UK Chemicals Regulation & Policy 2024 Conference Review

Last week (23rd May), Enviresearch’s Scott Watson attended the UK Chemicals Regulation and Policy 2024 Conference in London, hosted by Chemical Watch (Enehesa). The event took place in the week following Defra launching the much-anticipated consultation on UK REACH and less than 24 hours after the surprise announcement by UK Prime Minister, Rishi Sunak, calling a UK general election to be held on 4th July.

The conference gathered policymakers, industry stakeholders, NGOs, and regulatory experts to discuss recent developments and the current state-of-play for key areas of UK chemicals regulation.

A whistlestop tour of the highlights and take-home messages from the event are provided below:

 

// UK Chemicals Strategy //

◾ The UK chemicals strategy, initially promised in the 25-year Environment Plan back in 2018, remains unpublished with no clear timeline for its release.

◾ The potential impact of the upcoming UK general election on the chemicals strategy is uncertain.

 

 // ATRm for UK REACH //

◾ The most granular detail yet on the Alternative Transitional Registration model (ATRm) for UK REACH was published as part of the recently-launched Defra consultation on UK REACH. The proposals aim to reduce the cost to industry in moving from EU REACH to UK REACH while maintaining high levels of protection to human health and the environment.

◾ While several stakeholders cautiously welcome Defra’s efforts to address well-documented concerns around the transition to UK REACH, practical challenges clearly remain. Concerns were voiced around the challenges of providing more detailed use and exposure information as proposed under ATRm. Additionally, there were unanswered questions about intellectual property concerns regarding proposals for registrants to use hazard classifications, DNEL, and PNEC values without access to the underlying studies.

◾ With legislation for ATRm not expected to be in place until 2025, the unknown impact of the upcoming general election on timelines, and the need still for guidance development, concerns were also raised as to whether industry will have sufficient time to address the ATRm requirements by the first UK REACH registration deadline in October 2026.

 

// Classification and Labelling – EU and GB Divergence //

◾ Divergence between the EU and GB CLP regulations is already happening in policy and decision making as illustrated in the below points.

◾ New hazard classifications for Endocrine Disruption, PBT, vPvB, PMT, and vPvM implemented under the EU CLP are not currently planned for adoption under the GB CLP framework. GB CLP aligns with the UN GHS for classification and labelling when will only consider adopting the new classifications when they are included under the UN GHS.

◾ There are examples of divergence between EU harmonised classification and labelling (CLH) and GB Mandatory Classification and Labelling (MCL). This divergence includes instances where GB has adopted more and less severe hazard classifications for substances compared to the EU classification.

 

 // Scientific Developments in Chemicals Policy //

◾ Examples of New Approach Methods (NAMs) were presented, highlighting their potential to support future chemical risk assessments.

◾ Calls for a more flexible approach, or even a paradigm shift, in chemical regulation and risk assessment to help facilitate more widespread adoption of NAMs.

 

The day’s discussions highlighted the many ongoing developments in the chemicals regulatory landscape for UK and the many uncertainties that continue to remain. As the industry awaits further clarity, particularly in light of the upcoming general election, Enviresearch will continue to provide essential support to businesses navigating these complex regulatory environments.

You can contact our Commercial Director, Scott Watson (scott.watson@enviresearch.com) if you would like to discuss solutions for compliance of your chemicals under REACH, CLP or the BPR across the UK and EU.