United States companies exporting any chemical to Europe in a quantity between 1 and 100 metric tons now face a somewhat higher regulatory hurdle. The European Chemicals Agency (ECHA) will be applying rules formerly in place for larger quantities to shipments from smaller companies that were formerly able to request a waiver of some requirements. Companies still have a window to continue export of current products if they undertake a preregistration process one year before the final deadline of May 31, 2018. (Last call to pre-register your low volume chemicals )–ECHA website. Small producers have the opportunity to join a Substance Information Exchange Forum (SEIF) which allows multiple producers of the same substance to share the regulatory burden to a degree. In practice, smaller members of an SEIF often follow and endorse the lead of a larger member. It is up to each producer to make sure that their product is covered by the group’s filings. Given the expense and on-going effort of registering a chemical substance with the ECHA, some producers may choose to have the European marketers of their products handle the registration.

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