Product category:
Cleaning media and cleaning systems
News Release from: Enviro Tech Europe | Subject: REACH and chemicals prices
Edited by the Manufacturingtalk Editorial
Team on 28 February 2007
REACH will effect chemicals prices
One of the most radical changes to be made to the European chemical industry is 'Registration, Evaluation, Authorisation and Restriction of Chemicals', reviewed by Derek Carpenter.
The most radical change to affect the European chemical industry in twenty years arrives on June 1st 2007 The estimated cost to the industry over eleven years to complete the exercise is EUR 2.3 billion! It comes as a direct result of European Parliament legislation called Registration, Evaluation, Authorisation and Restriction of Chemicals
This article was originally published on Manufacturingtalk on 7 Apr 2008 at 8.00am (UK)
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(REACH) Part of the intention is to standardise the current broad range of EU Directives and regulations, together with existing and confusing rules for 'existing' and 'new' chemicals.
A single system will be created for both.
The two most important aims are to improve protection of human health and the environment from the risk of chemicals while enhancing the competitiveness of the EU chemicals industry.
Further reading
Be vigilant when making degreasing choices
While users are keenly interested in the advantages of process cleaning, they can be confused by the amount of misinformation that seems forever presented to them, writes Derek Carpenter.
Aerospace again favours solvent cleaning
Rigorous performance testing has enabled a solvent cleaning product to become the favoured choice for former aerospace manufacturing users of the carcinogen trichloroethylene.
Updating the use of trichloroethylene in factories
On the regulated use of trichloroethylene in European industry, Derek Carpenter writes that he had never seen more confusion resulting from the guidance given to users.
Inevitably there becomes a need to create an agency to oversee REACH and this will be the European Chemical Agency.
(ECHA).
The surprising choice for its location is Helsinki, Finland, and the European Commissions original budget for the agency was EUR 359 million.
This estimate has more recently increased to EUR 1,189 million.
Yes, a further EUR 829 million, which represents an increase of 230%! As if that were not bad enough the cost of a small firm registering an individual product in the 10-100 tonnes category rises more than 500% from EUR 400 to EUR 2443.
Registering a product in the 1-10 tonnes category rises from EUR 400 Euro to EUR 900.
(See Proposed REACH Registration Fees).
Unless sufficient data is provided a product will not gain registration and in such circumstances would cease to be available to users.
Article 5 of REACH states: "Substances on their own, in preparations or in articles, shall not be manufactured in the European Community or placed on the market unless they have been registered under REACH." (See REACH Registration Timeline).
Registration is determined by tonnages and is split into four groups and three different timescales with differing requirements for data.
(See REACH Registration Groups).
This presents an enormous amount of work, cost and challenge.
From a simple and understandable principle has sprung a costly and complex system.
Like many people I am left with a number of questions, the answers of which I can only guess at.
You may agree or disagree with my observations but such questions demand consideration.
* Will there be losers? - Inevitably there must be.
Companies with a diverse product range may well consider an individual product below 100 tonnes per annum as being insignificant and therefore not seek registration.
Hence the product will be lost.
If that same product is an important component for other products they may be lost too.
In the end the product user may find it difficult to find a suitable alternative.
The EU has estimated that 2% of existing products may be lost to the overall market.
Given their estimates on costings so far it is difficult to be confident.
* Will EU Companies be competitive? - The stronger companies are potentially likely to pick up what is lost by others.
In a sense some may see the investment as a means of shrinking competition.
In my experience lack of competition leads to higher market prices.
Importers will still need to register but are likely to benefit from lower manufacturing costs outside the EU.
I cannot imagine China, India or Japan missing an opportunity.
* Will the EU retain foreign manufacturers? - Continuing high levels of regulation and potential cost rises is not an ideal formula for many companies.
Many view regulation as lacking practical sense and it may lead to relocation outside the EU for some.
* Is the burden of cost fair? - It is certainly reasonable that the chemical industry have a burden of responsibility to provide good advice.
My fear is that REACH allows the EU to substitute science which has been a previous obligation with mere interpretation to create regulation.
It is widely felt, and I include myself here, that a 'precautionary principle' approach has led to major failures under the old system with court cases pending to test the validity of EU regulation.
Even more fearful to me is that REACH appears to give no right of appeal if mistakes are made.
Can you imagine British industry allowing such powers to a UK Government? Even more relevant, can you imagine UK law taking your right of appeal away? * Could it have been worse? - In a word, yes.
We are fortunate in the UK that the Chemical Business Association (formerly BCDTA) has worked tirelessly to gain concessions from the EU for a more workable REACH.
You can find their advice at www.chemical.org.uk * What can be expected for the future of the chemical industry? - I would think more of the same.
The chemical industry and manufacturers of finished and semi-finished products have always been a "cash cow" to regulators, who it has to be said have been very productive in keeping themselves employed.
Sadly, the chemical industry is unlikely to gain the commendation it deserves for its continued responsible care and achievements in the last 20 years.
I sincerely hope that a consequence of REACH will not see the industries research and development budgets reducing.
As I speak to many senior managers in the chemical industry many are grateful that they retire in less than eleven years and wonder who would choose the industry for a career now, when it appears the EU regulate regularly but appear reluctant to listen.
You would think that if the onus was entirely on the industry to secure the data to merit registration the EU would regard and respect the expertise of those providing it.
There is no utopia.
A European Community may on the surface give the impression of acting for all but a quick trip around Europe leaves me wondering if regulation is equitable for all.
Risk assessment has empowered us all to work for improvement but hard as many have worked, there is always the feeling that the 'interpretation' of someone else will ignore real practicalities and therefore frustrate our trust.
REACH is finally here.
If it proves positive we can celebrate.
If it proves a disaster perhaps we have ourselves to blame.
The rarest of breed over many years has been a politician willing to step forward to stand up for British industry.
We surely deserved more.
* About the author: Derek Carpenter is with Enviro Tech Europe. Request a free brochure from Enviro Tech Europe ...
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