Overview
During April 2022, details have been emerging on the progress of the delivery of the UK’s independent chemicals regimes, and the long-awaiting UK Chemicals Strategy. Two partners in Steptoe’s Chemicals and Life Sciences group, Simon Tilling and Darren Abrahams, have been speaking at key industry conferences alongside UK government officials and regulators, in which the focus of the discussions was the future direction of travel for the UK. Both the Chemical Industries Association (CIA) annual conference on chemicals regulation and the Westminster Environment, Energy and Transport (WEET) Forum conference on the chemicals industry looked in detail at the future of UK chemicals regulation, and how the regimes can be shaped for the independent market of Great Britain.
Here are some of the key messages:
Engagement on the UK Chemicals Strategy Will Start This Month
As part of its long-standing commitment to a new UK chemicals strategy under goal 9 (''managing exposure to chemicals'') of the statutory 25 Year Environment Plan, Minister Jo Churchill will chair a roundtable to commence a period of engagement with stakeholders, which will continue through the Summer. These sessions provide a real opportunity to influence the future direction of the UK chemicals strategy and we encourage clients to get involved.
There is, however, no firm date on when the strategy, first promised in 2018, will finally be published.
Regulatory Changes Will be Part of Delivering the Strategy
Amendments to the regulatory regime will be one of a range of tools to deliver the strategy, with the UK seeking to find efficiencies and bring greater coherence to the full spectrum of chemicals management regulations. James Dancy, head of UK REACH service and policy at Defra, told the WEET Forum that the UK Government was open to suggestions on how 'brave' it needs to be to deliver a strategy the works for the UK while also ensuring the same levels of protection for the environment and human health.
Defra Wants More Time for its Review into the Current UK REACH Transition Process
In parallel to discussions on the strategy, the chemicals industry, and the wider economy dependent on chemicals, all need to grapple with the transition arrangements to move from EU REACH to UK REACH. We covered the review into REACH alternative registration approach (nicknamed 'RARA') in our January briefing. During the CIA conference, Defra official David Look told the group that the first deadline for complete dossiers, which is the law currently dictates will be October 2023, is likely to be pushed back by three years to October 2026, but this would be subject to consultation and would need parliamentary approval.
The Steptoe Chemical and Life Science team has significant experience in helping clients both to navigate regulatory changes and to engage in the legislative and policy process. Our assessment is that the UK government is genuinely open to new ideas and new approaches, and now is the right time to engage in the review.