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ESBA statement for the REACH first reading plenary vote – 17/11/05

Small business entrepreneurs and self-employed represented by ESBA are highly concerned about the workability of the future EU REACH chemicals policy. ESBA acknowledges the need for ensuring the protection of human health and the environment from hazardous chemicals, and supports the goals of REACH. However, we are not convinced that these can be achieved with the current proposals. The administrative and financial burden must be kept to a minimum. Otherwise, SME’s capacity to grow, innovate and create jobs, will be jeopardised.

ESBA is concerned by the current proposals and a series of amendments of the Environment Committee (ENVI) inspired by a volume-based approach. We believe these are neither needed nor implementable.

Moreover, the overall complexity and cost of the procedure as adopted in ENVI would lead to the withdrawal of substances from the market for purely economic reasons. This would have disastrous effects for downstream users when no alternative is available.

Further, the ENVI amendments contradict many recent Commission’s initiatives that seek to promote a better business environment and achieve the Lisbon agenda‘s goals.

You will find below our key concerns along with voting recommendations, which we ask you to consider when voting on REACH on 17 November.

We thank you in advance for your attention,

Sincerely yours,

B.A. Prime, President of ESBA

Registration - The rapporteur’s compromise package on registration, which foresees lighter testing requirements for the 1-10-tonne category but imposes the full degradation tests as of 10 tonnes, would reduce the burden for SMEs only to a certain extent. On registration, ESBA thus supports the approach of the Internal Market Committee, which establishes the level of testing requirements according to the risk a substance may pose for human beings and the environment.

Keeping the risk-based approach would be in line the aims of the REACH regulation and alleviate the disproportionate regulatory burden that the Commission’s draft proposal and ENVI approach would put on SMEs, mainly in terms of information gathering. Indeed, small businesses can not provide the necessary human resources, financial commitment or level of expertise the volume-based approach would require.

One Substance One registration (OSOR) - ESBA supports the OSOR system. It will reduce the costs linked to registration for small businesses and lead to a more efficient registration scheme. However we oppose any amendments on mandatory consortia and sharing of all test data. Indeed, small business may not be willing to engage into consortia where they have no influence or if they feel sensitive commercial information would be put at risk.

Chemicals Agency - ESBA supports the concept of a strong agency, incl. the ENVI amendments that reinforce its powers, notably in the areas of evaluation of substances. We support its newly allocated tasks to assist business and SMEs in particular, including guidance tools, a help-desk; and a website.

Donwstream users - We support the ENVI amendments that would exempt a small or medium sized downstream user from providing information to the agency when the substance is used in a different way compared to what is described in the exposure scenario sent by the supplier. This supports the risk-based approach.

Chemicals Safety reports and Chemicals Safety assessment – ESBA opposes the extension of the obligation to complete chemicals safety reports, as well as chemical safety assessments, to all registrants, not only those producing or importing substances above 10 tonnes. This is an onerous burden for SMEs.

Exemptions for R&D – ESBA support the doubling of the length of the exemptions (10+10 years instead of 5+5 years) for research and developments. This will allow innovative small businesses to transfer their findings into business projects without being hampered by the cumbersome and costly registration process.

ESBA is the only organisation in Europe to focus its representation on the needs of independent small business organisations (vs. statutory or compulsory membership groups). We gather today more than 1.5 millions voluntary members across 22 European countries, who are entrepreneurs putting faith in the EU to deliver proportionate and efficient regulation to help them access the benefits of the single market and create jobs. For more information please contact: secretariat@esba-europe.org

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