Munich / Brussels (Pressweb) - Small and medium-sized enterprises (SMEs) are on the brink of losing touch with the requirements of the 2018 registration deadline under REACH. At the SME workshop organised by the European Commission and ECHA, representatives from the world of politics, authorities and industrial associations expressed concern that SMEs may fail with their registrations. TÜV SÜD has developed a strategy which guides SMEs in obtaining successful registration of their substances.
The successful submission of the registrations required under REACH by 31 May 2018 requires major efforts – a point agreed by all representatives from the EU Member States at the SME workshop in Brussels. However, few SMEs have the capacities and know-how to prepare the dossier themselves. To make matters worse, in many Substance Information Exchange Forums (SIEFs) there has as yet been no substance-related communication at all. At the workshop, many attendees therefore expressed concern that manufacturers or importers might suddenly be in the position of having to become a lead registrant. "This is very time-consuming", says Dr Dieter Reiml, REACH expert at TÜV SÜD Industrie Service GmbH. "Preparation and submission of a lead dossier that is in compliance with all requirements under REACH requires comprehensive experience." According to Dr Reiml, most SMEs so far have only had to prepare co-dossiers, which involve significantly less work.
Will substances disappear from the market?
If registration is not submitted on time and does not meet all requirements in terms of contents and form as defined by REACH, the company concerned will not be authorised to either produce or import the substance in volumes over 1 t/a. "If there is no registrant for a certain substance, the substance will suddenly disappear from the market", explains Dr Dieter Reiml. "Nobody knows at this stage what the consequences may be if an important substance is no longer available to the entire industry."
SMEs have only limited resources. Given this, it is understandable that many companies keep putting off the submission of a registration dossier with ECHA. They face questions such as
- Will I exceed the volume threshold of 1 t/a in 2018?
- Will I still be placing the substance on the market in 2018?
- Are the costs of registration so high that registration is no longer worthwhile?
On the other hand, these companies are soon running out of time. By 2017 at the latest, finding a consultant or laboratory with free capacities will be impossible. The preparation of lead dossiers should be initiated as soon as possible.
"TÜV SÜD’s SME initiative offers assistance", says Dr Dieter Reiml. "Against payment of a small annual fee, we monitor all activities in a SIEF, pass on important information to our clients and point out possible courses of action." Thus TÜV SÜD’s experts support SMEs in deciding when and in what role to register a substance. TÜV SÜD prepares the dossier on behalf of the company and submits it to ECHA. The annual service fee will be deducted from the total price of the registration. This keeps the financial risk to a minimum.
Further information about the services provided by TÜV SÜD in this sector is available at www.tuev-sued.de/is.