WIREDGOV

Are you manufacturing in Europe? If so, you will need to consider how the next and final round of registration could impact you and your supply chain.

May 2018 seems a long way off. But work on Registration 2018 needs to begin now: companies reliant on the use of speciality chemicals or formulations, either directly or in their supply chain, need to start to assess potential supply vulnerabilities. After 2018, substances that aren’t registered will no longer be able to be used in the EU.

The 2018 deadline, the final registration deadline under REACH (the EU's flagship chemical regime) applies to substances manufactured or imported into Europe annually in volumes between 1 and 100 tonnes. The process itself is the responsibility of those manufacturing or importing substances into the EU.

It is expected that over 70,000 registrations need to be submitted in 2018 covering approximately 25,000 substances. We are also expecting a significantly higher number of small and medium sized companies to be involved in the process, compared to previous deadlines.

This creates risks – SMEs are less likely to have internal expertise or the budget to put all the substances in their portfolio through the registration process. Internal resources to manage dossier preparation and to keep it updated may be stretched. 

There are still a number of companies, large and small, that still haven’t decided whether they will fully register the substances they pre-registered back in 2008, whether to remain just below the 1 tonne per year registration threshold to avoid registering altogether, or whether to drop products completely from their portfolios, either because the cost of registration exceeds the substances’ market value or simply because companies don’t have the resources to put all of their portfolio through the registration process and will focus only on their most profitable substances.

So we are expecting uncertainty in the market. Downstream chemicals users will need to consider what would happen if they were no longer able to access formulations or niche substances that are important to their business.

This is not a hypothetical risk. There are already signals from the market that companies that have begun to assess their portfolios might not register some of their substances. An EEF found that a third of companies were aware of suppliers who would be withdrawing substances from the market as a result of the registration requirements.

While this does not necessarily mean that substances will be “orphaned” – not registered and therefore unable to be used in Europe – it does signal significant changes in the market that companies will need to ready themselves for. For example, the number of suppliers may drop with supply consolidated among fewer companies and costs may increase.

If you are a potential registrant you need to start work now (you may have registration obligations if, for example, you import formulations in small quantities outside of Europe). Consider which chemicals you will register. Survey SIEF activity. Begin to assess the costs involved and make an informed decision on whether, and what to register.

Downstream users of substances need to also prepare. Assess vulnerabilities in the supply chain. Talk to your suppliers. Are they registering and will they cover your use? If a substance or formulation is business critical, could you sponsor its registration?

The key is planning and preparation. Companies that start now can avoid pressure, supply chain disruption and expensive mistakes later.

The UK Chemicals Stakeholder Forum has published a short briefing note for companies to help explain the registration process, answer key questions relating to the process and highlight resources to help companies manage registration.

To find out about some of the other elements of the REACH Regulation that might have an impact on your business visit ECHA and HSE's websites or join techUK's sustainable supply chain group, which monitors REACH closely.