INSIGHT: Reaching for some understanding

21 May 2008 16:50  [Source: ICIS news]

By Nigel Davis

LONDON (ICIS news)--Is the European Union’s Reach system all about regulatory compliance, or is it, as some producers have suggested, about good business as well?

Smaller companies and sellers of chemicals into the EU may be hard pressed to agree with the latter.

Certainly, it makes good business sense to understand your supply chain, know who’s who and who does, or rather makes, what. But the expected burdens of Reach are significant. Will Reach compliance ultimately be worth it?

So far, no one knows how Reach, the EU’s registration, evaluation and authorisation of chemicals project, will perform.

The cost of simply pre-registering and registering the chemicals in a company’s product portfolio is likely to be significant.

Reach will apply to the products companies sell and those purchased as intermediates as part of their business. The administrative and legal burden will fall hardest on the smallest players.

The new regulatory control system will, however, begin to be tested from 1 June when pre-registration begins.

Anyone wishing to sell more than one tonne of a chemical in the EU from the end of this year is expected to have at least registered the fact with the union's new chemicals agency.

No registration, no market, has fast become the mantra for the scheme.

Pre-registration is, purportedly, relatively simple but the business processes required to adequately complete that step are not necessarily as basic.

Producers and sellers of chemicals understand their customers and markets. But Reach means understanding your supply chain and that of your customers in another way.

Pre-registration and registration will be made by legal entities, not a company’s cross national, pan European or indeed, global business unit. Reach adds layers of complexity to already complex processes.

Reach pre-registration may not require the furnishing of anything but a very basic set of data on a substance but does require that a company has the processes in place to eventually enable Reach registration and, possibly evaluation, before authorisation for sale can be given.

Companies are required under Reach in the first instance to supply simple descriptive data of the substances they want to register using the EU’s own REACH-IT data portal.

Non-EU companies cannot pre-register but can nominate a representative that can pre-register and register on their behalf.

Even the big chemical companies concede the chain of events required to move through the Reach process are complex and need to be taken carefully.

Pre-registration is but a first step and will allow the new European Chemicals Agency to assess the scale of the task it - and the industry - is expected to perform. Companies are expected already to have done a great deal of ground work preparing for Reach. The new rules will require much greater understanding and, hence, co-operation, up and down the supply chain.

Beyond pre-registration lies the Substance Information Exchange Forum (SIEF) where those legal entities wanting to register a substance can see all others wanting to do the same.

In SIEF they can exchange contact details and begin the dialogues that will help streamline the process in which relevant health, safety and exposure data on a substance are collated from multiple sources.

It does appear strange to be talking about streamlining a process within Reach which in itself appears fiendishly complex. But Reach will need to be made to work if it is to be at all successful or, indeed, cost effective in delivering health and safety benefits.

For those still confused about Reach, EU member states have advisory services as do national chemical associations and the European chemical industry federation Cefic. The European Chemicals Agency also has a "frequently asked questions" website.

To discuss issues facing the chemicals industry visit ICIS connect

ICIS Copyright © Reed Business Information 2009

Author: Nigel Davis
+44 20 8652 3214

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