A small enterprise based in Hull finds a niche in the market for a new product it can sell to the retail market. To exploit this niche, they need to start to use a solvent at about 10 tonnes per year. It is a widely used solvent, but one that they have not dealt with before. They have located a supplier in the US who has agreed to provide the required amount.
The enterprise’s business manager, Fred, has heard of REACH from some of their EU suppliers. They’ve told him that chemical importers have a duty to compile detailed dossiers of scientific information on the substances they bring into the EU, and register them with an Agency in Finland.
This is a daunting prospect for Fred, because it is something the company has not planned for. It has less than 30 staff, and he is worried that they do not have the necessary skills and knowledge to get to grips with this. Fred was thinking about appointing a consultant to work on the registration dossier for the solvent, but has been put off by the high costs involved and not knowing how to select a suitable person.
Attending a seminar on REACH organised by a regional business initiative, the manager hears how a good many companies are also new to having registration duties and have also been daunted by the scale and complexity of REACH. During a series of presentations, the experience of one particular company caught his attention.
This company had been obtaining chemicals from companies based in Europe for many years. The company had looked into REACH and had determined that, as they sourced all their chemicals from within Europe, they were regarded as Downstream Users of chemicals and had no registration duties. However, one of their suppliers ceased trading in January 2009 and a new supplier had to be found. The new supplier was in China, and import from them would appear to mean registration duties. Worried, they had queried this with the helpdesk of the UK Competent Authority (in HSE). They were told that since they were importing the substance from outside the EU for the first time, the could pre-register the substance, which would enable them to delay the registration process for some time, depending on the amount they import.
Fred went back to his company and looked into pre-registration. He found that he could pre-register the substance late, as it was the first time the company was importing the solvent into the EU. As pre-registration is fairly simple, he decided to do it straight away.
After he had pre-registered the solvent on behalf of the company, Fred found that they had been added to something called a SIEF. This was a group of companies who had all pre-registered the same substance, who had all been brought together within the REACH-IT system to enable datasharing. Fred contacted some members of the SIEF and found that, between them, all the data needed for his registration was available and to buy his share of the data was not as much as expected, as there were lots of members of the SIEF to share the costs. A large company had already been appointed as lead registrant and would see to the technical part of the dossier. Fred’s company would have almost 10 years to work out the rest with help from other members of the SIEF, as their registration was not required until 2018. Consequently, Fred and his colleagues realised that REACH was not going to prevent them starting their new venture.