REACH — Small and Medium-Sized Enterprises

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” proposal would 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.
For some enterprises, especially those that produce fine chemicals or specialty products or are small, the REACH costs may become proportionally much higher than for the average (the average is approximately 0.1 % of turnover). A way to help these companies would be to compensate the enterprises for registration costs that exceed 0,2% of the turnover for any three consecutive years during the 11-year phase-in period. This suggestion needs to be promoted in the European Parliament.

Watering down the test requirements for low volume chemicals in REACH is not the way to protect or assist European SMEs. Better alternatives, such as OSOR and registration fee waivers, are available and need the MEPs’ support. Most importantly, a strong REACH with robust mandatory testing requirements will give European downstream SMEs the reliable information they need to avoid possible claims and fulfil workers' protection obligations.

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Downloads

Download the REACH text (pdf, 1,7 MB)

Facts and controversial issues 2006 (ppt, 1,26MB)

Report:

Implications of REACH for developing countries
(pdf, 1MB)

Les implications de REACH pour les pays en développement
(pdf, 1,4MB)