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Obviously, SEPA is the regulator for environmental issues in Scotland and will be for the environmental impact of REACH overall, but the competent authority for the issue of registration is the Health and Safety Executive. That decision was made across the board with the Scottish ministers, the Welsh ministers and so on, so the Health and Safety Executive is the equivalent of SEPA in this, and we have therefore worked closely with it on the issue. Officials are keeping SEPA very closely updated on all these developments, and it is always welcome to give us its feedback.

I do not know whether Dan Merckel might want to say more about the engagement that he has had with SEPA, but it is certainly not the official body on this. However, the convener is indicating that we need to be as short as possible.

I will split my answer into two points. First, what we are dealing with today is squarely about the extension of the deadline rather than about what system might replace the registration arrangements. On the extension of the deadline and the decision to be made today, I do not have much concern about divergence, because we are talking about trying to have a complete register and getting there within a realistic timescale. I do not see much scope for a concerning divergence between us and the EU in that regard. In fact, its register took 10 years to complete, and if we agree to this today, what we will be dealing with in UK REACH will happen within a similar timescale.

The risk of divergence comes further down the line when we look at the changes that will be made to the system and for which this time extension is needed. Officials are very much involved in the working groups, looking at what might be changed in registration arrangements. We have been clear from the outset that we would not tolerate any diminution in standards, and that is our starting point for the work with DEFRA, which is very much in the early stages.

I might bring in Dan Merckel to see whether he can offer anything else on your specific point, but for my part today, I am content that extending the deadline does not increase the risk of divergence and that, as we develop changes to the registration system, my officials and I are clear that we will not tolerate any diminution in standards. I will be very watchful for any risk of divergence in that regard, and we would want to see that mitigated as far as possible. Dan, do you know any more about the specific point that Mr Ruskell raises?

Yes, I am. I agree with Rebecca Pow, who wrote back to the committee—thank you for sharing those documents with me. As she put it:

“we believe that allowing the extra time could lessen potential burdens on businesses without significantly impacting on human health and environmental protections. We also recognise the potential for better quality data and maximising chances of compliance under the longer timescales.”

Yes, of course. Through the common framework process, we liaise closely and will continue to do that. My officials are part of the working group that is considering the development of the registration system and how it might change. We have been given assurances about DEFRA ensuring that there is sufficient capacity to get that work done in the necessary time.

When it comes to approving the final outcome, because of the statute under which the process is undertaken, Scottish ministers’ consent will, I understand, be required and, therefore, parliamentary scrutiny will be engaged. Also, that proposal will have to be accompanied by a statement in line with UK REACH article 1, which sets out the confidence that it is in line with environmental protections and does not threaten any of them.

Yes, we certainly will, and I suspect that further consultation will take place on the substance of whatever it is expected to replace that year.

I will try to answer that and, if I need to hand over to my officials, I will do so, because they are involved with that just now.

The UK strategy is currently being developed. I understand that our teams are feeding into that and our position at this point is that we will withhold our approval for it while we make sure that the final version reflects the input that we have made and is in line with Scotland’s interests. That is similar to the position that Welsh ministers are taking.

Dan Merckel or Ailsa Heine might have more to add to that, but I will comment briefly on the EU strategy. We are keeping a watchful eye on it and I suspect that a lot of what we will feed into the UK strategy development will be a part of learning from the EU strategy, in line with our desire to keep pace with the EU.

Is there anything to add to that, Dan?

I do not think that, ultimately, there is a realistic alternative. We spoke about the common frameworks. Those are the way in which we have agreed to work together in the post-Brexit landscape and, so far, that has worked well.

One of the problems that I have with UK REACH is that we are no longer doing it on an international basis, as we did with EU REACH. To suggest that we could do something even more insular in Scotland would not be credible. It is better for everyone involved that we continue to work together, continue to take advice from the Health and Safety Executive and continue to consult.

As for the on-going work on how the registration process might be changed, I am comfortable with the fact that the Scottish ministers’ consent will likely be required to any of those changes, and that a statement in compliance with article 1 of REACH UK will be required, which will demonstrate how it does not represent a difficulty for the environment.

On the first point, I am not concerned that changes to the deadlines are a risk to divergence or convergence. What might change is still very much at the early stages, so I have to withhold my view on that point while we develop the process. However, we will certainly make the argument for divergence to be minimised as far as possible.

I cannot really speak for the industry or the UK Government, but my impression is that the industry’s barrier is the cost of obtaining the data that is required under UK REACH, much of which it does not own. We will therefore have to find ways to try to overcome that barrier. It is very much early days, but our position will be to minimise any divergence as far as possible as that process develops.

We worked with DEFRA in advance of its public consultation, which, I think, was answered by industry, trade associations and non-governmental organisations. That was a broad spectrum, although, admittedly, the majority of the respondents were trade and industry representatives. It was very clear that a three-year extension across the board was the workable option, in their view, as opposed to what I think the UK Government’s preferred option was: to extend the first category by three years, the second by two years and the last by one year.

On the backdrop of the assurance that, in the view of DEFRA and of the Health and Safety Executive, those extensions are not likely to be detrimental to the environment, I was happy that three years across the board was appropriate, if that is what trade and industry believe is necessary to make it right. It goes back to the point that I raised with Fiona Hyslop: the risk of not getting it right is substantial and, if we need that time, we need that time.