Partnership in the Supply Chain with the Chemical Industry The planned reform of EU Chemicals legislation, the REACH procedure and its impact on leather production
Dr. Alois Püntener Quality and Environment
Summary The central instrument of the new European chemicals policy (EU White Paper) is to be the REACh system, which stands for Registration, Evaluation and Authorisation of Chemicals and will apply to both existing and new substances. The system imposes on chemical producers, preparation formulators and users in both trade and industry sweeping obligations to furnish proof and documentation. The aim being to improve safety for both humans and the environment in connection with the handling of chemicals. REACh was presented in May 2003 and after a six week consultation time modified in September 2003.
But this commendable objective can scarcely be achieved by the measures proposed because they entail loss of competitiveness for the processing firms such as tanners operating in the EU. The associated personnel and financial costs are so high as to be beyond the economic means of many companies, particularly small and medium-size firms (SME´s). Innovation strength and competitiveness of the EU businesses becomes threatened. If this future policy is not to become a pitfall for the European chemical and leather industries, care must be taken to avoid creating an additional competition disparity between EU and non-EU countries. REACh should be revised and re-drafted to take into account the following:
REACh must be so framed as to be implementable for small industry segments like the leather producers as well.
REACh must more strongly encourage research and devolvement work by a simplified and economical REACh procedure for new and low volume chemicals.
The same regulation for chemicals should also be put in place outside the EU and guaranteed within the framework of the WTO (World Trade Organisation).