This article is brought to you by the European Commission – Enterprise and Industry.


Undoubtedly, the EU chemicals legislation brings benefits for society. But there are gains for industry, too. Companies have developed a clearer insight into their product portfolios and addressed more systematically the hazards of the industrial chemicals that they place on the market. By identifying their uses, they have helped establish a better picture of the risks that merit dedicated risk management measures. Such stewardship contributes to the protection of human health and of the environment. It also helps identify potential for innovation.


Yet, the regulatory burden has its costs. Companies have needed to adapt their business and production practices. Establishing the data for dossier submissions and handling communication in the supply chain has its expense. Small and medium-sized enterprises are more limited in their means to bear as well as mitigate the effects of this burden. Some have little experience in handling their obligations under REACH or CLP. The new Biocidal Products’ Regulation requires companies even with long practice in the field to acquaint themselves with a new IT tool and novel regulatory processes. SMEs are often formulators preparing for the 2015 CLP deadline for classifying mixtures. Many will also soon be setting out to register dossiers for phase-in substances by the 2018 REACH registration deadline.


Another constraint is that the voice of SMEs is difficult to hear. Small and medium-sized companies and their representatives often see the legislation, as such, as being burdensome, but may not be able to identify the support they might appreciate. To facilitate compliance, ECHA needs to be in a position to duly identify the real concerns and still unaddressed needs of SMEs, even if small and technical, in relation to ECHA’s work and regulatory processes. The Agency should not be second-guessing these needs.


For the full article please refer to the European Commission link above.