**REACH Implementation**

Strategy for Communications with UK Industry

**CONTENTS**

1
Introduction..........................................................................3

2
Objectives............................................................................4

3 Target
Audience....................................................................5

4 Communications
Approach......................................................7

5 Communication Channels and
Tools..........................................8

6 Key
Messages.......................................................................9

7 Links with
GHS..................................................................\...10

8
Evaluation...........................................................................11

Annex 1: REACH Communications Plan -- Stage
1...............................12

Introduction................................................................12

Objectives..................................................................12

Target
Audience..........................................................13

Key
Messages............................................................13

\-
General....................................................................13

\-
Specific....................................................................15

Communications Channels and Tools..............................18

List of Trade
Associations..............................................19

**1 INTRODUCTION**

REACH is a complex piece of EU legislation that is going to replace over
40 separate pieces of existing legislation making up the current
chemicals regulatory framework. Its main objectives are improved
protection of human health and the environment, while at the same time
maintaining European industry's competitiveness. The onus will be on
industry to provide information on the substances that it manufactures,
imports, and/or uses, as part of the registration process. This
information will be available up and down the supply chain, and will be
used to ensure improved risk management measures for safe handling of
the substances concerned.

Under REACH, eligible substances that are not registered will not be
allowed to be marketed within the EU. This has implications for both
manufacturers and downstream users. Substances with particularly
hazardous properties will be banned unless industry can show that they
can be adequately controlled, or that the socio-economic case for
continued use outweighs the risks, and authorisations for their use are
granted accordingly.

Indications are that while there are some sectors of industry that are
quite familiar with REACH and its implications for business (such as the
chemicals and pharmaceuticals sectors), others are not so well informed,
particularly the small-medium enterprises (SMEs), either not realising
that REACH is coming into force, or not thinking that it applies to
them. In the worst case scenario, this could result in firms, especially
SMEs, going out of business, e.g. as supplies of key substances that
have inadvertently not been registered are removed from the market.

This strategy sets out the joint approach by Defra, DTI, and the HSE (as
the UK REACH Competent Authority) to communications with UK industry
during the implementation of the REACH Regulation, which is coming into
force on 1 June 2007. The strategy is important for delivering the key
messages about REACH that all sectors industry need to be aware of, to
be able them to prepare appropriately and not miss the major milestones
of REACH implementation.

It begins by setting out the objectives of the strategy, and goes on to
describe its components. The strategy considers the current
communications environment, the needs of key stakeholders, and then
identifies the key communications channels to be utilised. It sets out
the guiding principles by which the communication of key messages will
be achieved, and describes those key messages.

The strategy takes as its baseline the main timeline for the
implementation of REACH, with a number of more detailed communications
plans being developed on the basis of the major implementation
milestones identified in the timeline.

**2 OBJECTIVES**

The strategy has the following objectives:

-   Ensure that all the messages communicated are clear, effective, and
    consistent;

-   Ensure that communications with REACH industry stakeholders are
    effective, appropriate, and timely;

-   Identify and maximise the utilisation of current and potential
    communication channels;

-   Achieve widespread and shared understanding of REACH and what it
    aims to achieve among all audience segments;

-   Facilitate compliance with REACH by communicating roles,
    responsibilities, and enforcement principles to REACH dutyholders

    **3 TARGET AUDIENCE**

There are estimated to be about 100,000 different chemicals currently on
the EU market, of which some 30,000 are in quantities of more than one
tonne per year (i.e. meeting the minimum REACH registration threshold).
The potential number of individual REACH stakeholders is also enormous,
and it is clearly impracticable to identify each and every possible
individual manufacturer, importer, or downstream user that might fall
within the scope of REACH.

The strategy will therefore target primarily broad categories of
industry, such as trade associations, professional bodies, umbrella
organisations, etc., which are better-placed to disseminate information
and key messages about REACH to their members. This offers the
opportunity to engage with large numbers of stakeholders more
efficiently than trying to contact them individually.

This approach does not preclude dealing with individual stakeholders on
an ad hoc basis, and there may even be instances where a few of them are
identified as being key within their sectors, making it appropriate to
communicate directly with them in such cases.

It is important to recognise that different audience segments have
different communication needs, making it necessary for this strategy to
be flexible in identifying the most appropriate means of communicating
necessary information. It is also the case that not all individual
stakeholders will be members of a trade association, or similar, making
it necessary to ensure that there is an appropriate means of
communication that will increase as far as possible the likelihood of
them getting the key messages (for example through trade publications or
other media). It is also important that communications activity should
be worthwhile in terms of efficacy and cost.

There are three main categories of industry stakeholder: manufacturer,
importer, and downstream user. The size of companies within each
category ranges from large multinational corporations, to small
enterprises comprising less than 10 employees. The distribution of this
range varies across Europe, for example in Germany there is a large
chemicals industry consisting mainly of large companies, while in the UK
the industry consists more of small- and medium-sized enterprises
(SMEs).

Larger companies are more likely to have resources dedicated to
communications, lobbying, and monitoring legislation for new duties and
implications/impact on business. On the other hand, SMEs, and in
particular small- and micro-sized companies, are less likely to be able
to devote resources to anything that is not immediately apparent and
pressing; so for example having less awareness about impending
legislative changes until these are proactively communicated to them.
They will also have less time to devote to researching REACH obligations
once awareness is raised.

The European Commission uses the following definitions of SMEs:

  ---------- ------------- --------- ------------- -------- --------------------
             Headcount     **AND**   Turnover      **OR**   Balance sheet total

  medium     \< 250                  ≤ € 50                 ≤ € 43 million
                                     million                

  small      \< 50                   ≤ € 10                 ≤ € 10 million
                                     million                

  micro      \< 10                   ≤ € 2 million          ≤ € 2 million
  ---------- ------------- --------- ------------- -------- --------------------

Recital 8 of the REACH Regulation states that "Special account should be
taken of the potential impact of this Regulation on small- and
medium-sized enterprises (SMEs) and the need to avoid discrimination
against them". It is therefore essential that every reasonable effort
should be made to ensure that UK SMEs fully understand the implications
of REACH for them, both in terms of potential impact on their business
and the provisions within the Regulation to mitigate this as far as
possible. Initial engagement should aim to raise awareness and consult
via representative groups, trade press, and events, with the emphasis
shifting to on-going passive information sources (helpdesk, websites,
guidance) as awareness builds.

**4 COMMUNICATIONS APPROACH**

Although REACH enters into force on 1 June 2007, this is in fact the
start of a prolonged period of implementation, with different provisions
coming into force at different times over the succeeding 15 years. The
communications approach should reflect this process, taking key dates as
milestones around which specific communication plans can be developed
over time.

For industry, the principle milestones concern the various registration
deadlines over the next 11 years. These are summarised below:

-   **1 June 2007**: REACH entry into force;

-   **1 December 2008**: Deadline for all companies intending to
    register a substance to notify their intention to the EU chemicals
    Agency (pre-registration);

-   **1 December 2010**: Registration deadline for
    manufacturers/importers supplying a substance above 1,000 tonnes per
    year, or a CMR cat.1 or 2 substance above 1 tonne per year, or an
    R50-53 substance (PBT/vPvB) above 100 tonnes per year;

-   **1 June 2013**: Registration deadline for manufacturers/importers
    supplying a substance above 100 tonnes per year;

-   **1 June 2018**: Registration deadline for manufacturers/importers
    supplying a substance above 1 tonne per year;

The initial communications focus should therefore be on the
pre-registration period, with subsequent plans being developed for the
individual registration deadlines.

**5 COMMUNICATION CHANNELS AND TOOLS**

Given that it is impracticable to contact individually every possible
stakeholder that might have an interest in REACH, it is sensible to
instead use as wide a range of communication channels and tools as
practicable to present the key messages of REACH that we wish to
disseminate. As previously mentioned, the primary means of getting
messages across initially will be through trade associations, trade
media, and government-sponsored regional business fora.

A variety of other channels and tools are available:

Web-based

-   Defra/DTI/HSE websites, with dedicated REACH pages and links to the
    other websites;

-   History of REACH with Q&A/FAQ

-   Range of background documents providing greater detail on individual
    aspects of REACH, e.g. registration, authorisation, etc;

-   Current events, e.g. HSE Roadshows/RDA events, etc.

-   Links to other relevant websites, e.g. European Commission DGs
    Enterprise and Environment, European Chemicals Agency, UK Competent
    Authority (HSE).

    Email

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-   Newsletter;

-   Helpdesk;

-   Alerts;

-   Consultations.

    Publications

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-   Guidance;

-   Leaflets/posters/flyers;

-   Flowcharts (of REACH processes).

    Events

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-   Trade association meetings/conferences (presentations, mobile
    display stand, and/or useful inserts to delegates' packs, e.g.
    flyers, factsheets, etc.);

-   Government-sponsored regional meetings/conferences.

    Trade press

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-   Submission of articles on specific REACH issues;

-   Full-page advertisements with bulleted key messages.

    National/local media

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-   Adverts in press;

-   Adverts on local radio stations

    **6 KEY MESSAGES**

    ***Principles***

Consistency in messages will help to establish with stakeholders what
REACH is, who it can assist, and what it is intended to achieve. Use of
pre-determined channels for dissemination of messages will help to
ensure consistency.

Care must be taken to avoid complex messaging, as this serves to easily
confuse (especially SMEs that have little time or resources to devote to
receiving and understanding them), and so affects the levels of
participation that stakeholders are willing to invest. All
communications should be as concise and understandable as possible; use
of Plain English will help to achieve this.

A clear and accurate view of REACH should be established through use of
the key messages below in each and every communication opportunity.
Close involvement of the relevant Communications specialist people in
Defra, DTI, and HSE should help to ensure this.

***Key Messages***

The key messages to be communicated to industry will vary both with the
audience to which they are directed, and over time as REACH is
progressively implemented. The detailed messages are therefore set out
in the individual communication plans annexed to this strategy, but an
outline of the main messages is set out below:

-   The purpose of REACH is to improve protection of human health and
    the environment, at the same time as maintaining industry's
    innovation and competitiveness.

-   Entry into force of the Regulation's provisions is staggered over
    the next 15 years.

-   Legal duties will change

-   Emphasis in the early stages on the importance of pre-registration

-   Issues surrounding registration (data sharing, costs, animal
    testing, appointing sole representatives, etc)

-   Issues surrounding authorisation

    **7 LINKS WITH GHS**

The new Globally-Harmonised System (of Classification and Labelling) --
or GHS -- will be introduced across the EU through a new Regulation;
probably in 2008 (the exact date will depend on progress of the EU
legislative process). It is based on the United Nations' system of the
same name, and will incorporate much of the existing EU classification
and labelling system based on the hazardous properties of substances.

Within REACH, there is a requirement for a classification and labelling
inventory to be drawn up, to promote agreement on classifications of
hazardous substances manufactured in, or imported into, the EU. Industry
will be required to submit all its classifications to the new European
Chemicals Agency by 1 December 2010, for inclusion in the inventory. The
provisions of the new GHS Regulation will be phased-in consistent with
the relevant provisions of REACH.

The main changes with GHS will be:

-   New pictograms

-   New hazard and safety phrases, and different corresponding numbers

-   Differently defined and labelled categories

Those principally affected by the changes will be:

-   Workers using chemicals need to understand the new pictograms

-   Consumers purchasing chemicals need to understand the new pictograms

-   Enforcers

-   Emergency services

The target audience for communicating the changes arising from GHS will
be less generalised than for REACH, and probably focus on groups such as
toxicologists, test houses, academies, and toxico-pharmacologists
(rather than workers or consumers).

Additionally, organisations registering new chemicals under REACH will
need to be able to self-classify these based on the new classification
parameters.

The process of harmonising classifications under REACH is closely
connected to the GHS Regulation. Once the relationship between the
Dangerous Substances Directive (67/548/EEC) Annex 1 (the UK's Approved
Supply List), the Classification and Labelling Database, GHS Annex 14,
and the Industry Harmonised and Non-harmonised databases is clear, we
will need to explain it and provide organisations that wish to challenge
harmonised classifications, or produce their own, with support and
advice.

**8 EVALUATION**

In order to be able to show that the communications strategy has been
successful in achieving its objectives, we need to establish appropriate
targets, with measurement indicators that will demonstrate what impact
the strategy has had in getting the key messages on REACH across to
industry stakeholders.

Targets

-   strategy and pre-registration/registration communications plans
    finalised by mid-May

-   attend [?six]{.mark} industry events by end of 2007

-   prepare flyer/poster/factsheet on pre-registration/registration by
    end-June; post on Defra/DTI/HSE websites; print x hard copies for
    distribution; distribute electronic copies for inclusion in
    delegates' packs at industry/other conferences, etc;

    Indicators

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-   Numbers and types of helpdesk calls?

-   Numbers of website hits?

    Impacts

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-   What proportion of SMEs were alerted to REACH and took appropriate
    action as a result?

    Review

-   after [?12 months]{.mark}; assess whether to change things

    **ANNEX 1**

    **REACH COMMUNICATIONS PLAN -- STAGE 1**

**PRE-REGISTRATION AND REGISTRATION OF EXISTING ("PHASE-IN")
SUBSTANCES**

**1 Introduction**

The principal means by which REACH will achieve its objectives of
improving the protection of human health and the environment, is through
gathering of data on the intrinsic properties of all substances on the
EU market in quantities of more than one tonne per year. It will do this
through the process of registration, involving the submission of a
substance dossier providing required information as specified in the
Regulation. Exactly how much information is required, and of what type,
depends on the quantities of the substance that are produced in, or
imported into, the EU per year, and whether the substance is inherently
hazardous.

Registration is staggered over an 11-year period from entry into force
on 1 June 2007 to 1 June 2018, with the largest quantities being
registered first (since tonnage is taken as a proxy indicator for
exposure risk).

Prior to the Registration process starting, there is a pre-registration
period from 1 June -- 1 December 2008, during which notifications of
substances that companies intend to register are submitted to the
European Chemicals Agency. Based on this information, all producers,
importers/suppliers, and users of the same substance are out in touch
with each other to form a Substance Information Exchange Forum (SIEF),
to share data and associated costs in producing a single registration
dossier for the substance.

The purpose of this communications plan is to set out the key messages
that industry need to be aware of in relation to the pre-registration
and registration phases, and the kinds of activities that companies
should be embarking on to prepare for these. The plan identifies the
target audience, and sets out the main communication channels and tools
to be used in getting the messages out.

Further communications plans covering later stages of REACH
implementation will be developed in due course.

**2 Objectives**

The Stage 1 plan has the following objectives:

-   Ensure clear and concise messages about pre-registration, provision
    of information down the supply chain involving Safety Data Sheets,
    and the harmonisation of classification and labelling for CMRs and
    respiratory sensitisers;

-   Achieve widespread understanding among stakeholders about the early
    stages of REACH implementation, and what they need to do to prepare
    and participate

-   Identify the most appropriate communications channels to deliver the
    key messages.

    **3 Target Audience**

The target audience for the Stage 1 Communications Plan will consist of
all UK-based manufacturers, importers, and downstream users of chemicals
that are currently on the EU market in quantities of more than one tonne
per year. This audience will range in size from large multinational
corporations to SMEs employing less than 10 people.

The target audience will be reached through relevant trade associations,
rather than attempting to contact each company individually (see list
below).

**4 Key Messages**

The following key messages are to be delivered:

***General Messages***

-   The purpose of REACH is to improve protection of human health and
    the environment, while also maintaining industry innovation and
    competitiveness.

-   Any business that makes, supplies or uses chemicals in any form will
    be affected by REACH. It is therefore in your interest to
    familiarise yourself with at least the basics of the Regulation, to
    assess the extent to which REACH will impact on your business.

-   REACH will benefit industry by replacing the current patchwork of
    over 40 separate pieces of regulatory legislation with a single
    regime.

-   REACH enters into force on 1 June 2007: if it applies to your
    business, you need to be preparing for registration -- if you do not
    register your substance(s), you will not be able to market or use
    them.

-   Registration of existing ("phase-in") substances is staggered over
    11 years (2007-2018), depending on quantities marketed/used per
    year: make sure you understand how this applies to your business,
    and what information you will need to provide accordingly for
    registration.

-   Registration costs will be finalised in an EU Regulation by 1 June
    2008, with significant savings for joint registrations, and for
    SMEs.

-   The pre-registration period is 1 June -- 1 December 2008, for
    submitting registration intentions to the new European Chemicals
    Agency in Helsinki: do not wait until then to put together the
    necessary information -- start gathering the information now.

-   If you fail to pre-register your substance(s) within the period
    above, you will not be able to register them using the staggered
    'phase-in' periods, but will instead have to register them
    straightaway to be able to continue marketing/using them.

-   There are new requirements for manufacturers/suppliers to provide
    information down the supply chain (Safety Data Sheets), from 1 June
    2007: make sure you are familiar with these to be able to comply.

-   New requirements for the harmonisation of classification and
    labelling of CMRs and respiratory sensitisers at European Community
    level take effect from 1 June 2007 [\[HSE to revise this if
    requirement impacts on industry\]]{.mark}.

-   If you are not sure, then seek advice on technical matters from the
    Competent Authority (HSE): telephone 0845 408 9575 or email
    <ukreachca@hse.gsi.gov.uk> Other sources of help and advice also
    existing, both industry and independent consultants.

-   If you are not in a Trade Association, consider joining one, as many
    are now providing help and advice on REACH.

    ***Specific Messages***

+----------------+----------------+-----------------+-----------------+
| **Issue**      | **             | **Importer**    | **Downstream    |
|                | Manufacturer** |                 | User**          |
+----------------+----------------+-----------------+-----------------+
|                |                |                 |                 |
+----------------+----------------+-----------------+-----------------+
| Pr             | -   Assess     | -   Assess      | -   Check your  |
| e-registration |     your       |     whether the |     inventory   |
|                |     production |     volumes of  |     -- what do  |
| (Article 28)   |     processes  |     substances  |     you use     |
|                |     and        |     imported    |     that will   |
|                |     outputs    |     meet        |     need to be  |
|                |     for        |                 |     registered? |
|                |     substances |    registration |                 |
|                |     that need  |     thresholds. | -   Check that  |
|                |     to be      |                 |     your        |
|                |                |                 |     supplier(s) |
|                |    registered. |                 |     is/are      |
|                |                |                 |     going to    |
|                | -   What       |                 |     register    |
|                |     volumes    |                 |     substances  |
|                |     per year   |                 |     that you    |
|                |     of         |                 |     use --      |
|                |     substances |                 |     especially  |
|                |     do you     |                 |     any that    |
|                |     need to    |                 |     are         |
|                |     register?  |                 |     essential   |
|                |                |                 |     to your     |
|                | -   Any        |                 |     continued   |
|                |     isolated   |                 |     business.   |
|                |     on-site    |                 |                 |
|                |                |                 | -   If any      |
|                |  intermediates |                 |     substance   |
|                |     also need  |                 |     supplied    |
|                |     to be      |                 |     will not be |
|                |                |                 |     registered, |
|                |    registered. |                 |     either      |
|                |                |                 |     begin to    |
|                | -   Check with |                 |     seek an     |
|                |     your       |                 |     alternative |
|                |     downstream |                 |     supplier,   |
|                |     users      |                 |     or consider |
|                |     about any  |                 |     registering |
|                |     smaller    |                 |     the         |
|                |     volume     |                 |     substance   |
|                |     substances |                 |     yourself.   |
|                |     you        |                 |                 |
|                |     produce    |                 | -   Identify    |
|                |     that may   |                 |     the         |
|                |     be vital   |                 |     relative    |
|                |     to their   |                 |     importance  |
|                |     business,  |                 |     of          |
|                |     and so     |                 |     substances, |
|                |     will need  |                 |     and plan    |
|                |                |                 |     for         |
|                |    registering |                 |     feasible    |
|                |     to remain  |                 |                 |
|                |     on the     |                 |   alternatives, |
|                |     market for |                 |     possible    |
|                |     their use. |                 |     future      |
|                |                |                 |                 |
|                |                |                 |   restrictions, |
|                |                |                 |     or their    |
|                |                |                 |     possible    |
|                |                |                 |     removal     |
|                |                |                 |     from the    |
|                |                |                 |     market.     |
+----------------+----------------+-----------------+-----------------+
| Information    | -   Make sure  | -   Ensure that | -   Make sure   |
| down the       |     you are    |     your        |     you know    |
| supply chain   |     familiar   |     supplier    |     what        |
|                |     with the   |     complies    |     information |
| (Articles 31   |     changes to |     with the    |     your        |
| and 32)        |     Safety     |     new SDS and |     supplier(s) |
|                |     Data       |     other       |     should be   |
|                |     Sheets     |     supply      |     providing   |
|                |     (SDSs)     |     chain       |     you with    |
|                |     required   |     information |     from 1 June |
|                |     under      |                 |     2007,       |
|                |     Article 31 |    requirements |     either in   |
|                |     and Annex  |     from 1 June |     an SDS or   |
|                |     II of      |     2007.       |     otherwise,  |
|                |     REACH.     |                 |     or on       |
|                |                | -   Make sure   |     hazardous   |
|                | -   Where an   |     that your   |     substances  |
|                |     SDS is not |     supplier    |     in articles |
|                |     required,  |     provides    |     that you    |
|                |     ensure     |     the         |     are using.  |
|                |     that you   |     information |                 |
|                |     are able   |     required in | -   You should  |
|                |     to pass    |     Article 33, |     provide     |
|                |     the        |     where       |     your        |
|                |                |     hazardous   |     supplier(s) |
|                |    information |     substances  |     and/or      |
|                |     required   |     are used in |                 |
|                |     by Article |     articles    | manufacturer(s) |
|                |     32 to      |     that you    |     with any    |
|                |     users down |     are         |     new         |
|                |     the supply |     importing.  |     information |
|                |     chain.     |                 |     that you    |
|                |                |                 |     identify on |
|                | -   Make sure  |                 |     hazardous   |
|                |     that you   |                 |     properties  |
|                |     can        |                 |     and/or that |
|                |     provide    |                 |     call into   |
|                |     the        |                 |     question    |
|                |                |                 |     the         |
|                |    information |                 |                 |
|                |     required   |                 | appropriateness |
|                |     in Article |                 |     of the risk |
|                |     33 on      |                 |     management  |
|                |     hazardous  |                 |     measures    |
|                |     substances |                 |     set out in  |
|                |     in         |                 |     the SDS     |
|                |     articles   |                 |     provided    |
|                |     that you   |                 |     for         |
|                |     produce.   |                 |     identified  |
|                |                |                 |     uses.       |
+----------------+----------------+-----------------+-----------------+
| Harmonisation  | -   [HSE to    | -   [HSE to     | -   [HSE to     |
| of             |     provide    |     provide     |     provide     |
| classification |     some key   |     some key    |     some key    |
| and labelling  |     messages   |     messages on |     messages on |
| at Community   |     on         |                 |                 |
| level of       |                |    C&L?]{.mark} |    C&L?]{.mark} |
| category 1, 2, |   C&L?]{.mark} |                 |                 |
| and 3 CMRs,    |                |                 |                 |
| and            |                |                 |                 |
| respiratory    |                |                 |                 |
| sensitisers.   |                |                 |                 |
|                |                |                 |                 |
| (Article 115)  |                |                 |                 |
+----------------+----------------+-----------------+-----------------+

**5 Communications channels and tools**

The following communication channels and tools will be used to contact
the target audience:

-   An A4-sized flyer with key messages to be produced, containing the
    key messages on pre-registration, registration, and information in
    the supply chain, [\[by 31 May?\]]{.mark}

-   REACH Factsheet No. 1: providing summary information of the relevant
    provisions and requirements [\[by 31 May?\]]{.mark}.

-   The flyer and factsheet may be circulated electronically to trade
    associations, etc., for onward dissemination to their members, and
    may also be posted on the Defra, DTI, and HSE websites as
    downloadable [(?pdf]{.mark}) documents [\[by 31 May?\]]{.mark}.

-   Advert and/or one-page article to be developed around the
    flyer/factsheet [\[by 31 May?\]]{.mark}, for submission to as many
    trade publications as possible during the course of the next
    [\[three months\]]{.mark}, depending on copy lead-times, publication
    dates/intervals (i.e. monthly/bi-monthly/quarterly), etc.

-   Forthcoming trade events are to be identified as far as possible,
    and the flyer and factsheet to be sent to the organisers for
    inclusion in the delegates' packs.

-   Develop a [\[half-\]\[one-\]]{.mark}day presentation and workshop
    event for local industry, to be added onto a planned series of HSE
    'roadshows' to train regional staff on REACH [\[being held between
    ?May and ?October\]]{.mark}.

    **6 List of Trade Associations**

The following list of Trade Associations will be contacted initially
with the key messages on REACH. As more associations are identified,
they too will be contacted in the same way.

Agricultural Industries' Confederation

Alliance of Industry Associations

ARENA Network

Association of British Pharmaceutical Industry

British Aerosol Manufacturers' Association

British Association for Chemical Specialities

British Cement Association

British Chamber of Commerce

British Coatings Federation Ltd

British Footwear Manufacturers' Association

British Furniture Manufacturers

British Geological Survey

British Hardware and Houseware Manufacturers' Association

British Plastics Federation

British Printing Industries' Federation

British Retail Consortium

British Rubber Manufacturers' Association

British Surface Treatment Suppliers' Association

British Toy and Hobby Association

British Wood Preserving and Damp Proofing Association

Chemical Business Association

Chemical Industries Association

Chemical Industries Association (Scotland)

Chemlaw UK

Confederation of British Industry

Confederation of British Industry -- Wales

Confederation of British Wool and textile Manufacturers

Confederation of Paper Industries

Defence Aviation Repair Agency

Engineering Employers' Federation

European Oilfield Speciality Chemicals Association

Federation of Small Businesses

Federation of Small Businesses (Scotland)

Institute of Metal Finishing

Non-Ferrous Alliance

Packaging and Industrial Films Association

Paint Research Association

Performance Textile Association

Scotch Whisky Association

Scottish Business in the Community

Scottish Committee of the Chemical Industries Association

Scottish Engineering

Scottish Enterprise

Scottish Power

Society of Chemical Industry

Society of Dyers and Colourists

Society of Motor Manufacturers and Traders Ltd

Solvents Industry Association

UK Cleaning Products Industry Association

UK Steel Association

Wood Panel Industries Federation