and exposure data – in particular, the difficulty of getting use and exposure data from further down the supply chain,
- expertise of current downstream users – it was highlighted that current downstream users may not have enough regulatory knowledge to complete registrations.
- market withdrawal – there are worries that the proposals could cause some products to be withdrawn from the market due to the costs of registration.
- divergence – a few responses highlighted that diverging standards could result in barriers to trade and suggested an alternative option such as the model used in Switzerland.