Cost benefit analysis, and a thorough assessment of all areas required by the registration process including tonnage size and usage, need to be heavily considered due to the substantial cost difference per substance for each of these factors, it was said. These should then be compared with actual realized profits, to gauge whether or not it is the appropriate course of action.
According to Dr. Paetz, a question to ask oneself is if it is or isn’t necessary to register a substance over 10,000 tons. As data on all substances of up to this amount already exists, an adequate assessment can be made. For amounts that exceed this threshold, additional testing, thus additional expenditure would be required.
The use in which a substance is registered for also greatly determines its cost of registration. Should a chemical have a limited probability of exposure, then there are many tests that are not necessary for registration, so to specify a substances precise usage, again saves on the costs of needless further testing.
An additional aspect for consideration, as well as cost at point of registration, is the effect of the registration process on the end product. As a substance is commercialized according to its assigned tonnage band, its uses, and it’s positioning within the market, it can therefore hold great effect on a company’s portfolio.
In regards to her own company, Dr. Paetz said that REACH registration of a substance is not just about regulatory compliance, but is also a business decision too. It is in fact, she said “crucial if companies are to save time and money spent meeting the 2018 REACH deadline”.
This opinion flies in the face of commonly given advice for REACH registration, but it also highlights a key notion of any regulatory compliance procedure: it is first and foremost a strategic decision which implies for companies an acute knowledge of their goals et resources, as well as a thorough analysis of their situation.rs ressources, ainsi qu'une analyse rigoureuse de la situation.
One the same topic, read our advice to industrials for the REACH deadline of 2018.
Article published in The Molecule #14 - June 2014
