The government’s position in respect of the ATRm does not adequately acknowledge that it is possible to operate successfully under a default policy of regulatory alignment with EU chemicals legislation, known as “autonomous adaptation.” Under this approach, a country can independently choose to keep their chemicals frameworks aligned with EU REACH. Crucially, this policy is unilateral, not contingent on broader trade agreements, and it preserves the sovereign ability to diverge where genuinely necessary. In practice, divergences are rare, narrow in scope, and are often introduced to offer greater protection for public health or the environment.
A key benefit of autonomous adaptation is that it does not require companies to resubmit or recreate detailed chemical safety data for substances that are already registered under EU REACH. Instead, the system recognises that the data already exists, has undergone robust evaluation, and remains fully valid for regulatory purposes. From an industry perspective, this approach avoids duplication, unnecessary costs, and wasteful administrative burdens, with no loss of protections for workers, consumers, or the environment.
Given these advantages, it is difficult to understand why the UK cannot adopt this pragmatic policy of alignment, one that maintains high standards while avoiding disproportionate costs for manufacturers and formulators.
Moreover, the government’s proposed ATRm does not address the major structural problem facing UK downstream users: many would be forced into the role of first-time registrants, despite lacking the data, resources, and market leverage to obtain the information required.
These companies, often SMEs, would bear significant costs simply to recreate data that already exists in the EU system. This creates no additional safety benefit and risks putting UK formulators at a competitive disadvantage.
The ATRm, as currently designed, fails to alleviate these pressures, meaning downstream users still face an expensive, duplicated registration burden that offers no tangible gain for human health or environmental protection.
BASA has co-signed a letter from the Alliance of Chemical Associations sent to DEFRA on 22 April outlining these concerns and. The full letter can be read here
BASA represents the £1.7 billion UK and Irish adhesives and sealants sector, promoting innovation, compliance, and sustainability while supporting business growth and industry standards. Visit http://www.basa.uk.com
