Despite the efforts made, not everybody seems satisfied with the Commission's moves to facilitate REACH implementation.
On 13 September, the United States Council for International Business - a trade body whose membership includes some 300 leading US companies with combined annual revenues in excess of $3 trillion - hit out at the Commission's proposed guidelines for REACH implementation.
The final guidelines, known as RIP 3.8, relate to substances that are contained in finished products, or 'substances in articles' in REACH jargon. But with the number of chemicals in finished products, such as computers, sometimes amounting to 100 or more, registration can become somewhat complicated.
"We are concerned that these guidelines are neither workable nor proportionate," said Andrea Fava, USCIB's manager of environmental affairs. USCIB recommended the revision of the proposed guidelines, saying that its members are "concerned about the workability of the draft from both the compliance and enforcement perspectives". USCIB has also expressed concern that the guidelines go beyond the scope of the draft chemicals legislation.
"We urge that further input be considered and that the guidance for articles be revised," said the USCIB statement.
In June 2006, the European Chemicals Industry Council (CEFIC) launched ReachCentrum, a help desk to support companies along the value chain to fulfil the requirements of REACH.
CEFIC said the Brussels-based ReachCentrum will draw from experience gained with European Commission projects that is says have given CEFIC "unique expertise on REACH".
"CEFIC is now turning this expertise into practical help to companies." Services provided will include consortia management, "including Chinese walls facility to preserve confidentiality" and a registration service to handle submissions of dossiers to the future chemicals agency.
In response to the passing of the regulation itself, CEFIC Director-General Alain Perroy called on EU institutions "to continue developing the technical guidance and instruments needed to secure the successful implementation of REACH.” In this context, Perroy said it will be “of paramount importance to establish an efficient and cost-effective agency".
UEAPME, the European small-businesses association - which represents both small chemical producers and downstream manufacturers who use chemicals in their products – praised moves supporting their implementation of the legislation.
But overall, UEAPME said the end result is "quite disappointing." "The issues of data sharing and data liberalisation have been sidelined during the debate, and legal certainty on cost sharing is left to future guidelines. More could have been done," said Guido Lena, environmental policy director at UEAPME.
For the WWF, "the effective implementation of the substitution principle will be decisive in assessing whether REACH has been a real improvement over the current system".