Hi Brian,
Well, I didn't _say_ that it would work globally...just that it would be
rolled out globally ;o) I agree that that is extremely sub-optimal. One just
has to look, sometimes closely, at the various regulations we refer to as
"RoHS" to know that...implementations of recycling regs like WEEE are of
course even worse in terms of consistency.
Thanks for the link to the German study. It is interesting, if quite old -
REACH has been somewhat defanged since then to reduce cost to industry. Only
the 1500 to 2000 or so substances that require authorization will have
significant costs associated with them; not all substances in the "medium
sized production" range. Now they discount (and, I think dramatically
underestimate) and justify the costs of implementation (2.8 to 5.2 billion
Euros - RoHS alone - on six substances - cost the Electronics industry more
than that) based on projected health care savings (a SWAG of 50 billion
Euros over 30 years).
Mike
On Thu, 31 Aug 2006 10:43:58 +0300, Brian Ellis <[log in to unmask]> wrote:
>Sorry, I cannot agree. The only way it would work globally is if there
>were an international protocol, devised by UNEP and WHO, signed and
>ratified by all countries, with sanctions against all non-signatories
>forbidding signatories to import products manufactured with
>non-homologated chemicals, the onus of proof being on the non-signatory.
>This technique worked with the Montreal Protocol (I think ~193
>signatories). You need both a carrot and a stick and everyone MUST be on
>the same footing with the same timescale. The itty-bitty approach of
>non-EU countries introducing different rules at different times just
>wouldn't work.
>
>I don't think the EU chemical industry will develop "greener"
>substitutes, at least in the near future. Rather, it will stifle
>innovation, because it will cost the industry zillions just to
>homologate what they are already producing in vast quantities. The
>medium-sized production (1 - 1,000 tonnes/year) will largely go by the
>board in Europe as the cost will drive it to death - and many of the
>chemicals our industry uses fall into this category. The smaller
>speciality producers simply could not afford to homologate all their
>products at €100,000 minimum per throw.
>
>I'm very pessimistic about this. The German chemical industry foresees
>losses in employment figures:
>[quote]The first comprehensive study assessing the broader social and
>economic effects of REACH as described in the White Paper was conducted
>by Arthur D. Little for the German employers’ federation BDI. This
>macro-economic study was released in November 2002 and examined the
>effects of REACh on German industry. A calculation model was used with a
>bottom-up approach, meaning that the effects were first assessed in
>relation to specific value chains and industries and then extrapolated
>to determine the overall effect on industry as a whole. Important
>determinants in this study are the registration costs and the number of
>expected multiple registrations. Three scenarios were developed, named
>Clouds, Storm and Hurricane, resulting in gross added value loss in all
>German industry sectors of 0.4%, 2.4% and 6.4% respectively, and
>corresponding job losses of 150 000, 900 000 and 2 350 000. Other
>anticipated effects included a considerable loss of substances from the
>market, particularly products in small volumes, a loss of innovation, a
>decline in investments, a fall in German exports. Overall
>competitiveness and innovative capacity of German industry was expected
>to diminish. [/quote]
>
>(http://www.cefic.be/files/Publications/Appendix%204%20-%20Summary%20of%20Business%20Impact%20Assessments%20of%20New%20Chemicals%20Policy.doc)
>
>And that is just one country :-(
>
>Sorry!
>
>Brian
>
>Mike Kirschner wrote:
>> Hi Brian,
>>
>> Just a couple points. First, I expect REACH to eventually be implemented
>> more or less globally in much the same hysterical and inconsistent manner
>> RoHS is rolling out globally. The Environment DG is working with China on
>> their chemical policy and they're here in the US working with North American
>> countries and states that have interest in such things (like California and
>> Massachusetts...not Washington DC at this point).
>>
>> I'm not so sure it will create unemployment in the EU; your point about
>> process steps moving outside the EU is a good one though. The expectation,
>> and quite honestly one of the concerns I hear here in the US, is that this
>> will drive the EU chemical industry to develop safer alternatives to
>> existing chemicals ("green chemistry") where feasible, thus giving them a
>> potential competitive advantage. In any case chemistry and chemical
>> engineering might be lucrative fields for our kids to go in to if they have
>> the interest. ;o)
>>
>> Speaking of Massachusetts, it's time for another advertisement. I think I've
>> mentioned this before, but now it's germaine to the topic... The Lowell
>> Center for Sustainable Production (part of the University of Massachusetts)
>> is putting on short series of inexpensive seminars about REACH here in the
>> US. I'm not participating but I'll attend the one in Foster City! Here's the
>> link:
>>
>> http://www.chemicalspolicy.org/registration.shtml
>>
>> Mike
>>
>> On Wed, 30 Aug 2006 11:27:45 +0300, Brian Ellis <[log in to unmask]> wrote:
>>
>>> No, it's not going to be like RoHS, it's going to be far worse :-(
>>> You'll see this when speciality chemicals you use are no longer
>>> available because the cost of homologating them will push the price up
>>> by a few hundred pounds or euros/kg, so manufacturers just won't do it.
>>> The biggest effect it will have is to force European manufacturers to
>>> export their processes (where the chemicals are used as a process agent
>>> and do not remain in the finished product) to countries where such
>>> regulations do not exist, such as the Far East or South Asia.
>>>
>>> As I have said before, I would welcome REACH, provided it was introduced
>>> globally and not just in one economic region. This would put everyone on
>>> an equal footing. As it is, it will create unemployment in many European
>>> industries.
>>>
>>> Brian
>>>
>>> Paul Jackson wrote:
>>>> Is REACH going to be like RoHS... what does it mean for the industry as a
>> whole....?
>>>> http://www.netregs.gov.uk/netregs/legislation/380525/1285481/?lang=_e
>>>>
>>>>
>>>>
>>>>
>>>> Paul Jackson
>>>> Hotline Purchasing Manager
>>>> Black Box Network Services
>>>> Tel: 0118 965 5225
>>>> Fax: 0118 9751 565
>>>> E-Mail: Paul <mailto:[log in to unmask]> [log in to unmask]
>>>>
>>>> Web: www.blackbox.co.uk
>>>>
>>>> One source for worldwide infrastructure services
>>>>
>>>>
>>>>
>>>>
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