Reached the target for the petition promoted by Dye-Staff that denounces the serious situation of Italian SMEs in the chemical industry and calls for immediate action by the competent authorities.

There are 11.317 signatures collected for the awareness campaign launched by Dye-Staff through the Change.org website.
The petition – addressed to the Minister of Health, Beatrice Lorenzin, and to the Minister of Economic Development, Carlo Calenda – started in July and self-powered without financial means, with the help of Word of mouth.

At this point the authorities will listen.

Our requests are:

formal acknowledgment by Italian and European institutions of the objective difficulties that REACH puts on SMEs and the work done so far in the definition of scientific results;
an economic support on the costs for analysis and testing required for registrations;
a simplified path in the REACH registration process for Enterprises that operate with this type of product.

Mrs Elisabetta Gardini, Member of the European Parliament and member of the European Environment Committee, made a parliamentary question to the EU Commission to support the reasons for chemical SMEs and to highlight the unsustainability of registration costs imposed by REACH.

Here is the text below.

Question for written answer E-006451/2017 to the Commission
Rule 130
Elisabetta Gardini (PPE)

Subject: Sustainability of costs of registering dyes/colourings for SMEs

31 May 2018 will be the final deadline for registering with the European Chemicals Agency (ECHA) all chemical substances that are manufactured in or imported into the European Economic Area within a range of 1 and 100 tonnes per year. It is the final registration deadline established by Regulation (EC) No 1907/2006 (REACH Regulation) for existing chemical substances.

Can the Commission answer the following questions:

– Is it aware of the difficulties that small and medium-sized enterprises operating in the dye/colouring sector are facing with regard to the sustainability of registration costs?
– Will it take any measures to facilitate such registration, together with access to and sharing of data?

Thanks to a study conducted by RPA with a the contribution also of Centro Reach and some of Dye-Staff members, on 3rd October, ECHA, the European Chemicals Agency, declared in a press release (as outlined below) that it had realized the difficulties of SMEs with regard to REACH’s registrations and negative impacts on European competitiveness and employment. The Agency then announced that it has started looking for solutions to help the SMEs involved. “It’s a big step forward, after so much silence! We are confident that by a few months before the 2018 deadline, we can find a way out, “said chairmen of Dye-Staff’s, Marco Lariccia and Cesar Knebel.

SMES FACE FINANCIAL CHALLENGES REGISTERING UNDER REACH

A recent study on the segmentation of the small and medium-sized enterprise (SME) market confirms uncertainties regarding the SMEs’ intentions to register their substances by the 31 May 2018 deadline.
The main hurdle seems to be the cost of data needed for registration. It also makes recommendations for the Agency on how to convince SMEs to use and benefit from the ECHA Cloud Services.

Helsinki, 3 October 2017 – The study, commissioned by ECHA, gathered insights on the SME market structure, mainly for marketing the recently launched ECHA Cloud Services giving SMEs online access to IUCLID. It also collected information on the SMEs’ intentions to register by the last registration deadline on 31 May 2018 and analysed issues these smaller companies face in the registration process.
Three types of SME market segments were introduced, based on the SMEs’ role within REACH and their attitudes towards registration:
1. Product builders and suppliers that manufacture and import substances and have direct registration duties. This segment is further divided into companies that have a good understanding of REACH and have set aside resources for registration; companies who are not sure whether or not they have to register; and SMEs who fear losing their businesses as they cannot afford to register.
2. Advice givers that assists and guide the first segment.
3. Experts, who are either service providers or in-house experts. Among these segments, the key finding is that while most SMEs (95 % of the respondents) are aware of their duties, a sizeable number struggle with the high costs of registration, in particular, the costs for letters of access and participating in the substance information exchange forums (SIEFs). As a result, a proportion of companies are rationalising their substance portfolios and finding alternative solutions, for example, reconsidering their production and import volumes to remain below the one tonne per year threshold that triggers registration obligations.
Regarding the ECHA Cloud Services, ECHA will have to carefully consider how to improve its stakeholders’ perception of privacy and security of the service.
The study proposes actions for ECHA, the Member States and the European Commission to help SMEs register by the 2018 deadline and to prevent the negative impact of their failure to do so on European competitiveness and employment. These actions include, for example, mobilising resources to support SMEs in their registration obligations, and helping SMEs challenge the SIEF costs if necessary. It also recommends making information on funding more easily available. The full list of suggestions can be seen at the end of the Executive Summary.
ECHA has already started looking into solutions that could improve the situation for struggling SMEs and is discussing them with the Commission and different industry stakeholders that take part in the Directors’ Contact Group. This group was set up in 2010 to monitor the overall readiness of companies and to identify and resolve issues of concern relevant to REACH registration.

https://echa.europa.eu/en/-/smes-face-financial-challenges-registering-under-reach

Dye-Staff launched this petition online https://www.change.org/p/beatrice-lorenzin-aiutaci-a-salvare-le-piccole-imprese-e-i-lavoratori-che-fanno-grande-il-made-in-italy

The purpose of this petition is to prevent the closure of many SMEs and loss of jobs of their employees: to ensure that rules are respected at sustainable costs.

Italian fashion is going to loose its colours due to the risk that Italian SMEs supplier of the this sector are likely to close their activities, forever. The reason for all of this is that the registration costs for these dyes according to the European Regulation REACH (EC 1907/2006 – Registration, Evaluation, and Authorization of Chemicals) are too high for SMEs.

REACH REGULATION ESTABLISHES CORRECT OBJECTIVES FOR THE PROTECTION OF HEALTH AND ENVIRONMENT AND THE COMPANIES WHICH LAUNCH THIS APPEAL INTEND TO RESPECT EUROPEAN REGULATION.

REACH Regulation requires that all companies producing and importing chemical substances have to prepare a technical dossier for each substance for “Registration”, specifying information about intrinsic – chemical-physical, toxicological and ecotoxicological properties – and on the uses of chemicals substances.

THE PROBLEM IS THAT THESE REGISTRATIONS HAVE AN AVERAGE COST OF € 30,000 FOR EACH SUBSTANCE (FOR SUBSTANCES WITH A PRODUCTION/IMPORTATION VOLUME OF MAX 10 TONS PER YEAR) IF THE TESTS ARE PERFORMED IN A TRADITIONAL WAY AND THEY ARE MUCH HIGHER IF THEY EXCEED 10 TONS/YEAR.

The fact that a typical SME in this sector has on average some hundred substances subject to single registration and that there is need to register as many substances as possible in order to remain competitive on the market, it becomes evident that such costs are not sustainable for them.

The risk is the closure of many SMEs and the loss of several hundreds of jobs they generate. This is a very Italian problem considering the peculiarity of our country, leader in the Eurozone for the value of SMEs (over 95%) and the undiscussed leadership in Europe for textile.

SMEs in this sector are not able to cope with these costs concerning the application of the Regulation in its’ present concept which is seriously threatening their survival and their occupation.

Italy is the world’s leading textile exporter, luxury clothing and accessories, and second overall in the fashion sector.

With a share of 41% Italy is the first country in Europe for gross production value, followed by Germany with 11%, Spain with 10%, France with 8% and Great Britain with 7%. Perhaps it is the sole sector where the first country is 30 points higher than the second.

Thus without forgetting to mention the international record of Italian leather, which accounts for 65% of European production and 19% of world production.

These figures are generated by many small and prestigious manufacturing districts throughout Italy: Prato, Arzignano, Como, Biella, Bergamo, Santa Croce sull’Arno, Solofra, Naples.

The SMEs launching this petition did not limit only to warn of this almost inevitable decline but have reacted by investing their limited resources in the research of Mario Negri Institute in Milan, where researchers – perhaps the best in the world in terms of knowledge in dyestuff sector – work on methodologies and alternative applications to those on animals.

A large database has been created, thanks to the collaboration of Institutes, Universities and Governmental Organizations (ie American and Canadian EPAs) to find useful data and studies for the evaluation of dyes.

We therefore ask:

1. formal acknowledgment by Italian and European institutions of the objective difficulties that REACH puts on SMEs and the work done so far in the definition of scientific results;
2. an economic support on the costs for analysis and testing required for registrations;
3. a simplified path in the REACH registration process for Enterprises that operate with this type of product.

We need your signature

• to defend jobs
• to defend SMEs that work well and honestly
• to defend our Made in Italy!

(photo Angelo Amboldi)

Federchimica, Sistema Moda Italia, Unione Nazionale Industria Conciaria and Camera Nazionale della Moda Italiana have drafted a Position Paper to support the reasons of Dye-Staff Cooperation and its companies.

This is an important supplement to the Italian contribution to the European debate on the implementation of the REACH Regulation (EC 1907/2006 – Registration, Evaluation and Authorization of Chemicals) and its effects on the SME dye industry system and its negative impacts in the Made in Italy’s fashion chain.

We ask a formal recognition by the national and European institutions of the objective difficulties that REACH puts on SMEs and of the work done so far in the definition of scientific results by companies that are part of Dye-Staff with the collaboration of the Mario Negri Institute for Pharmacological Research.

There is an urgent need for a decisive public initiative aimed to an economic support to the costs associated with the analysis and testing required for recordings.

Finally, it is vital to have an easier path in the REACH registration process for Companies that operate with this type of products.