The Alliance of Chemical Associations (ACA), which represents 15 trade bodies (including IFRA UK) and around 1,400 companies across the chemicals supply chain, has warned that the United Kingdom’s revised approach to chemical regulation under U.K. REACH still risks imposing significant costs and barriers to trade, despite government efforts to streamline requirements.
(In a separate aligned statement on LinkedIn, IFRA UK noted, "Alignment on REACH bans, authorizations and restrictions alone won’t save UK-EU chemicals trade without full recognition of EU registrations.")
In a response to the government’s consultation on the Alternative Transitional Registration model (ATRm), the group said that while some proposed burdens have been reduced—particularly around additional use and exposure requirements—core obligations remain that will continue to duplicate existing EU systems and drive up costs for businesses operating in Great Britain.
The ACA said the government’s continued reliance on a “no data, no market” principle fails to recognize that much of the required hazard and safety data already exists under EU REACH and is publicly available via the European Chemicals Agency database. It argues that requiring companies to resubmit similar datasets for substances already registered in the EU creates unnecessary duplication without improving protections for human health or the environment.
A central concern is the estimated cost of more than £500 million associated with generating and submitting U.K.-specific data packages for substances already registered under EU REACH. The ACA argues that this burden will ultimately be passed through supply chains, disproportionately affecting SMEs across manufacturing sectors including plastics, paints, cosmetics and chemical distribution.
The group also criticized the continued requirement for parallel U.K. registration even where substances have already been fully assessed under EU REACH. It said this undermines regulatory alignment goals and creates friction for companies attempting to operate across both markets, particularly as the UK government has indicated it will align with EU decisions on bans, authorizations and restrictions.
According to the ACA, the divergence is especially challenging for importers and downstream users in Great Britain, many of whom are SMEs that will be required to take on first-time registration responsibilities for imported chemical mixtures. The organization warned that this increases administrative complexity and regulatory risk without delivering additional safety benefits.
While the government has delayed or removed some elements of the original ATRm proposal, including certain expanded exposure data requirements, it has retained obligations for hazard information, chemical safety assessments and joint substance submissions. Revised timelines also compress implementation periods into 12-month windows rather than the previously expected 24 months, further increasing operational pressure on industry.
The ACA also highlighted uncertainty around whether publicly available EU data can be used in U.K. registrations without consent from data owners. It said the lack of clear guidance on this issue risks undermining any intended cost savings from the reform.
More broadly, the group warned that duplicating EU REACH registration requirements for substances introduced after Brexit continues to weaken the United Kingdom’s competitiveness as a location for chemical innovation, investment and scale-up. It said this is particularly problematic for specialty and novel chemicals, where additional testing requirements—including potential animal testing—could delay market entry.
The ACA concluded that a more effective approach would be for the United Kingdom to formally recognize EU REACH registrations while maintaining visibility through a simplified notification system. It argued this would preserve regulatory alignment, reduce administrative duplication and support growth objectives while maintaining existing health and environmental protections.
The organization said the current trajectory risks adding to already elevated business costs in the UK, including energy, labor and raw materials, and represents a missed opportunity to reduce regulatory friction following Brexit.
