The EU’s chemicals formula

As a new European Chemicals Agency (ECHA) opens its doors in Helsinki, multi-billion euro industries are preparing to deal with the effects of one of the most ambitious pieces of legislation ever agreed at EU level.

A regulation for the registration, evaluation, authorisation and restriction of chemicals, known as REACH, will force industry to apply to register 30,000 chemicals. Some of them may not be approved.

Stavros Dimas, the European environment commissioner, calls REACH "the most progressive chemicals legislation in the world".

Cefic, the European chemicals federation, says it is also "one of the biggest regulatory challenges [industry] has ever faced". Since the start of last year, Cefic has published five sets of ‘REACH preparation’ guidelines.

Even the simplest applications, to register some of the most common chemicals produced in or exported to the EU, will be far from easy. Even with the Cefic guidelines, industries using chemicals are unsure how the 849-page regulation will affect them.

To help them, the European Chemicals Bureau (ECB) and European Commission are preparing six REACH implementation projects (RIPs), each of which will be broken into several sub-projects. The RIPs should help the ECHA, as well as industry and the national authorities, cope with the new legislation.

Hewlett-Packard (HP), the electronic goods company, has criticised early RIP sub-projects for increasing, rather than reducing, the administrative burden for industry. In particular HP says that the RIPs "introduce new terminology and classifications" not included in the final version of REACH.

RIPs are all due to be completed in the first quarter of 2008.

In the meantime, industry sectors are preparing their own guidebooks to complement the general Cefic advice.

One of the earliest of these came from Orgalime, the engineering industry association. This 37-page guidebook includes a one-page overview of the REACH timeline: from entry into force on 1 June this year, to 31 May 2018, when the final registration should have taken place. It also contains four one-page diagrams to explain different aspects of compliance.

Orgalime says that it has received hundreds of requests to download this simplified version of REACH.

"We were disappointed there was not more information in REACH about communicating all along the supply chain," said Adrian Harris, Orgalime secretary-general, explaining the reasons for producing the booklet.

Orgalime gives mobile phone production as an example of a complex supply chain, at every stage of which information on REACH compliance will be vital. The 150 mobile phone products on the market include 500 accessories and 30,000 components, explains Harris, involving ten factories and 100 production lines.

DSM, a manufacturing company, said that faced with this overwhelming challenge, it was trying to pull together an inventory of all the substances in its products, whether raw materials or intermediate chemicals. Jan Berends, environment manager at DSM, estimated that this inventory would have to cover "more than 500 products and more than 5,000 raw materials, and thousands of suppliers".

Like the engineering and manufacturing industries, Cepi, the European industry association for paper sector, will be affected by REACH as a downstream user of substances, and as an importer and producer of chemical articles.

Paper production also involves the production of chemical by-products and intermediates, said Danny Croon, Cepi’s environment and process manager. The association is now waiting for the RIPs to explain which of these substances will have to meet registration requirements.

The group estimates that the cost of chemicals used by the paper industry could rise by as much as 5% under REACH. It is pushing for registration exemptions where these would be "logical", said Croon, in order to keep the impact on pricing and competitiveness as low as possible.

"Implementing REACH will be a continuous learning process," said Croon.

As a new European Chemicals Agency (ECHA) opens its doors in Helsinki, multi-billion euro industries are preparing to deal with the effects of one of the most ambitious pieces of legislation ever agreed at EU level.

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