REACH - UEAPME Calls for Re-examination of Rule on Naming Potentially Harmful Substances
Tuesday, 8 November 2016
The European Association of Craft, Small and Medium-Sized Enterprises (UEAPME) has called for the European Commission (EC) to re-examine Article 33 of REACH legislation on substance declarations, as it is 'unworkable' for small companies.
Guido Lena, Director for Sustainable Development (UEAPME), noted that any product containing more than 0.1% by weight of a substance of very high concern (SVHC) means that the company supplying must provide their customers with "sufficient information, available to te supplier, to allow safe use of the article including, as a minimum, the name of that substance". The European Chemicals Agency (ECHA) has also stated that Article 33 could also require a chemical safety report. Mr Lena suggested that, due to the test and examinations involved, and the lack of information from suppliers to these companies, the process would only be "feasible for big multinationals but not for micro or small companies".
UEAPME's Secretary General Peter Faross also wrote to the EC and ECHA, explaining that the provision of a chemical name was "the last step of a very burdensome process", particularly when dealing with complex articles.






