May 31, 2024 by Lucy Kennelly

Last week, Lucy attended a conference on UK chemical regulations and policy, hosted by Chemical Watch. The conference included presentations by regulators Defra and HSE, as well as industry and NGO representatives.

Since leaving the European Union, much of the UK’s chemicals legislation has been directly transposed from the EU legislation, but the UK is planning to deviate in a number of ways. The proposals for UK REACH, and overall UK chemical policy, seem to be focused on chemical risk, rather than hazard alone, with an emphasis on gathering high quality UK-specific use and exposure information. For classification and labelling, UK regulators indicated that the new EU classification, labelling and packaging (CLP) hazard classes for endocrine disruption (ED), persistence, bioaccumulation and toxicity (PBT/vPvB) and persistence, mobility and toxicity (PMT/vPvM) will not be integrated into UK regulations until they are accepted at an international level under the globally harmonised system (GHS). On the subject of PFAS, the UK plans to use targeted restrictions and authorisations for PFAS substances or groups, rather than following the EU with a universal restriction.

The UK is also aiming to reduce the need for animal testing, and is expected to be more open to the use of New Approach Methodologies or Non-Animal Methods (NAMs) and Next Generation Risk Assessment (NGRA) using these methods.

A widely discussed topic was the consultation on the UK’s Alternative Transition Registration model (ATRm), which opened earlier this month (see our blog post on the ATRm consultation here). Some of the main issues and questions surrounding the ATRm raised by the conference panellists and delegates include:

• Potential data sharing issues and legal concerns surrounding the publication by UK regulators of PNEC and DNEL values that have been sourced from ECHA portal summary information on REACH-registered substances, without UK companies purchasing the underlying hazard data.
• Timing concerns, as the first registration deadline is 27 October 2026 and legislation for the ATRm is planned for 2025, which creates concerns that there may not be sufficient time to gather use and exposure information.
• It is currently unknown how the UK will select which substance dossiers to check for compliance, and there are concerns about a lack of resources for the regulators to achieve their target of checking 20% of submissions.

The UK’s chemical regulation policy is also likely to be impacted by the outcome of the general election that was announced last week, and which will take place on 4th July 2024. The publication of the UK Chemical’s Strategy itself is expected to be delayed (again) until it can be reviewed by the incoming government.

wca is planning to respond to the ATRm consultation, and we will continue to closely monitor developments in the UK’s chemical regulation sphere.

If you have any questions on UK REACH, the ATRm proposal, or any other aspects of UK chemical regulations and policy, please contact us.