The ECHA is looking for ways to simplify the registration of substances for small and midsize enterprises (SMEs). Many companies hesitate registering substances because of the high costs involved with the Letter of Access(LoA) and participation in the Substance Information Exchange Forum (SIEF). That’s the finding of a study sponsored by the ECHA and carried out by a British consultancy, Risk & Policy Analysts (RPA).
That’s why the ECHA has called upon the Directors’ Contact Group (DCG) to vote for specific relief measures at its next meeting. In its letter to the DCG, ECHA representatives emphasize that the industry could make a major contribution if it freed small companies from the cost of the LoA and then made the token needed for a joint submission available to them as well.
Of course, the accommodations made by large enterprises should be linked to specific conditions. That’s why SMEs should meet the following requirements and agree that they:
- Present a self-declaration that they comply with the definition of an SME
- Agree with the classification in the lead dossier and the safety data sheet and implement the required risk management measures
- Waive their right to detailed cost itemization and not demand any reimbursement
- Confirm that they have the same substance and that no additional information is necessary
- Agree that access to free data applies only to existing data for the 2018 REACH deadline and does not apply to new data
The calls for granting relief to SMEs is not new. As early as 2013, the British Chemical Business Association (CBA) and the European Association of Chemical Distributors (FECC) argued strongly for this idea at a conference with the ECHA and representatives of industry.
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