Brian:

Do you think that large EU chemical manufacturers favor REACH for just those
reasons (that chemical industry SMEs will be reduced or eliminated from
competition within the EU and that REACH will give the large chemical
companies a ready-made excuse for outsourcing production using cheap labor
in countries where pollution regulations are lax)?

Tim
----- Original Message -----
From: "Brian Ellis" <[log in to unmask]>
To: "(Leadfree Electronics Assembly Forum)" <[log in to unmask]>; "Timothy
McGrady" <[log in to unmask]>
Sent: Wednesday, December 27, 2006 4:41 AM
Subject: Re: [LF] REACH


> The only way the competitiveness will be enhanced is inevitable: the
> European manufacturers will increase their production in Asia, where costs
> will be lower and where they can do what they damn well please. It will
> the deathknell of competitiveness within the EU. Of course, imported
> chemicals will have to comply in the same way as home-grown products, so
> there is neither advantage nor disadvantage there. What it does mean, in a
> second phase - and this applies to our own industry - is that the users of
> the chemicals will also largely export their production because the cost
> of homologation will be too great for the comparatively small quantities
> of speciality chemicals that we use, so these will be taken off the
> European market.
>
> Brian
>
> Timothy McGrady wrote:
>> Mike:
>>
>> I have a few questions for you based on the following from the Europa
>> website concerning REACH:
>>
>> "The Commission proposed a new EU regulatory framework for the
>> Registration,
>> Evaluation and Authorisation of Chemicals (REACH) on 29 October 2003
>> (COM(03) 644 (01)). The aim is to improve the protection of human health
>> and
>> the environment through the better and earlier identification of the
>> properties of chemical substances. At the same time, innovative
>> capability
>> and competitiveness of the EU chemicals industry should be enhanced."
>>
>> Concerning that last sentence: Do you consider that to be indicative of
>> an
>> intended competitive advantage for Europe's chemicals industry as a
>> result
>> of the implementation of REACH?  If that is the intent, then how can
>> REACH
>> not be classified as a technical barrier to trade?
>>
>> I think this is indicative of what REACH is intended to accomplish and in
>> general it exposes the underlying intent of the EU gvovernment with
>> regard
>> to technical regulations.  I cannot support legislation that on the one
>> hand
>> states it will improve protection of human health and the environment and
>> on
>> the other states that it will improve the economic standing of industry
>> within the territories of the legislating body.
>>
>> Tim McGrady
>>
>> ----- Original Message -----
>> From: "Mike Kirschner" <[log in to unmask]>
>> To: <[log in to unmask]>
>> Sent: Tuesday, December 26, 2006 8:06 PM
>> Subject: Re: [LF] REACH
>>
>>
>>> Hi Chuck,
>>>
>>> Great post - thanks for the links. Good to know about the UCB research
>>> (and
>>> opinion). There are other studies that are somewhat more conclusive than
>>> those you identify that use "might", "could", and other weasel words.
>>> http://www.ehponline.org/members/2004/7421/7421.html still has some (I
>>> think
>>> it's unavoidable with that type of research) but it seems quite
>>> confident
>>> in
>>> its conclusions. the www.ehponline.org site is a good site for this sort
>>> of
>>> research.
>>>
>>> Just one point - REACH is about more than just the carcinogenic effects
>>> of
>>> chemicals; all toxic and ecotoxic effects are in it's cross-hairs.
>>>
>>> By the way, here is the EU NGOs' joint press release stating that they
>>> are
>>> not pleased with REACH:
>>> http://www.env-health.org/IMG/pdf/Joint_NGO_press_release_REACH_final_vote.pdf
>>>
>>> The bottom line of REACH is that it will be law; like RoHS companies
>>> will
>>> need to comply with it.
>>>
>>> Mike
>>>
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