CIRS releases its REACH registration report for the year of 2010

10 Dec 2010

As the largest REACH only representative in the world, CIRS has published its REACH registration report for the year of 2010.

The report shows that only 5%~10% of Chinese companies have done at least 1 REACH registration before 30 Nov - the first REACH registration deadline. The average cost of registering a substance over 1000t/y is around 50,000 Euros.

The percentage of Chinese companies that have decided to go for REACH registration is significantly lower than we have expected; many companies have chosen to lower tonnage band or postpone registration or cease export simply because the price of letter of access is too high. Although ECHA fee is also high, it is of less concern to many companies.

It is no surprise that most of Chinese companies have chosen to participate in joint submission because they do not hold any data. This leaves them no choice but to buy the letter of access no matter how much the lead registrant/consortium might charge. In this regards, small and medium sized companies are quite vulnerable. Even though it is possible to opt out, in many cases it could be more expensive or too late by the time the cost of letter of access is published.

The report also shows that most of the substances exported in quantities of over 1000t per year, requiring registration are raw materials with low profit-margins.

Finally, the report reflects the vulnerability of SIEF members and small-medium sized companies who depend on letter of access for REACH registrations. Two cases are given.

Case I:

Consortium management companies (some, but not all of them) usually work with big companies which leaves it possible for them to charge an unlimited administrative fee (provided the budget can be approved by those big companies which are in a stronger financial position). In addition, they work together to determine a cost-sharing model and the price of letter of access. A higher price of letter of access, benefits both the consortium management company and big companies that they are involved with. In this business model, SMEs are in a very weak position as the fees and unaffordable and sometimes unwarranted/ unjustified. Meanwhile the larger companies are not keen to ask for a reduction to the price of letter of access sold to SIEF members, as they foresee a greater market if the SMEs eventually fail to compete (fail to purchase letter of access and participate in the joint submission).

Case II:

Member registrants end up paying more for the REACH registration than the lead registrant.

Statement: The primary objective of this report is to illustrate the weak positions of member registrants/SIEF members who depend on letter of access for REACH registration and call for more transparent and fair fee structure. This report does not intend to offend any consortium management companies.


The report has been changed on 6 Jan 2011.

  • Download Full Report [pdf, 500KB]