Unnoticed by everyone out there the entirety of European industry has been tying itself in knots this past decade or so. The cause is the REACH regulations. The idea is that everyone has to show that the chemicals they sell or use are safe. That’s the way it was sold to us all by Margot Walstrom when she was a commissioner but of course it hasn’t quite worked out very well. This is an email detailing one small part of the process for one specific such chemical:
Dear Registrants and pre-registrant of the substance Sodium iodide CAS: 7681-82-5,
We have requested the lead registrant verification according to ECHA. It will takes three weeks to be done according to our information.
Even if the deadline has been delayed to the 01rst of september, the summer time will runs very fast.
We think it’s a good idea to begin the discussion on how to merge the registration as soon as possible.
All registrant have paid for letters of access for datas. Registrants have questions on how to merge two joint submissions with different datas and differerent classifications
Having two sets of datas is a problem but can also be considered as the opportunity to consolidate all submission by regrouping and discussing the information.
If we found an agreement on how to deal with these datas with a reasonable minimal costs for all current registrants of both submission we will all benefits from the discussion and the dossier will be strengthened.
On the contrary if no agreement is found some registrants will have to opt –out or to pay again for datas. This situation will probably lead to legal dispute that will take time, and also lead to uncertain conclusion.
We deeply think there is nothing to gain this way
Now we ask you if you agree to discuss about the final content of the lead registration ?
In this purpose , we are ready to share a summary of the datas and the current costs we have as a base for discussion and exchange. We demand to SSS to do the same.
No, me neither, and I’m one of the people supposedly taking part in the process.
Note an important point about this. Every importer, every manufacturer, every user, has to take part in this process. More, everyone – that’s every user, importer and producer – has to take part in the process for each and every chemical being used. So, you use sodium, you do this once, you use iodine, you do it again, you use, make or import sodium iodide then you do it a third time. From memory it costs €9,000 per user/importer/producer per chemical.
Yes, per person per chemical. And that’s just the fee to get them to read the paperwork. That’s not the cost of doing the tests to show that it’s safe, nor is it the cost of all the bumphery like the above email.
Now do one more little bit of thinking. What is the effect of this upon new entrants into the market place? Yes, quite, we’ve just placed a vast barrier in the way of anyone ever doing either anything new or starting up as a new supplier, user or importer, haven’t we?
Thank The Lord we’re leaving and at least we can potentially be free of this nonsense in the domestic economy.