Document NjoYee1BXvxRv9DdnayRLrZb

= 21 MarcMhin20u2t3e,s BorfustsheelmseReentaiinssgawnictheCHefoitce,l S(\rEeudnuiPteduaand S19MEs10o5n0 tBhreusRseElsA)CH Revision Cate Trmsparency regis n Gas70142325. | -- SMEunit(eTdransparency register n 555208J5115735 SMEs representatives gaubergroup, Germany), IRRteil Chemie cals Cooperative. Hungary). PinoPine, Portugal), EE Don. J ChemCon, Netherlands). Solvachem, Polar) (Cromoge `nia Units, spani)| ro vicon Belgium), European Commision- DG GROW Bozzetto Group, Italy) EE sohs and opportunities faced bs SIES with current REACH requirements REACH revision `The representatives from DG ENV and DG GROW outlined the envisaged changes under the REACH revision. DG ENV explained the main changes to registration requirements, These are noably new information requirements on endocrine disruptors and additional information requirements for low-tonnage substances, the obligation to register certain polymers and to produce Chemical Safety Reports (CSR) for the 1-10 tonnage band, as well as the introduction ofaMixture Assessment Factor (MAF) for tonnages above 1000 tonnes sear. Regarding authorisation and restriction, DG GROW. explained that amendments will potentially include the extensionofthe Generic Risk management Approach (GRA) to new hazard classes and some professional uses, and the introduction of the Essential Use Concept to the decision procedure for derogations. DG GROW also preseated possible measures. to improve enforcement, especially concerning online sales and custom controlsof imports `The concerns expressed by the SMES relate in particular to the new registration requirement for polymers and the requirement (0 prepare Chemical Safety Reports for all hazards in the 1-10 tonnage band. Concerning the push for New Approach Methodologies, Cefic noted that these methodologies requireexpertise that SMES often do not have and suggested that support for SMES on this aspect would be needed. How to help SMEs Proposals on how to improve the general business environment for SMES comprise more EU efforts to ensure access {0 clieaper energy, securing access to raw materials and EU funding. Legal predictability as well as aligning different pieces of legislation were also suggested as key factors o support SMES. `Some representatives also called for a review of the EU definition of SMES, possibly introducing an intermediate level between SMEs and large companies, which was however not supported by SMEunited, and consider revising the EUR 50 million turmover threshold that dates back to 2003. To be noted that these suggestions do not fal specifically in the remit of the REACH Regulation. Regarding REACH registration requirements, the following suggestions were made: allowing foar read-across for similar substances; considering the real tonnage insteadofthe tonnage band or sizeof the company to allocate the sharesofregistration costs; lower information requirements for higher tonnages. Concerning possible support by ECHA and administrative procedures, SMES representatives sug`gested that ECHA could organise annual trainings for companies on how to use IT tools (IUCLID, CHESAR). SMEunited noted thata translation of IT tools for registration would not be necessary. In viewofthe REACH revision, SMEs prefear clear and simple legislation which would make comprehensive later guidance obsolete. `SMES representatives also asked foar staggered approach for the registration of polymers, `The attending Commission representatives listened to the concernsof the SMES and encouraged them to provide input on issues and proposals, in particular on substitution workshops and the registration of polymers via Cefic 2