UK REACH: Challenges and opportunities for improvement

Chemical pollution in the UK is at critical levels. Meanwhile chemical regulation in the UK continues to fall behind. We risk becoming a chemical dumping ground for toxic chemicals banned elsewhere if we don’t act urgently.

Here, we will explore the challenges and opportunities for improvement in the current system of UK REACH.

REACH Recap 

Chemical regulation in the UK is currently managed under UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). This regulatory framework was implemented in the UK following its exit from the European Union. It is designed to manage and control the use of chemicals, ensuring their safety for human health and the environment, and was based on EU REACH.

The UK Health and Safety Executive (HSE) is responsible for administering and enforcing UK REACH, which requires companies that manufacture or import chemicals into the UK to register them, provide safety data, and comply with specific restrictions and authorizations for certain hazardous substances. It covers England, Scotland, and Wales, whereas Northern Ireland remains under EU REACH.

So, what’s the issue?

Unfortunately, this new system has proved challenging – with the implementation of UK REACH facing multiple hurdles that have led to repeated delays to both restriction and registration of chemicals. Access to data, resourcing capabilities and delays to the overarching UK Chemical Strategy mean that the UK, at present, is unable to efficiently register, assess or regulate chemicals, with few restrictions progressing since we left the EU.

Let’s take a closer look at these hurdles

Lack of capacity

Capacity and resourcing are crucial in the implementation of UK REACH. Chemical production continues to grow globally1, and so it is essential that the UK has the capacity and resources required to register, assess, and restrict chemicals effectively. Enforcement programmes also rely on resources, and without, enforcement regulation is unworkable.

Lack of capacity has already led to the UK falling significantly behind the EU. Since Brexit, the EU have declared 26 new substances on their ‘substances of very high concern list’2, whereas the UK have declared zero3.

A similar story unfolds with restrictions, with the EU adopting eight restrictions and considering a further 164. Meanwhile, the UK has not banned any substances5 and is currently only considering two restrictions on tattoo ink substances and lead ammunition.

Divergence from EU REACH

As we trail further and further behind, we lose out on the most up to date research on chemical hazards, weakening both our health and environmental protection standards. We also increase the regulatory burden on industries trading in both the UK and EU, who are already experiencing additional administration and compliance in dealing with two separate regulatory frameworks (UK REACH and EU REACH).

And should this trend continue, the UK risks becoming a chemical dumping ground, where products unable to meet the EU’s higher standards of chemical regulation instead make their way into UK homes and our environment.

An Alternative Transitional Registration Model (ATRm) has been proposed to assist businesses transitioning from EU to UK REACH by reducing their costs. This prioritisation of cost comes with consequences however, as this week it was announced that the ATRm model will have a reduced requirement for chemical hazard data when registering a substance in the UK, ultimately providing less protection against toxic chemicals6.

Lack of data

During the transition, the UK lost access to chemicals data held within the European Chemical Agency (ECHA) database. This is because the data is owned by companies who may not be willing to share data with companies in the UK. As a result,  UK REACH is operating without the comprehensive safety data needed for identifying, controlling, and enforcing protections from known chemical risks.

As explained in our video – this lack of data leads to an ongoing loop of inaction. We are also lacking data on chemicals of concern in products, the environment and even in people. Prior to Brexit, chemicals of concern were monitored and identified by governments and agencies across 27 member states, with restriction proposals coming from health agencies, consumer bodies and environmental regulators. We have yet to develop and resource robust UK systems to do so.

Insufficient assessment and regulation

All the above, alongside the absence of a UK Chemical Strategy and environmental targets, create a dangerous scenario for chemical pollution within the UK. Currently, UK REACH is not sufficiently robust to protect our health and environment from harmful chemicals, and current plans to develop UK REACH further do not address these shortcomings.

Phasing out harmful chemicals is also a delayed process, with accurate risk data sometimes taking decades to obtain. A precautionary approach is therefore essential to ensure effective protection for both people and wildlife.

There are also issues with regulating substances one by one, whereby industry often substitutes one banned chemical with another unregulated one from the same chemical group. The substituted substance may offer similar properties and functionalities but can also be just as harmful as the chemical is has replaced – a process known as “regrettable substitution”. The grouping of chemicals of concern would help rationalise regulation and reduce the risk of regrettable substitutions, but this has not yet been widely adopted under UK REACH plans.

More action to prevent chemical pollution needed

Chemical pollution is already impacting UK public and environmental health, and it is becoming increasingly clear that UK REACH, in its current form, is not effective. More ambitious action is needed to address the challenges of chemical pollution. The UK government must reform and adequately resource UK REACH in a meaningful timeframe, and align with the EU until UK regulation is fit for purpose. This should be supported by clear and robust commitments within the UK Chemicals Strategy to protect human health and the environment from harmful substances.

Our video explains these hurdles as they appear during the UK REACH process and illustrates how they can interact with each other. Watch our video and visit our chemical pollution webpage for more information.



1 BASF. (2022). Outlook for the Chemical  Industry, BASF Report 2022. Available at:,2022%3A%20%2B2.2%25).

2 European Chemicals Agency (ECHA). (2023). Candidate List of substances of very high concern for Authorisation. Available from:

3 Health and Safety Executive (HSE). (2023). UK REACH Candidate List of substances of very high concern (SVHCs) for authorisation. Available from:

4European Chemicals Agency (ECHA). (2023). Substances restricted under REACH. Available from:

5 Health and Safety Executive (HSE). (2023). Restrictions under REACH. Available from:

Department for Environment, Food  and Rural Affairs (DEFRA). (2023). UK REACH alternative transitional registration model (ATRm) Policy Paper. Available from: