REACH in numbers 2023

The past political cycle has been one of the most prolific ever when it comes to legislation with a clear focus on chemicals. Several legislative initiatives related to the Chemicals Strategy for Sustainability (EU CSS) have either been launched or have come to conclusion.

The main aim of these new regulations and directives is to protect EU citizens and the environment from the adverse effect of harmful chemicals by introducing requirements in several sectors and at different stages of the life cycle of products. This growing number of pieces of legislation come with additional requirements in respect to substance monitoring and reporting.

REACH has always been crucial for the Aerospace & Defence industry. Specific chemicals are key to ensure safety and product performance (e.g. durability, reparability & maintainability, upgradeability, reliability). Sustainability criteria are also a strong driver for innovation in the sector (e.g. circular economy, chemical safety).

In 2023, ASD Europe conducted in accordance with EU competition law, a survey to analyse the resources committed to the work on REACH among ASD members. 

ASD collected and anonymised data from 28 companies from the A&D sector which are either direct or indirect members of the association. Overall, the turnover of the companies that responded to the survey is estimated to be around 135 billion EUR, with an overall number of employees of over 390,000. For reference, this survey covered 51.9% of the overall 2022 turnover of ASD member companies reported to be €260.5bn, and 42,3% of the total number of employees reported to be about 921,400 people. 

Out of the over 390,000 employees working for the responding companies, 642 FTE (full-time employees) are reported to be working on REACH matters.

These 642 FTEs make up 0,16 % of the total workforce reported. On average, companies reported that 0.6% of the employees are dedicated to work full or part time on REACH, with numbers going from 1 REACH expert up to above 100 per company. Due to the specific expertise needed to work on matters related to REACH and other chemical legislation, these roles are limited and covered by highly skilled professionals who are also expected to have an overview on the company’s activities and latest regulatory requirements in the EU.

REACH-related costs

The data collection also covered the costs incurred by the surveyed companies linked to REACH activities. These overall costs include aspects such as costs for impact assessments, authorisations, advocacy and participation to trade associations, REACH obsolescence-management, development of alternatives & project management. A more detailed overview will be provided in the sections below.

The overall REACH related costs and investments were reported to be over 293 million EUR per year between 2020 and 2022, i.e. close to 1 billion EUR for the 3 years period. Moreover, companies reported additional costs for Registrations and Authorisations of above 32 million EUR accumulated until 2022.

In general, surveyed companies observed an increasing trend in costs related to REACH implementation in the years 2020 towards 2022.