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REACH registration deadline: SMEs struggle to comply

30 May 2018
by UEAPME -- last modified 30 May 2018

UEAPME is highly concerned about recent developments around REACH, the chemicals' regulation, and the future availability of resources for the European economy.


he recently published review of the REACH regulation suggests business-as-usual with some minor adjustments. However, the last statistics of the 3rd registration deadline show a totally different picture: by 1st June 2018, ECHA, the European Chemicals Agency, predicted 25.000 substances to be registered, but so far not even half of that number have been attained. A substance cannot be manufactured nor marketed without the necessary registration, in consequence, after the end of May deadline, such substances will also not be available to the users anymore. This can lead to serious and unforeseen impacts on many value chains, a situation UEAPME has been warning about for over a year.

According to UEAPME Secretary General Véronique Willems, "it is worrying that ECHA's estimations are relatively conservative and that other industry estimations presented much higher numbers of substances that needed a registration." She underlined that every single substance – no matter if produced in the EU or imported to the EU – may have a crucial role for European enterprises. "I would be already worried if the discrepancy between the status quo and estimations would be a couple of hundred substances, but we are now talking about thousands of substances. Either the past predictions are totally wrong or we will indeed have a huge problem soon. So far no one – not authorities, nor other industry associations – could give us a convincing comforting answer," said Ms Willems.

UEAPME is convinced that the complexity of REACH, including all the other chemical legislation like the F-gas regulation or biocidal product legislation, is part of the problem. "It goes without saying that safety measures are essential whenever dealing with chemicals, but choosing the most burdensome options instead of available alternatives is a real threat to SMEs" reiterated Ms Willems. She recognises that some safety benefits are there, but they come at a very high cost, at least for SMEs. On the other side, significant advantages for competitiveness and innovation are truly missing. "How can an average SME keep up with a legislation that requires the involvement of several highly trained experts to develop a registration or authorisation file?" asked Ms Willems, although for her the answer is crystal clear: "It is nearly impossible under the current circumstances!"

The REACH review that the European Commission published earlier this year recognises that SMEs need more support. Additionally, Ms Willems is convinced that "we will need more fundamental and concrete simplifications as outlined in the review." She also considers this necessary especially for the authorisation application process and the registration regime. There are two fundamental reasons the registration negatively effects SMEs: (i) the complex administration built around REACH that constantly drains valuable resources from an enterprise; (ii) testing costs, which for lower tonnages are disproportionally high. "We need some serious fixes that give SMEs room to concentrate on their core activities and to be able to prosper," said Ms Willems and she suggests a systematic evaluation of how REACH could become SME-proof. "We should also consider bold measures, like for example reducing data requirements in the range of 1-100-tons-tier" she concluded.


UEAPME is the employers' organisation representing Crafts and SMEs from the EU and accession countries at European level. UEAPME has 64 member organisations covering about 12 million enterprises with 55 million employees. UEAPME is a European Social Partner.

UEAPME – the European craft and SME employers' organisation
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