As the UK government moves forward with its revised UK REACH Alternative Transitional Registration model (ATRm), the fragrance industry is warning that the framework still risks imposing significant costs and regulatory duplication on businesses already operating under robust safety standards. In this commentary, Caroline Raine, technical director of IFRA UK, outlines why the current approach could hinder innovation, burden SMEs and weaken the United Kingdom’s competitiveness in fragrance and ingredient development. -Editor
IFRA UK, the trade association representing the fragrance industry in Great Britain, responds to the Government's long-awaited consultation response on the UK REACH Alternative Transitional Registration model (ATRm). While we acknowledge the Government's decision not to introduce the additional use and exposure requirements originally proposed, the response falls significantly short of what is needed to support a sector that contributes billions to the UK economy, underpins iconic British brands, and depends on complex, multi-ingredient formulations involving hundreds of carefully assessed substances.
The fragrance industry's relationship with REACH is uniquely complex. Fragrances are not single substances - they are sophisticated compositions of dozens or even hundreds of ingredients, many of which are already subject to rigorous safety assessment under both EU REACH and the separate IFRA Code of Practice. Our industry has long demonstrated its commitment to the highest standards of human health and environmental protection. The imposition of a duplicative UK registration system on top of this existing framework is not a proportionate regulatory response - it is an unnecessary and costly administrative burden with no meaningful safety benefit.
We welcome, but note the limitations of, the reduced hazard information requirements under ATRm. The decision to maintain use and exposure information at current legislative levels, rather than expanding them, is a positive step. However, the fundamental problem remains: UK businesses - including many fragrance formulators and ingredient suppliers, the majority of which are SMEs - will still be required to undertake full UK-specific registrations for substances already comprehensively registered under EU REACH. Given the Government's stated commitment to align UK REACH regulatory decisions with EU bans, authorizations and restrictions, this duplication is without logical justification.
The "no data, no market" principle, as currently applied, does not reflect reality. Extensive hazard, use and exposure data for fragrance ingredients is already publicly available - on the ECHA website, in safety data sheets, and through IFRA's own published standards and safety assessments. The Government's insistence on a separate UK data-gathering exercise, estimated to cost industry in excess of £500 million in aggregate, ignores this wealth of existing information. IFRA UK urges the Government to provide urgent, clear guidance confirming that publicly available data may be used for UK REACH registration purposes without requiring the consent of data owners. Without this, the ATRm will fail to deliver even the modest cost reductions it promises.
Novel fragrance ingredients face a particularly damaging double burden. Substances registered under EU REACH since the end of the EU Exit Transition Period - and therefore treated as new to the GB market - will continue to face fully duplicative registration requirements, potentially including the generation of new hazard data and animal testing. For a sector that depends on continuous innovation to meet consumer demand for new and sustainable fragrance materials, this is deeply counterproductive. It will delay the introduction of novel ingredients into the UK market, discourage investment in UK-based research and development, and push innovation activity towards jurisdictions with less burdensome regulatory frameworks.
The compressed registration timelines compound these concerns. With implementation now required within 12-month windows - rather than the 24-month periods originally anticipated - industry faces an acute resourcing challenge, particularly for smaller formulators and distributors who lack the regulatory infrastructure of larger multinationals.
There is a better way. IFRA UK supports the recognition of EU REACH registrations for substances already on the EU market, consistent with the Government's own policy of aligning with EU regulatory decisions on authorizations and restrictions. A proportionate notification process - confirming which substances are placed on the GB market and in what quantities - could satisfy the legitimate objectives of the "no data, no market" principle without the enormous cost and administrative duplication of parallel registration. This approach would require no agreement from the EU, could be implemented unilaterally, and would immediately improve the UK's attractiveness as a destination for fragrance innovation and investment.
IFRA UK calls on the Government to:
- Confirm urgently that publicly available ECHA data and IFRA safety assessments may be used for UK REACH registration submissions
; - Extend recognition of EU REACH registrations to substances already on the EU market, replacing duplicative registration with a streamlined notification process;
- Remove the requirement for novel fragrance ingredients registered under EU REACH post-transition to undergo fully duplicative UK registration, including the avoidance of unnecessary repeat animal testing;
- Extend registration implementation windows to a minimum of 24 months to give industry - especially SMEs - a realistic prospect of compliance; and
- Engage substantively with IFRA UK and the wider fragrance supply chain to ensure that future regulatory design reflects the specific characteristics of multi-ingredient formulated products.
The fragrance industry stands ready to work constructively with Government to achieve a regulatory framework that maintains the U.K.'s well-deserved reputation for the highest standards of safety, whilst removing unnecessary barriers to competitiveness, growth and innovation. The ATRm, as currently designed, does not meet that test.
IFRA UK represents the fragrance industry in Great Britain, working to ensure that fragrances can be enjoyed safely and sustainably. IFRA UK members are committed to the responsible use of fragrance ingredients in accordance with the IFRA Code of Practice, which is based on the safety assessments of the independent Research Institute for Fragrance Materials (RIFM).
IFRA UK is pleased to discuss any aspect of this response further and remains available to participate in ongoing stakeholder. Please direct any queries to the IFRA UK Secretariat or Technical Director [email protected]
