ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL
Chemicals, metals, mechanical, electrical and construction industries; Raw materials
Chemicals - REACH
Brussels, 26 June 2012
EPG Sub-Group On REACH
Meeting on 5 July 2012
Working Document
ER-03-05A
[PUBLIC]
Agenda Point: 5.A Action: For Discussion
Subject: Strategic approach on SME awareness raising and support
1. Background
Less than 10% of registration dossiers were submitted by SMEs for the 2010 deadline[1]. This share is expected to increase until the 2018 deadline. As there are over 20 million SMEs in the EU they represent the highest share of entities involved in REACH. Out of this about 64.000 are estimated to be manufacturers of chemicals; others are downstream users, distributors or other companies[2].
Around 92% of SMEs are micro enterprises with less than 10 employees, which are often run by the founder. He determines the policy and the strategy, which are very often restricted to the region where the enterprise is located. The language skills of employees can also be limited. Within the region those enterprises are frequently members of existing local or regional organisations, networks and chambers. These enterprises rely on local and regional sources of information including news media[3].
Due to the complexity of some REACH-provisions, SMEs have specific needs as they often face very limited resources in their daily routine as well as limited REACH-related knowledge. In addition there are concerns that some SMEs may even not be aware of their general obligations under REACH. As in 2018 a high number of SMEs is expected to have fulfilled the obligation to register their substances, this is a matter that has to be closely observed.
The Commission, ECHA, Member States and different stakeholders have invested considerable resources to inform companies in general, but also SMEs in particular, about their obligations. So far the work has been fruitful and the 2010-deadline was a success. However, it has been observed that it is a challenge to draw the attention of new, until now not involved companies on REACH. As reported for example by enforcement authorities in Member States the knowledge in companies varies from “quite good” to “never heard of it before”.[4] Information tools and strategies which were successful so far seem not to be as efficient to widely reach those companies. Therefore there is an urgent need to adapt existing tools and to identify new strategies to approach such companies and their specific demands for support.
2. Overview on useful support developed so far
The majority of supporting activities and tools were so far not focusing in particular on SMEs, but proved to be useful for them as well. However, numerous initiatives focusing specifically on SMEs can be reported.
The Commission has intensified its internal communication to more effectively reach "non-chemical" sectors to increase their awareness on REACH and SME related issues. For this purpose a small info package has been distributed, including also a few slides, which can be easily integrated in every presentation when talking to potential multipliers. In general, the Commission is giving a stronger focus on outside communication organising workshops and conferences, but also contributing to other events with speakers or panellists. For that the cooperation with member states (e.g. through CARACAL, EPG Subgroup REACH, HelpNet) and other relevant stakeholders (e.g. through DCG) has been intensified.
Existing networks such as the Enterprise Europe Network (EEN) or the Small Business Portal (SBP) are being used for dissemination of REACH-related information and awareness raising. This includes articles in newsletters and participation at meetings, workshops as well as exhibition stands. Furthermore, the EEN is offering its support to implement REACH as for example in case of the Italian "National Implementation Plan on REACH". The European Regional Development Fund (ERDF) is also supporting REACH-related issues as for example developing IT-tools for the information in the supply chain or mentorships for regional REACH implementation projects[5]. The European Investment Bank (EIB) offers grants for the purpose of REACH compliance in particular to SMEs[6]. In the latest Framework Research Programmes FP6 and FP7 projects related to REACH and SMEs were and are supported[7]. Projects can be also supported by the European Social fond (ESF) as for example the REACH-Net in Germany[8].
ECHA as the responsible agency for REACH has provided a wide range of different support initiatives related to REACH. Most of the support is aiming at all companies and is not in particular SME tailored. However, SMEs can use most of this information as ECHA has intensified its translation work to offer guidance and other relevant tools in all official EU languages and also a multilingual REACH & CLP terminology database "ECHA Term". ECHA has prepared a SME section on its webpage[9] as a contact point for SMEs and has invited stakeholders to distribute this link. Furthermore, ECHA has recently established a cross-directorate task force coordinating SME-issues and intensified its cooperation with its accredited stakeholders offering them a special online news-page.
The involvement of Member States' authorities in raising awareness varies across individual Member States (MS). The national helpdesks play a central role in providing support, organising events and keeping a link to ECHA-resources (e.g. via HelpNet). The Competent Authorities (CA) as such in general have the political and strategic responsibility to implement REACH. In many MS the CA share co-responsibility with other authorities such as ministries responsible for economy or industry and/or labour-safety and/or environment. Those often play a very important role, namely in case of Italy or Austria in providing financial support and strategic (co-)steering for REACH implementation projects.
Industry associations have been so far very intensively supporting implementation of REACH on a European, national or regional level. The commonly used tools are webpages and printed publications, guidance of general and specialized nature, workshops and other events, training and industry helpdesks. Some of the key industry stakeholders such as UEAPME, FECC, CEFIC and Business Europe are particularly involved in the ongoing awareness raising considerations for SMEs. In many countries chambers of commerce play an important role in providing REACH related support.
3. Two main focus groups for potential future support
For the development of an additional support and communication strategy, different actors stated numerous proposals and ideas. Many proposals suggested well-tried approaches including further short leaflets or short guidance documents on specific problems, web-appearances targeting SMEs, webinars, posters and national/regional events. Very important is also that this support is offered in all relevant official languages and in an understandable, not too technical "SME-proof" language.
These offers certainly are fine for companies which are incorporated into existing structures, e.g. members of national/regional chambers or other associations which regularly get information on REACH (="SME-in"). Such companies are aware that REACH exists independently of considering it highly relevant for them or not. In case they "overlook" an obligation there is someone competent in their closer environment who can offer them support. Individual problems of SMEs can be expected to be solved in a satisfactory way or brought forward to relevant authorities. There is a strong indication that most existing means of communication primarily reach this type of SMEs.
The second group of SMEs are unaware of REACH and/or are not involved into any networks (="SME-out") and for this reason are hard to reach. Despite the wide range of support offered and all the communication activities going on, these companies did not take notice of REACH or they do not consider REACH being relevant for them. These companies have proven not to be reachable with specialised REACH information. Therefore it should be considered to access them via more general approaches as for example using mass media or new media or in events of a more general nature not only REACH.
General newspapers were reported as not being an effective route, but national economic and financial press seems to be adequate[10]. Sectoral periodicals could be also helpful. With this in mind, it would be useful to have prepared info packages in the relevant languages. Sectoral events and fairs could be for example an opportunity to place very short and general messages on REACH. Printed material with diverse topics could be filled with brief REACH information. Such approaches would focus on waking readers' interest and preventing a "REACH-overflow" at the same time.
The internet could also be used more efficiently for REACH awareness. Existing Commission pages on mainstream social-networks as for example the appearances of ENTR[11], the SME-envoy[12] or the EYE[13] could be arranged to include some basic REACH information. It could be also considered to switch ads with brief REACH-statements on popular general pages as for example search engines, but also putting short REACH clips online.
A general observation is that countries with traditionally strong chamber organisations have a high penetration level of their national/regional campaigns. Examples from Italy (a national plan is embracing 24 chambers, 10 regions, 6 industry associations and 15 others for a joint effort in implementing REACH)[14], France (chambers are providing tailor made support also for very specific problems as for example finding substitute substances)[15] and Austria (approx. 150 REACH experts were trained in 9-day trainings)[16] support this observation. Many chamber organisations started already early with regional events and/or roadshows about REACH, although it is also under these circumstances not possible to reach all "SME-out" companies.
The following table contains the so far identified means for support and awareness-raising. The proposals include the potential addressee(s) to apply the proposal and which group of SMEs – "SME-in" or "SME-out" – could be reached with that measure.
Task / Who? / SME-in / SME-out /
SMEs organisations to link up to ECHA’s website / EIA, NIA / x
Run surveys to identify specific SME needs in particular for 2018-deadline / EIA, NIA / x
SME-leaflet on relevant activities (DU-role, report on uses, application of RMM, OC in SDS, substances in articles notification) / EIA / x
Periodic training courses for consultants and companies / NIA / x
List of experienced consultants / NIA / x
Support events/seminars especially in countries with less chemical industry / ECHA, EC / x
Involve journalists at local level / ECHA, EC / x
Contact all national industry associations outlining their support plan for SMEs / ECHA / x / x
Provide case studies of successful SMEs being a LR from 2010-deadline to convince others taking up this role / ECHA / x
Provide briefings for journalists covering SME issues in general press / ECHA / x
Provide briefings for specialised press / ECHA / x
Information sessions at local level / MSA, ECHA / x / x
Brochures raising awareness on REACH in local languages / MSA / x
Liaise with authorities having direct contact with companies to provide information on REACH to SMEs and importers of articles and mixtures (enforcement, chambers of commerce, labour inspectors, customs) / MSA / x
National/regional awareness raising campaigns with trade unions and chambers of commerce / MSA / x / x
Use general events and publications to disseminate brief REACH info / ECHA, MSA / x
Use online social media to disseminate brief REACH-info / EC, ECHA / x
Switch online adds with brief REACH-info / ECHA / x
Local/national television and/or radio campaign / MSA / x
Investigate SME needs in REACH Review / EC / x / x
Identify one person per country to provide telephone contact in national language (IUCLID, REACH-IT, etc.) / ECHA / x
Support on SIEF communication (e.g. sending mails to pre-SIEF members, to facilitate communication in REACH-IT; download of pre-registrants; sending alerts to SIEF where no SFF/LR is appointed yet) / ECHA / x
Support intermediaries in chemical and non-chemical sectors (provide relevant information, organise briefings and webinars) / ECHA / x
Use HelpNet to coordinate SME support and awareness raising / ECHA, EC / x / x
Publish relevant “Guidance in a nutshell”, posters, videos / ECHA / x
Train trainers through Europe Enterprise Network / MSA, ECHA, EC, NIA / x
Organise joint events at regional or local level involving helpdesks and national federations / MSA, ECHA, EC, NIA, EIA / x / x
Organise joint initiatives between national/regional authorities to support small companies (e.g. VLARIP or WALRIP - Flanders and Wallonia implementation projects) / MSA, ECHA, EC, NIA, EIA / x / x
Explore the use of European funds such as the ERDF, EIB, FP7 or the ESF / MSA, ECHA, EC, NIA, EIA / x
Organise a joint campaign with the European Chemical Regions Network (ECRN) / MSA, ECHA, EC, NIA, EIA / x / x
MSA (Member States' Authorities); NIA (National Industry Associations); EIA (European Industry Associations); EC (European Commission); ECHA (European Chemicals Agency)
4. Conclusion
During the preparations for the first registration deadline, the main focus group of REACH-implementation was industry manufacturing or importing substances in high volumes. As other deadlines approach, the production volumes relevant for registration are decreasing. With that and, in particular, until the last phase-in-deadline in 2018 more and more SMEs are expected to be involved in registration. SMEs are involved in REACH obligations also in other roles as downstream users or distributers. The awareness of their obligations is crucial for the functioning of the whole REACH system as both, the user and the distributor, play and important role for example in the communication in the supply chain.
SMEs are not as well organised in associations as larger industry players. They are often involved only into national/regional networks or not part of a network at all. In particular, those not involved are frequently not informed about REACH and its provisions. This analysis identifies two groups of SMEs: "SME-in" and "SME-out".
Demands of the "SME-in" can be met with existing measures and strategies, despite possibly needing some adaptations. In general, this group is of less concern, since it is already on the radar. The topics concerned are known so far and are more of legal or technical nature. The communication may not always work to its optimum extent, but it is established and can be with some effort further improved.
The second group, "SME-out", is causing more concern, as it can be concluded that all past information efforts had no impact on these companies. From that perspective it seems of no use to again elaborate very general information material as this already exists sufficiently and in excellent quality. This material has to be channelled to the right recipients. In that respect national-authorities, the HelpNet, industry-associations and chambers should be activated to once again start an intense information campaign and also integrate information about REACH in everyday's work. Articles in general newspapers or even national television channels could be as well a good approach. Also the use of web-based media could be applied more intensively as for example with ads on widely used webpages.