Costs

Costs can be direct costs, for example for the acquisition of toxicological or eco toxicological data in corresponding studies. In 2005 the EU commission has charged the consultancy KPMG to estimate the direct costs of REACH in preparation of REACH. Under the condition that really all studies have to be carried out since no other data from other sources are available from other sources and provided that there is only one registrant, i.e. the costs cannot be shared, the KPMG determined the following figures:

• 1 - 10 t per year: 15.000 €
• 10 - 100 t per year: 163.000 €
• 100 - 1.000 t per year: 282.000 €
• > 1.000 t per year: 323.000 €

Another comment: Since 2005, the year of the KMPG estimation, the catalogue of the studies to be carried out has been modified. This means that the above figures are no concrete figures. They only show the possible amounts which have to be expected by the company who has to apply for registration - and this applies to our company as well.

In view of the costs it is understandable why REACH has the aim to help the medium and small sized companies. Studies can only be carried out in case there is really no other - less expensive - possibility of data acquisition. Such cost effective alternatives are, e.g. computer models. Furthermore the really expensive toxicological and eco toxicological studies with vertebrates must be shared in the registration consortia, the SIEFs. This means the costs are shared among various companies. All other studies can be shared - in case the SIEFs can find an agreement. This means that a lot depends on the cooperation among the SIEFs. Unfortunately it cannot yet be foreseen how the SIEFs will function in the future.

Besides the direct costs which are caused by the studies to be carried out, there are also the indirect costs. For example it has to be considered that the prices for raw materials will increase since the producers who have to arrange for registration will pass on the direct costs at least in part to their customers. To which extent the raw materials will really increase in price and how this will effect on the higher levels of the supply chain - possibly even on the end user - can currently only be roughly estimated. The EU commission assumes that there will be an only insignificant increase in the raw material prices. Industrial associations, of course, disagree. Also in this respect we have to await the future development before reliable figures can be discussed.