EEF’s chief executive Terry Scuoler reaches out to UK manufacturers to raise awareness of the wide ranging impact of updated regulation for REACH – the registration, evaluation, authorisation and restriction of chemicals.
What would happen to your business if a chemical in your production process suddenly disappeared? Or if a key chemical in your product was withdrawn from the market?
Maybe the first response would be blind panic or heated discussions into the night with your engineers about possible alternatives. I think we can assume the last recourse would be calls to your customers to say, sorry, you are not able to fulfil their orders or that the products they receive won’t be as they had expected.
Unfortunately this scenario is not entirely unfeasible. Yet manufacturers display a worrying lack of awareness around the way in which European regulations on chemical usage may affect them. The impact is far broader than many suspect.
A recent EEF survey shows 20% of companies still believe REACH is not applicable to them while a further 30% say it isn’t important to their business. The figure rises for the smallest companies. Just under a third of companies with turnovers below £2 million per annum are unaware of how they will be affected by REACH – a rapidly changing area of regulation with a number of direct legal obligations falling on potentially any manufacturer.
At least once a year new substances will be targeted for bans, so it’s a moving feast.
It is important that all manufacturers monitor developments and plan for future changes by searching for substitutes, changing production processes or getting ready to apply for permission for continued use.
In some cases there may be easily available alternatives, in others, searching for substitutes will be a more involved process. Companies may need to purposely target innovations and work closely with their supply chain to make this work. The registration element of REACH raises further challenges. It can cause substances to disappear from the market.
“On the June 1 2013, companies that place substances on the market in quantities between 1,000 and 100 tonnes a year are required to register them” – Terry Scuoler, chief executive, EEF
This year marks the second major deadline for registration. On the June 1 2013, companies that place substances on the market in quantities between 1,000 and 100 tonnes a year are required to register them.
The registration dossiers assess the potential impact of substances on human health and the environment and sets out risk management measures to enable their safe use. Preparing this dossier can be expensive and in some cases companies may decide not to register a substance and, instead, withdraw it from the market – particularly true of specialty chemicals produced in low volumes.
Critically, if a substance isn’t registered you cannot use it within the EU.
In a recent survey for the European Commission, 37% of firms said they had experienced a withdrawal of a substance as a result of the first round of registrations in 2010. Around 30% were expecting it to happen again. I’m surprised it’s not more.
Armed with the right information, our survey confirms that most companies can and will react to REACH.
There does remain an issue for small companies, however. Despite this group expressing the most acute concern over possible substance bans our survey showed that, even when aware, half are not monitoring REACH developments. This compares to 72% of large companies and 83% of medium-sized who are monitoring it closely.
What does this mean? Well, we need to make REACH easy to comply with. There needs to be better communication of changes and this must include clearer explanations of the potential impact of these changes. We need stronger guidance from European regulators and legislators which is easy to understand and follow.
EEF has a role to ensure that the manufacturing community grasps that this is an issue for us all. If you are not monitoring REACH you could make a good start by signing up to our free Substance Alert Service or consider REACH training or an audit by one of our consultants.
For further details visit www.eef.org.uk/REACH.