Chemicals review: German industry asks for new REACH

On 16 September, the German industry federation BDI sounded the alarm bell over the EU’s plans for stricter legislation on chemical substances, stating the current proposals would lead to a loss of 1.7 million jobs.

After having consulted stakeholders in the course of 2001 on
its White Paper “Strategy for a future chemicals policy”, the
Commission presented in May 2003 a first 1,200 pages outline of its
legislative proposals in a consultation document. It started an
8-weeks internet consultation on the workability of its proposals.
More than 6,400 comments were sent in, half of them coming from the
downstream user side.

The German industry, which had opposed the plans
from the start, asked corporate consultants Arthur D. Little for a
second economic assessment of the Commission’s proposals. At the
end of 2002, Arthur D. Little had already undertaken a first study
based on the White Paper’s orientations.

The results of the new study indicate that the
current proposals in the Commission’s consultation paper would lead
to a gross value added loss of 4.7 per cent. More than 1.7 million
jobs would be at risk if the proposals were to become law.


In its press conference in Brussels on 16 September, the
German industry federation BDI called for "a new
REACH", which should consist of three elements:

  • the new REACH should focus on the "most problematic"
    substances, instead of targeting all substances at the same
  • communication in the supply chain between producers and users
    of chemical substances should be better organised;
  • the Commission should conduct pilot projects in order to test
    how the major elements of its proposals would function in

French government has also been warning that the
Commission proposals would undermine the competitiveness of the
European chemicals industry and lead to job losses (see

EURACTIV 16 September

In the UK,
Trade and Industry Secretary Patricia Hewitt
announced on 16 September that her country is ready for a showdown
with the Commission on this legislation as it would "destroy the
European chemicals industry".

Environment NGOs have repeatedly questioned these
economic impact assessments, accusing the industry of
scaremongering over job losses and forgetting about positive
effects for health and the environment. For the NGOs, the chemicals
debate has also become a test case, but then on the commitments of
the EU concerning its sustainable development strategy. In a
reaction to the new Arthur D. Little report presented by the BDI,
the Greens in the European Parliament accused the report o f being
"detached from economic reality". They criticised the methodology
of the study, pointing to a critical

assessment of the first study by the Federal Environmental Agency (Umweltbundesamt)in
February 2003.

In an

impact assessment,
prepared for the
Commission's DG Enterprise in June 2002, the
results are not as dramatic as predicted in the two Arthur D.
Little studies and the study even foresees an important impetus for
innovation thanks to the clearer rules. An independent evaluation
of the different impact assessments was undertaken in July 2003 by
the German "Rat von Sachverständigen für Umweltfragen" (Council of
Environmental Experts). According to this advisory body to the
German government, the studies done for the chemicals industry
overestimate the new system's economic impact and underestimate the
advantages for environment and health (see


The revision of the EU's chemical substances policy aims at
improving the testing of chemical substances before putting them on
the market. Currently, around 30,000 chemicals are used in all kind
of products without ever having undergone serious public testing.
Worries over the impact of these chemicals on the environment and
public health have led to this revision.

The key elements of the proposed legislation

  • the introduction of the "REACH" system to Register, Evaluate
    and Authorise new CHemicals under the supervision of a new European
    Chemicals Agency;
  • the obligation for the chemical industry to provide safety data
    and risk assessments of the new chemicals it puts on the
  • lesser registration requirements or exemptions for chemical
    substances used to produce other chemicals;
  • provisions to reduce animal testing.

For the whole of industry, the revision of the
chemicals policy has become the test case for the EU's seriousness
about its Lisbon agenda of becoming the most competitive knowledge
economy by 2010. As chemical substances are used in every product
put on the market (e.g. more than 10,000 individual substances are
involved in the production of a car), the proposals affect more
than just the chemicals industry.


The Commission is expected to present its final legislative
proposals on 29 October.


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