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Intermediates guidance will hit SMEs, says industry
ECHA deleted "difficult" section on use of hazard criteria citing a lack of consensus.
The European Chemical Industry Council (CEFIC) and the European Association of Chemical Distributors (FECC) have struck out against the revised REACH guidance on intermediates saying it will have a significant socio-economic impact, especially for small and medium-sized enterprises and the fine chemicals sector in Europe.
Intermediates handled under strictly controlled conditions have reduced information requirements under REACH. Last year the European Commission, ECHA and EU member states decided to revisit both the definition of intermediates under REACH, and to clarify what constitutes strict control. The updated guidance on intermediates and revised chapter on adaptation of information requirements, part of the guidance on information requirements and chemical safety assessment, were published in December 2010.
CEFIC and the FECC say: “The costs for either updating an intermediate dossier or investing in modifications to the installation in line with the new guidance will not be a viable option for many companies, especially SMEs. These companies may be forced to stop their production in the EU or to move their intermediate production outside... Another consequence would be that the subsequent supply chain manufacturing operations would delocalise outside [the] EU, leading to significant jobs and business losses.”
http://www.cefic.org/Documents/IndustrySupport/Industry%20position%20Intermediates%20Finalforpublication.pdf
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