UK REACH ATRm second consultation: What companies should do now

The UK Government has published a technical consultation on the proposed Alternative Transitional Registration model (ATRm) for UK REACH. The consultation seeks feedback on draft legal provisions intended to implement the policy direction confirmed earlier this year and closes on November 10, 2026.

This is the second major consultation on ATRm. Rather than introducing a fundamentally new approach, it provides draft legal provisions intended to implement the policy direction set out in the Governments response to the 2024 consultation.

Sagentia Regulatory’s key takeaways on the UK REACH ATRm technical consultation

1. Registration obligations are not disappearing

The consultation proposes a more proportionate registration framework, but businesses should not interpret this as removing the need to register. For substances covered by a DUIN and already registered under EU REACH, a registration dossier will still need to be submitted to the UK authorities by the relevant deadline.

Similarly, for substances that already have a UK REACH registration (including grandfathered substances) and are also registered under EU REACH, any information required under the new reduced data requirements that is not already included in the original registration, such as basic Chemical Safety Report (CSR) information, must be provided through a dossier update by the applicable transitional deadline.

In both situations, companies will need to participate in the relevant joint submission and ensure they have access to the information necessary to meet their regulatory obligations.

2. This is evolution, not a change of direction

Companies that followed the 2024 consultation and the Government’s March 2026 response will find relatively few surprises in the latest proposals. The consultation largely translates the previously announced policy approach into draft legal provisions, retaining the hazard baseline concept and the principle of reduced upfront registration requirements while clarifying how Chemical Safety Assessments, Chemical Safety Reports, intermediates and substance groups will be treated in practice.

For organisations that have already invested time assessing the implications of ATRm, the primary value of this consultation is understanding how those policy commitments are expected to operate legally and identifying any practical issues before the legislation is finalised.

3. The direction of travel is becoming clearer

For organisations that have delayed planning while awaiting greater certainty on UK REACH, the framework is now taking clearer shape. The Government continues to signal an intention to avoid unnecessary duplication of EU REACH registration data while maintaining regulatory oversight.

4. Data access and consortium arrangements will still matter

Although the volume of information required may be reduced, questions around Letters of Access, Lead Registrants, joint submissions and access to key information remain. Companies should continue to engage with suppliers, consortia and other registrants where relevant.

5. This is a good time to revisit portfolio priorities

The potential reduction in registration costs may improve the business case for maintaining some substances on the GB market. Equally, companies should continue to evaluate which registrations, products and markets justify future investment.

What Sagentia Regulatory is watching

While the overall direction of travel is becoming clearer, we believe several practical questions remain important for industry:

• How registrants will obtain and rely on key hazard assessment outputs such as DNELs, DMELs and PNECs where they do not own the underlying EU REACH data
• How data access, Lead Registrant and consortium arrangements will evolve under the new framework
• How HSE will apply its proposed powers to request additional information beyond the initial ATRm submission
• How the system will operate over time should UK and EU regulatory requirements diverge further

These questions do not alter the positive direction of the proposals, but they may ultimately influence the actual costs, data access requirements and administrative burden experienced by industry.

What Sagentia Regulatory recommends doing now

Over the coming months, we suggest companies:

• Review substances covered by existing DUINs and confirm their registration deadlines
• Identify registrations where data access arrangements are still unclear
• Engage with industry groups or potential Lead Registrants where appropriate
• Assess whether the proposed ATRm changes alter portfolio or market access decisions
• Consider responding to the consultation if there are concerns regarding practicality, implementation or unintended consequences

While important details remain subject to consultation and final legislation, the proposals provide the clearest indication yet of how transitional registrations are likely to operate in practice.