Pointed comments by outgoing CEFIC (European Chemical Industry Council) president Squinzi on REACH here.  One highlight on the 2 billion euro cost since 2007:

“This is within the initial cost range for the whole of REACH, yet we have only passed through the first registration deadline. This points to two things: firstly, the costs are high; secondly, as smaller organizations enter the REACH processes we must find ways to eliminate all unnecessary costs. This can range from highlighting the big cost items and amending the legislation to simplifying the procedures at the implementation phase. Here, we look to the agency to review any activities which we're not explicitly required by the legal text."

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