CBA: Long-awaited progress on UK REACH, but key concerns remain
7 April 2026
7 April 2026
After years of delay and growing frustration across industry, the Chemical Business Association (CBA) acknowledges long-awaited progress on the UK REACH Alternative Transitional Registration model (ATRm) following the Department for Environment, Food and Rural Affairs’ (DEFRA) response to the 2024 consultation.
The announcement represents an important step towards a more workable and proportionate UK REACH regime. However, the CBA cautions that significant concerns and challenges remain as the model moves towards implementation.
Confirmation that transitional registrations will require less information than full registrations, alongside the decision not to introduce additional use and exposure requirements, reflects key principles the CBA has consistently advocated for on behalf of the UK chemical supply chain since DEFRA first announced the need “to explore a new model for transitional registrations” in December 2021.
The CBA also notes DEFRA’s intention to use EU regulatory decisions as the starting point for UK REACH. While this has the potential to reduce duplication, ease regulatory burden, and support UK competitiveness, it raises fundamental questions over the need for Government to independently hold data, given the risk of unnecessary cost and overlap.
Tim Doggett, CEO of the CBA, commented: “As I have said consistently since the need for an alternative model was first announced by DEFRA in December 2021, progress has been painfully and woefully slow, so it is positive to finally see some movement.
“However, serious concerns remain. Prior to Brexit, industry had already paid over half a billion pounds to access EU REACH. While the costs now envisaged may be lower than those set out in DEFRA’s original UK REACH Impact Assessment – which were estimated at between £1.3 and £3.5 billion – it will still represent a significant burden, likely running into hundreds of millions at a time when businesses are already under intense economic pressures.”
He added: “There is also still a lack of clarity on how this will work in practice, with real questions as to whether the proposed registration deadlines of 2029, 2030 and 2031 – already pushed back several times – are achievable. Maintaining momentum and continued engagement with industry will be critical to ensuring the system is both effective and deliverable.
“If this becomes nothing more than a sticking plaster over the original UK REACH model, it will not address the underlying issues. The reality is that Brexit did not fully consider the practical implications for business, and UK REACH remains a clear example of that.”
The CBA reiterates its long-standing position that UK REACH must protect human health and the environment while remaining proportionate, cost-effective, and supportive of trade, innovation, and growth. It remains determined to see a satisfactory outcome and will continue to play a leading role in securing a pragmatic solution – working closely with Government, regulators, and industry stakeholders, providing specialist input to working groups, and delivering support to its members to ensure the successful implementation of ATRm and a competitive, sustainable future for the UK chemical supply chain.