October 14, 2024 by Sylwia Kosmala-Grzechnik


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I recently had the opportunity to attend the “Chemical Reactions: UK Chemicals Conference“, organized by Chemicals Industries Association (CIA), Steptoe and Ramboll in Manchester. The event provided insights into the evolving UK chemicals regulatory landscape, with key discussions around several critical topics, including the UK’s Alternative Transitional Registration model (ATRm), UK REACH, GB Classification, Labelling and Packaging (GB CLP), and GB Biocidal Products Regulation (GB BPR) regulations.

Key Takeaways on UK REACH and ATRm

One of the main points discussed during the conference was the UK REACH ATRm. The proposed reduction in hazard data requirements was met with approval from industry participants, as it aims to reduce cost concerns. Nevertheless, there is significant uncertainty regarding the legal implications of the proposal, particularly how companies will handle data compensation. Additionally, the enhanced use and exposure information required is more extensive than demanded by other REACH-like regulations, raising concerns about the feasibility of obtaining such information due to the complexities of supply chains and confidentiality issues. This complexity could result in resource and cost implications for many companies. Due to the high level of uncertainty, the need for extending registration deadlines was highlighted to allow sufficient time for the model to be fully developed and for industries to prepare for the upcoming registration deadlines.

Navigating the Existing Regulatory Scene

Another topic of discussion was the existing architecture of UK chemicals regulation. Presenters noted that the UK is still undergoing a transitional phase, presenting a unique opportunity for stakeholders to influence the future direction of UK regulation. Therefore, it is very important for companies to engage in consultations—whether independently or through trade associations.

Despite the uncertainty surrounding data requirements and the registration process, companies are encouraged to prepare for upcoming registration deadlines. This preparation includes keeping accurate records of the tonnages of substances manufactured or imported into the UK, conducting analytical testing, collecting information on the uses of these substances, and submitting inquiry dossiers to participate in discussions concerning relevant ‘substance groups.’

Divergence from EU Regulations

The conference also addressed the topic of the UK’s divergence from EU regulations. A representative from the Health and Safety Executive (HSE) shared plans to separate UK chemicals supply regulations—including GB BPR and GB CLP—from EU regulations. The key aim of this new regulatory framework is to achieve greater autonomy in decision-making and increase flexibility in assessing which chemicals to evaluate and when to conduct these assessments, rather than adhering to the EU’s schedule.

The HSE plans to conduct informal stakeholder engagements this autumn, followed by a formal public consultation on the proposed regulatory framework in early 2025, with implementation planned for 2026.

Conclusion

In summary, while the UK largely mirrors EU regulatory activities, so far the divergence primarily occurs through delays rather than content differences. It was highlighted that companies operating in the UK market must keep a close eye on EU developments, as similar regulations are likely to follow in the UK. Once an EU decision or deadline is announced, UK companies should prepare without delay, as short deadlines could emerge in the UK context.

The conference was a great opportunity to discuss and share views on these important issues between key stakeholders in the UK chemicals sector.

wca continue to monitor closely the developments of the UK REACH and wca experts can provide advice on your obligations under UK REACH, support with developing a registration strategy, or act as your UK Only Representative, if you need one. If you need any help or have any questions regarding your obligations under UK REACH, please do not hesitate to contact us and we can discuss with you how to proceed.