Difficulties experienced by Member Units for Registration of Products under REACH Regulation

摘要

As per the extant guidelines, products exported to European Union (EU) are mandatorily to be registered by May 2018. Many of our members have been, however, experiencing hardships for registration with LOA mainly due to the high cost charged by Lead Registrants (LRs). This has created a dent in their efforts for registration thereby preventing them to participate in the registration process of the products. From the study of data and dossier preparation costs, it is observed that the charges could be anything between 30% and 50% of LOA cost offered. Under the circumstances, many of our units, particularly under SMEs, are finding it extremely difficult for registration of their products. This may affect our exports to EU drastically in future.