The Directors’ Contact Group (DCG), which consists of representatives of the EU Commission, the ECHA and industry, rejected free access to REACH data for small and midsize enterprises (SMEs) at its meeting held on December 15. The ECHA has requested such access from the DCG to simplify the registration of substances for companies. We reported on the request in our article, REACH 2018: ECHA Seeks Financial Relief for Smaller Companies.
Instead of free access, the group recommends that lead registrants and Substance Information Exchange Forum (SIEF) managers ask the companies involved for a one-time, lump-sum payment. The DCG feels that this approach would reduce administrative effort and lower the risk of conflicts that commonly arise when sharing data.
In its recommendations, the DCG suggests a variety of additional measures as well. For example, it recommends that the companies involved read Article 12 (1) (a) and (b) of REACH and the criteria listed in Annex III very closely. In many cases, physicochemical data might be completely adequate for a registration dossier, rather than the much more complex ecotoxicological data.
If first-time registrants and partners cannot agree on the conditions for joint use of data, the registrants should notify ECHA. Despite the ongoing dispute, they can still submit a registration dossier. The ECHA will decide on the way to deal with such cases at the beginning of 2018.
The DCG also finds it helpful to allow registrants to pay in installments if they cannot afford the high costs of a Letter of Access (LoA) and participation in a forum on information exchange.
Peter Newport of the British Chemical Business Association (CBA) criticized the DCG’s suggested measure as far too weak and too late. Now, says Newport, it’s payback time for the many years of ECHA inactivity. As early as 2013, the CBA and the European Association of Chemical Distributors (FECC) argued forcefully for much broader measures at a conference of ECHA and industry representatives.
Please note the ECHA Stakeholders Day on January 31, 2018. Novice registrants will be able to pick up some useful tips there. And, of course, you can contact us about any upcoming registration at any time at email@example.com.