Tim,

First, what I hear from this side of the pond is that since the regulated
are in the EU, it can make sense for the supply base to migrate there
because they will KNOW that they are being regulated and will provide the
requisite information up/down the supply chain (as is required by REACH).
This may have the effect of companies replacing non-EU suppliers with EU
suppliers if/when they have trouble getting the required information. We did
see this with RoHS so there is precedence. Of course, there is nothing
preventing US- or China-based companies from providing the required
information when/if necessary...but they are under no legal obligation to do
so while EU-based companies are.

Second, and more from the EU government side, I hear that REACH could drive
innovation of replacement substances that can compete with current
substances and are less toxic (which, of course, is what they are hoping
for). The regulated companies in the EU will have such incentives due to the
costs of going through the registration/evaluation/authorization process
with current chemicals - new replacements may be less expensive.

Note that I am the messenger here; these are not original thoughts of mine.

The point was made that suppliers may just up and leave the EU due to REACH;
it could happen but that's probably a short-term win only. I have said it
before - these regulations get adopted in other locales, as we have seen
with RoHS. So you can only run for so long.

Mike



On Wed, 27 Dec 2006 02:26:59 -0500, Timothy McGrady <[log in to unmask]>
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

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