It’s here! The study that tells us how the EU’s REACH affects SMEs.

After what seems like an eternity, the long-awaited study on Monitoring the Impacts of REACH on Innovation, Competitiveness and SMEs is upon us. UEIL provided input to this work that was performed by a consortia of three parties, CSES, RPA and Okopol. The study was commissioned by DG GROW.

So what does it tell us? Firstly and squarely the consortia find that the EU’s REACH has had a negative effect on EU competiveness, especially to larger firms with an export portfolio outside the EU. As regards to REACH effect on EU firms capacity to innovate, the regulation has led to an increased level of R&D, as well as replacement and substitution activity, which while qualifying as innovation in terms of the OECD/ European Commission (2005) definition, many firms are of the view that the activity is purely driven by the need to comply with legislation and has not led to an increase in competitiveness in terms of more and/ or higher quality products or services that better meet customers’ preferences.

On costs of the implementation, the study volunteers that the costs involved in the implementation of the regulation, these are according to plan and around 459 million Euros a year (for 2013 alone). For 2018 however the study finds that the estimated cost will balloon for 10-100tpy substances if no corrective action is taken, and there is no readily available or apparent way of reducing this cost. No surprise then that the consortia puts forward the statement that “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”.

The study then goes on to put forward 18 recommendations. In fear of losing the readers we will hone in on the most important ones. Discarding the many suggestions for more studies to obtain a better understanding on “real” impact of REACH on the market, the most useful recommendations are: 1. A call for setting up a database that sets up different provisions at a substance level

2. Raise more awareness of companies REACH roles and obligations for companies in light of the 2018 registration requirements, calls on Industry associations to play a larger role to share best practices in this area and help with translation services

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

4. The Commission should assess what the scope and impact is of SMEs having to pay substantial sums for Letters of Access – well beyond what they consider affordable – and identify and investigate what the options are for dealing with the problem. This issue is important for the run-up to the 2018 registration.

Overall this study is rather cautious in its overall findings and recommendations - however it puts forward many useful

recommendations that we as UEIL will latch on to. Going forward UEIL will be following this issue closely. Especially in light of the overall REACH “fit for purpose review” that the EU commission wants to complete by the middle of 2017. For all those REACH enthusiasts amongst you please find the whole study here: reach/studies/index_en.htm


Italy has formally requested the Presidency to include on the agenda of the next Excise Committee on 30 and 31 May the topic ‘inclusion of all lubes under EMCS’. More and more EU Member States seem to be willing to agree on the inclusion of all lubes under EMCS as tax authorities of certain EU Member States stated that fraud with lubes has allegedly increased in recent years (UEIL will investigate this matter to gather further evidence of these claims). The decision will be taken by qualified majority.

The UEIL position is against this proposal and therefore will increase its outreach activities to secure a blocking minority. Actions are already planned - don’t hesitate to contact us for further information.


The UEIL 2016 Annual Congress of the European Lubricants’ Industry will take place in Berlin (Germany), between 26-28 October 2016!

UEIL is currently preparing this year’s conference programme – would you like to take the opportunity to address over 250 representatives of the lubricants’ industry? Send us an e-mail by 8 April 2016 with: 1) the title of your proposed presentation; and 2) a one-page abstract.

This year’s congress promises to be one of the best ever! - Berlin’s easily reachable from other European countries - Germany being a great driver of the lubricants’ industry - The great programme we are putting together

All of these (and many more) factors will ensure a great turnout at this year’s event. Why not showcase your company’s work? Take a look at the currently available sponsorship opportunities!

For more information on any of the above, contact us:




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