We heard last week that REACH was the most burdensome legislation for SMEs to manage. What could the Commission do to help SMEs? Here are our top 5 recommendations:
· Establish a mechanism to monitor the authorisation process.
A stakeholder group, similar to the Commissions Director's Contact Group (set up to feed industry experience on registration straight to the Commission), should be established to feed in on-the-ground experience with for example the authorisation process into the Commission in a timely and systematic way. This should be combined with external reviews by consultants appointed by the Commission to provide credible, third-party assessment.
· Set out how authorisation applications will be judged.For SMEs using SVHCs in maybe niche (but promising) applications then the case for authorisation may not be clear cut. To help smaller companies understand whether they, or their supply chain, has a case for authorisation there should be stronger guidance on what would be a credible case for authorisation so smaller companies are in a better position to assess whether they should cut their losses and move on to other things without wasting time and money to develop an application which is doomed from the outset.
· Outline how the competitiveness impacts of REACH will be monitored.
This was announced in the REACH review but we are not sure yet what this actually means in practice. From our point of view this must entail a monitoring of REACH (authorisation, restriction etc.) as well as impacts on innovation activity, raw material costs and inward investment.
· Outline a clear delivery plan for developing SME-friendly guidance.We've been promised SME-friendly guidance but when, and how. We need to see the Commission and the European Chemical's Agency spell out how it intends to roll this out and – importantly – how it will engage with SMEs to ensure it delivers to brief. We need guidance that genuinely meets the needs of SMEs, not scaled down versions of existing guidance.
· Develop a methodology for implementing the Risk Management Options process.It's an approach that promises a more risk-based approach to REACH, but if the methodology is unclear how can you expect less experienced Member States to adopt it?