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Thematic studies for Review of REACH 2012

Impact of the REACH regulation on the innovativeness of EU chemical industry


A study to assess the impact of the application of the REACH regulation on the capacity to innovate of the European chemical industry. Enhancing innovation is one of the primary objectives of the Regulation (expressed in article 1) and the study will consider the positive and negative impacts on it.

Data gathering

Input: Interviews with industry and public authorities / pan-EU survey with industry

Workshop: December 2011

Final report and Annexes

Highlights of the consultants findings

It has been found that the Regulation's objectives regarding the innovativeness of the EU chemical industry are highly relevant in terms of EU industrial and innovation policies. The industrial information creation, capture and dissemination mechanisms created by the Regulation have acted as stimuli to product conception or innovation to varying degrees among survey respondents (Registration Dossiers with Technical Dossier and Chemical Safety Report – 17%, development of Safety Data Sheets and extended Safety Data Sheets 26% and Substance Information Exchange Fora – 9%). Some 72% of companies surveyed thought it had led to an increase in access and scrutiny of information about chemical substances and 24% indicated that they had been able benefit from this through increased knowledge of substances and properties. However, this has come a t a significant cost to the industry. More positive results may be apparent in the longer term, as companies reorient their R&D and innovation programmes.

It was asserted that the registration process has had an impact on innovation, but the candidate list is currently creating the greatest deal of innovative activity (with the SIN list, and more recently, possibly the CoRAP). Authorisation and restriction, while important in specific sectors affected, are affecting a smaller part of the industry. It has not been able to discern overall unequivocal benefits for consumers, the market and society at this stage of implementation.

The research findings suggest that SMEs, and particularly small firms, are especially affected by the Regulation due issues surrounding access to input markets such as costs of specialised staff, training, and Letters of Access for formulators; and also access to finance in the view of increased risks and uncertainties associated with innovation. Highly innovative SMEs have a more negative view of the overall effect of REACH on innovation than large firms for the present and the future.

Main recommendations from the consultants are: work through leading industry associations and MS educational organisations to increase provision of appropriately skilled human resources; encourage Member States to provide for REACH-specific support programmes and link this to knowledge-sharing networks; attract specific private sector funding through a series of promotional initiatives in collaboration with the industry; increase the clarity of predictability of substances destined for the candidate list; support development of alternative testing methods; increase the predictability of costs and timing as regards the inquiry and registration process at ECHA; develop a new category of firm within REACH: the small chemical company, with reduced obligations.

Lead Directorate-General

Enterprise and Industry


Centre for Strategy and Evaluation Services L.p.p.