In May 2024, Defra, the policy lead for UK REACH, released a public consultation on the Alternative Transitional Registration model (ATRm), a new registration model proposed to deal with concerns raised by industry on the current model. The current model is a replica of EU REACH, which industry believes is not appropriate for a Great Britain (GB) specific market predominately due to the high data costs. As a result, Defra proposed the ATRm in reaction to these concerns, aiming to reduce the need for costly data access, while increasing the use and exposure information required in registration dossiers. The consultation sought views from industry on 4 key areas, details of which can be found here: Unlocking UK REACH: Understanding the ATRm Public Consultation and its Future | H2 Compliance
Since the consultation closed in 2024, Defra have been reviewing the responses and published these in March 2026. In the response, Defra have decided to move forward with most aspects of the ATRm as originally proposed, with registrants submitting “hazard conclusions” rather than full hazard data. However, the requirements for additional use and exposure information have been removed due to the regulatory burden it would create for GB-based businesses. See below for a summary of the key technical points in the response:
- Hazard data: Registrants will submit “hazard conclusions” rather than the full hazard data that is required under EU REACH, significantly reducing the data access costs for registrants.Though, to counterbalance this change, transitional evaluations will be introduced to ensure the regulator has power to request additional hazard data if they need it to complete their regulatory activities.
- Use and exposure data: The consultation proposed enhanced use and exposure data requirements compared to the current requirements, but this proposal has been removed due to the regulatory burden it would create for GB-based businesses. As such, there will be no change in the data requirements compared to EU REACH.
- Chemical Safety Assessment (CSA) and Chemical Safety Report (CSR): While the hazard requirements are reduced in the ATRm, the duty to prepare a CSA and CSR remains unchanged and the registrant should still have sufficient information to complete this where required.
- Joint registrations and data sharing: Joint registration and data sharing mechanisms will still apply under UK REACH, and registrants should form “Substance Groups” which are equivalent “Substance Information Exchange Fora (SIEFs)” under EU REACH. Within the substance groups, the hazard conclusion data should be shared, including any sharing of costs where applicable.
The full response to the public consultation can be found here: Summary of responses and government response – GOV.UK, and please note this only applies to substances that were registered under EU REACH before the 1 January 2021. Any substances registered after this data do not qualify as “transitional substances” so the full information requirements should be provided for registration, just as they would under EU REACH.
For more information and support on the ATRm and UK REACH, please contact H2 Compliance.
Published April 22nd, 2026
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