Of course, that is one aspect.
Brian
Timothy McGrady wrote:
> 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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>>
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