Small and medium-sized enterprises (SME) are a vital part of the EU chemicals industry. Since safety is a key concern, regardless of company size, the REACH information requirements relate to production volumes, uses and properties of the chemicals, and not to turnover or the number of employees of the companies.
Many of the SMEs that will be affected by the present legislative proposal are 'downstream users', i.e. companies that buy chemicals and use them as ingredients in their own products or use chemicals in an industrial or professional way. As a result of their position in the value-added chain, most chemicals will already be registered when they are utilised by downstream users. When assessing risks, manufacturers and importers must address the uses identified by downstream users. This will help to ensure a high level of chemical safety for downstream users and will reduce their costs. Downstream users who wish to keep their uses secret can choose to do their own risk assessments.
SMEs that are manufacturers will be able to take advantage of the incentives for innovation that the REACH system will create, such as:
- Exemption from testing requirements for substances used in product- and process- orientated research and development.
- No registration below 1 tonne.
- Light information requirements for low volume substances (registration threshold at 1 tonne/year per manufacturer/importer, normally only in vitro testing for substances between 1 and 10 tonnes). This should reduce the costs for manufacturing SMEs, who will typically work in this range.
- Administrative burdens and costs can partly be shared between registrants in the pre-registration process.