IHS Chemical Week


Reach: ECHA's Statistics Challenged by Eugachem in Open Letter

6:32 AM MDT | June 15, 2009 | By GUEST AUTHOR

Below is a letter sent to CW by Eugachem (Cologne, Germany), a Reach services group, in which Eugachem challenges ECHA's statistics relating to the pre-registration phase of the Registration, Evaluation and Authorisation of Chemicals (Reach) program. CW has requested a response from ECHA. Any response will posted as an update to this article.

, May 29th 2009



Dear Sir or Madam,

As we all know the number of pre-registrations and companies that pre-registered substances overwhelmed the bravest expectations of the industry and the ECHA as well. According the news alert dated December 19th 2008, the number of companies, having submitted a pre-registration was approximately 65.000.


According to our investigations this figure does not correspond to the reality.

65.000 is the amount of partyUUID-Numbers (PIN). If one PIN corresponds to one legal entity, then the figure is representative. But this is not the case. On the base of the phase-in substances (EINECS) we notice that one company (Ch. from London) has approximately 9.800 PINs, the company REACH-A. (London) with the same address (!?) has approximately 4.400 PINs. Instead of counting these 14.000 PINs as 14.000 companies, we are dealing with a maximum of two companies. The same is true for the company N. (Amsterdam): 3.459 PINs and the company C.I. (Dublin) with 2.500 PINs. In summary, a small group of only 593 companies makes up for 26.810 PINs, representing 26.810 companies in the ECHA statistics. This number does not include companies that express their status as 'only representative' by a name suffix like (OR).


This fact reduces the real number of companies to less than 38,190 or 58.8% of the ECHA value.

Another remarkable fact is that 6.245 companies pre-registered only one single substance. Can they really be considered as real pre-registering companies? From the fact that the majority of companies in almost any SIEF considers itself as dormant, this could probably be negated.  

Moreover, what is ECHA intended to do with the 279 pre-registering legal entities from the United States (with addresses in the U.S.), 284 from Switzerland and dozens from several other non-EU countries, which were, according the REACH-regulation, not allowed to do a pre-registration, at all?


We kindly ask the ECHA, which has at its disposal a rather expensive IT-System (> €16 Mio)* why it is not possible to evaluate the statistics in a manner that they represent a real picture of the pre-registration activities? A picture that allows for a more realistic estimation of parties involved in the cost sharing and to give a sound map of the European market, both are pre-requisites for strategic decisions.

Is it a technical problem alone, or are there other reasons not to do so?


Dr. M. Urban

European Gate for Chemicals
Industriestrasse 180
D - 50999 Cologne


* (according to ECHA Budget 2009 for 2008 and 2009 together; chapter 210 ICT equipment, software and related training: €11,719,000.00 and item 3411 REACH-IT €5,068,000.00)




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