31 May 2018 is the last possible registration deadline for manufacturers and importers of chemical substances in more than 1 tonne per year in Europe. A number of small and medium enterprises have pre-registered with no intention of registering their substances under REACH, estimating the cost of the procedure too expensive.
The amount of companies having pre-registered without the intention of registering comes from a lack of knowledge of these small companies according to Laura Grisai, from the Federation of the Italian Chemical Industry (Federchimica). The federation has received many information requests concerning this deadline, and observed that some companies thought they didn’t need to register when in fact they did.
In Spain and Italy, between 2016 and 2018, a survey was conducted on potential 2018 registrants and pre-registrants. On the 1,700 surveyed, only 385 answered, 70 % of which were SMEs. Maria Eugenia Anta from the Spanish chemicals industry association (Feique) says that 600 companies have "disappeared" since they pre-registered their substances. This could be due to the high cost and resources required by registration.
Raising SME awareness on REACH registration
Due to their size and resources, some SMEs do not feel impacted by REACH registration. Which is why many initiatives have been taken in the concerned countries: in France, the French Chemical Industries Association (UIC) are planning on raising awareness through webinars for example.
In the United Kingdom, the environment department’s stakeholder group on chemicals policy recently updated its guidance for SMEs and downstream users.
In Spain, competent authorities are planning an increase in registration dossiers for a single substance, as well as an increase in the number of SIEFs (Substance Information Exchange Forum) and SMEs acting as Lead Registrants. Feique and the Spanish competent authorities also surveyed pre-registrants of 63 essential oils. Once again, only 25 on those surveyed intend to fully register.
You wish to know more?
EcoMundo is an expert service provider for REACH registration 2018. Our services include:
- REACH Late pre-registration and inquiry process
- Preparation and/or analysis of a SIEF Agreement
- Representation of your interests within the SIEF and/or consortium
- Negotiation on your behalf and purchase of the Letter of Access (LoA) from the Lead Registrant
- Submission of your REACH dossier to ECHA and follow-up until acceptance
- Drafting of your REACH IUCLID dossier
- Only Representative (OR) service
For more information, do not hesitate to contact us via phone: for North America please dial + 1 (778) 231-1607 or for Europe +33 (0)1 83 64 20 54 or email us: contact@ecomundo.eu.
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