The study found that REACH has had a negative effect on European Union competiveness, especially for larger firms with an export portfolio outside the EU. The study did find that the regulation has led to increased R&D, as well as replacement and substitution activity, which qualifies as innovation in terms of the OECD/European Commission definition. However, many firms expressed the view that the activity has been driven purely by the need to comply with legislation and has not led to increased competitiveness in terms of more or higher quality products or services that better meet customers needs.

Regarding the costs of the implementation, the study notes that the costs involved in the implementation of the regulation are running according to plan at around 459 million per year (for 2013 alone). For 2018, however, the analysis found that the estimated cost will balloon for substances produced at volumes of 10 to 100 tons per year if no corrective action is taken, and there is no readily available or apparent way to reduce this cost.

As a result, the study concludes, There is a strong view in industry that the costs incurred for implementation have, for the present, delivered little in terms of enhanced competitiveness and innovation and that benefits of implementation, in as much as they exist, need to be sought in the wider health, safety and environmental benefits of the legislation. Finally, the study makes 18 recommendations, including:

Set up a database that provides different provisions at a substance level.

Raise awareness of companies REACH roles and obligations in light of 2018 registration requirements. Industry associations need to play a larger role in sharing best practices in this area and helping with translation services.

Create a pan-EU body to assess the development of certification (or equivalent qualification) for a REACH practitioner. In particular, small and micro firms need external support at affordable costs.

Assess the scope and impact on SMEs having to pay substantial sums for Letters of Access – well beyond what they consider affordable. Identify and investigate options for dealing with the problem. This issue is important for the run-up to the 2018 registration.

According to a statement by the UEIL, the study is rather cautious in its overall findings and recommendations. However, it puts forward many useful recommendations that the organization will adopt. Going forward, UEIL stated that it will follow this issue closely, especially in light of the REACH fit for purpose review that the EU commission wants to complete by the middle of 2017.

The 250-page study can be found at: ec.europa.eu/growth/sectors/chemicals/reach/studies/index_en.htm.