Adhesives and sealants are essential products supporting almost every sector of the economy, from construction and automotive manufacturing to packaging, renewable energy, healthcare and infrastructure. BASA members are overwhelmingly downstream users of chemicals, not producers of chemical substances. They are already highly knowledgeable about the hazards and risks of the chemicals they use, with robust systems to ensure safe handling, storage and use throughout the supply chain.

The proposed ATRm would create a duplicate UK chemicals database despite the Government signalling its intention to align closely with EU REACH restrictions, authorisations and bans. BASA questions what additional protection this duplication would deliver for human health or the environment when the same substances have already been assessed and registered under EU REACH.

What is clear is the additional cost. BASA members already face mounting regulatory and commercial pressures, including Extended Producer Responsibility (EPR), ongoing Northern Ireland trading complexities, and the wider administrative and financial burdens created by Brexit. The ATRm risks adding yet another layer of cost without corresponding benefits.

A particular concern is that many BASA members have never previously been required to undertake REACH registrations because they operated as downstream users. Registration requires specialised regulatory expertise many companies do not possess. Businesses may be forced into substance groups involving hundreds, or potentially thousands, of registrants, creating administrative complexity, governance challenges and legal risk. Substance identification alone can be technically demanding and costly, often requiring scarce specialist consultants.

Furthermore, the UK chemicals market is predominantly a user market rather than a producer market. The registration model appears to underestimate the practical challenges for importers and downstream users in obtaining data, understanding obligations and navigating complex regulatory processes previously managed elsewhere in the supply chain.

BASA supports a more proportionate approach, similar to that adopted by Switzerland, which recognises EU REACH registrations while maintaining appropriate regulatory oversight. Such an approach would protect human health and the environment, preserve access to essential chemicals, support innovation and competitiveness, and avoid imposing unnecessary costs on UK industry.

The UK needs a chemicals regulatory framework that is effective, proportionate and supports growth. The proposed ATRm, in its current form, risks achieving the opposite.