What are the consequences of REACH for SMEs?

• The vast majority of European SMEs are so-called down-stream users or articles users, not producers of chemicals. In fact, only 0.3% of all European SMEs are chemical producers. According to CEFIC there are 24.500 European companies with less than 500 employees producing chemicals. However, there are more than 7 million SME in Europe with less than 250 employees. Note that the definition of an SME is < 250 staff, although CEFIC uses 500.
• In addition, European chemicals producers that are SMEs with >20 employees, according to the most recent CEFIC statistics, around 2,000 companies.
• There is a tendency to say that the test requirements for low volume chemical should be reduced because of the workload on and costs for SMEs. However, there is no evidence of a correlation between SMEs producing chemicals and low volumes. Some SMEs produce a few chemicals in high volumes, others produce low volume chemicals.
• The required information for low volume chemicals is basic information needed to guarantee a minimal protection of workers handling the chemicals. None of the tests are unnecessary.

European SMEs are largely downstream users, or users of articles, who under the current system, or under a weakened REACH:

• Have no or limited right to information on chemicals in the products they buy
• Operate on a market with consumers increasingly suspicious of chemicals
• Have to carry the costs of workers' ill-health in terms of e.g. work days lost and rehabilitation
• Ultimately get named, shamed and pay the price when something goes wrong with chemicals in their products

Efforts to assist SMEs producing chemicals under REACH

• OSOR - "the one substance one registration" approach will reduce the registration costs up to 24 %.
• There will be no registration for substances produced in volumes below 1 tpa. In comparison: current legislation requires registration for new substances produced in volumes above 10 kg.