With the end of the year comes the season of budgets of all kind; whether these are private as your Christmas shopping budget, or the money spent on projects we have to report. REACH activities are no exception, even if it is usual to hear that Compliance is a mandatory cost whatever the amount is.
I haven't heard yet of any industry actor claiming it made money directly thanks to REACH (speaking of Manufacturers, Importers and Downstream Users here; obviously not true for consultants and service providers).
But still, it might be interesting to have a deeper look inside the money ins and outs for REACH, and identify (in)direct incomes or benefits.
What REACH costs
Direct debits will mostly be linked to:
- Consortium fees
- External consultants (chemical Dossier portfolio management, toxicologists, IT systems set up and maintenance )
- Third parties dealing with confidentiality issues, only representatives
- Registration fees
- Dedicated staff
- Travelling costs
- Information providers
- Training sessions
- And more...
These costs are easily identifiable, which is usually the reason why Compliance is considered a hole in the pocket. Nevertheless, there are also plenty of benefits behind the scene, less shiny than direct income but having substantial impact on the final balance that should be considered.
Benefits from REACH
- The first and most obvious of these benefits is, of course, the license to operate.
- Some small industry players may have disappeared, stopping some low-value activities and therefore putting bigger players at an advantage.
- In keeping with the above, you may have stopped some low-value activities, having then freed resources to be reassigned to more productive activities, creating more capacity and more income.
- Similarly, new arrangements/opportunities may have been unveiled leading to a greater focus on core business and the development of new activity, such as becoming exclusive importers or suppliers. For example, becoming an Only Representative so that your customers do not need to register and can stop their production that was not part of their core business.
- REACH must be considered as a first step in a new pavement of new regulations and, therefore, considered as an investment.
Indeed, money was invested in REACH data and experience. That investment is highly valuable now that worldwide regulations are spreading around the globe:
- Many studies can be re-used for other regulatory schemes (depending of what was agreed at SIEF level).
- Related side benefits are your Regulatory team requires less training, the team is already staffed, the organization is ready to go global.
- In the end, it is continuous market that is ensured in all these countries.
- The studies conducted (experience from consortium) showed more than one a positive outcome. Some substances were in the end less toxic than initially thought. The classification was based on old assessments and reports made when methods were less precise. These new findings lead to opening the substance to new applications and new markets!