EU and industry directors recommend actions to help SME registrants
The Directors Contact Group (DCG) – a platform of the European Commission, ECHA and industry associations – continued its discussions on 15 December on how to best help SME registrants that face significant expenditure ahead of the 31 May 2018 registration deadline. The DCG recommends four actions for companies and ECHA to allow small-volume or SME registrants that have not registered substances before to access data and the joint submission with reasonable effort.
These actions are:
- Reducing the costs of data for 1-10 tonne registrants by exploring data waiving arguments: Companies should check whether they are exempted from providing (eco)toxicological data with their small-volume registration and could register only with physicochemical data. These exemptions relate to Articles 12(1)(a) and (b) and Annex III of REACH. Those who can register with physicochemical data only, should get access to the data and joint submission at reduced or no costs.
- Addressing situations caused by late data-sharing negotiations or pending dispute decisions: The DCG recommends that first-time registrants file a data-sharing dispute with ECHA if the negotiations for access to data have come to a standstill and all means to reach an agreement have been exhausted. Companies will be able to submit their registration dossier while the negotiations or the dispute process are ongoing. ECHA will clarify how it will deal with these dossiers by the end of January 2018.
- Reducing the cost burden on SMEs by allowing payment in instalments: If a one-time payment of the letter of access (LoA) is unaffordable for the first-time registrant – and they can justify why – lead registrants and the managers of the substance information exchange fora (SIEF) should consider granting the registrant the opportunity to pay in instalments.
- Offering a low-cost affordable lump sum payment option for 1-10 tonne registrants: Lead registrants and SIEF managers can reduce the administrative burden of joining an existing joint submission and the risk of a data-sharing dispute by offering first-time registrants the opportunity to make an affordable lump sum payment. The recommendation also provides circumstances and conditions that facilitate lump sum charging.
The DCG recommendation only concerns access to existing data for registering substances by the May 2018 deadline. It will not apply to sharing the costs of creating new data or providing information, for example, in response to ECHA’s substance evaluation decision.
In addition, the DCG decided to open four solutions designed already for the 2010 and 2013 deadlines for companies in exceptional circumstances (solutions 10, 15, 20 and 21). These will be available for the 2018 registrants from 31 January 2018 onwards. It also decided to slightly amend the wording of solutions 15 and 21.
On 31 January 2018, ECHA holds its REACH 2018 Stakeholders’ Day where first-time registrants get advice from ECHA and industry experts and can ask questions from ECHA staff.
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