UIC – 29 & 30 May 2006 REACH Registration, Evaluation and Authorisation of Chemicals View of the French Chemical Industry Jean PELIN Union des Industries Chimiques Bucarest - 29 & 30 May 2006

UIC – 29 & 30 May 2006  Development of the new legislation - co decision process and timing  French chemical industry view on REACH  Preparing industry for REACH  Next steps

UIC – 29 & 30 May 2006 Development of the new legislation Key Dates  February 2001 Publication of the White Paper  May / July 2003Public Internet Consultation  29 Oct 2003Commission Proposal COM(2003) 644  17 Nov 2005European Parliament Resolution  14 Dec 2005Council Political Agreement Next steps  Council Common Position in June 2006  EP and Council 2 nd reading by the end of 2006; Conciliation?  Adoption in March / April 2007?

UIC – 29 & 30 May 2006 CO-DECISION PROCESS & TIMING REACH comes into force: 2007? Communication from the COM on common position Council political agreement DEC 2005 EP first reading NOV 2005 COM proposal 29 October 2003 EP approves Council common position EP second reading (absolute majority) Act is deemed to be adopted EP proposes amendments to Council common position Commission’s opinion on EPs amendments Second reading by the Council Council does not approve the amendments to the common position Council approves the amended common position: (i)By a qualified majority if COM has delivered a positive opinion (ii)Unanimously if the COM has delivered a negative opinion (3 + 1 months) Act adopted as amended Conciliation weeks YES NO YES NO Council Common Position May/June 2006

UIC – 29 & 30 May 2006 French chemical industry view on REACH The chemical industry has always supported the overall political objectives of REACH:  protection of human health and the environment,  maintenance and enhancement of the competitiveness of the EU chemical industry However the proposed system still has to be improved. Otherwise it will have a negative impact on the competitiveness of the EU chemical industry in the global market, on its contribution to the economic wellbeing of the EU and on its ability to finance innovation. stressing at the same time the need for a risk-based and workable system.

UIC – 29 & 30 May 2006 Socio-economic impact: the French study  carried out by MERCER (2003, updated 2004) involving French authorities and downstream sectors  Four Business Case studies on electronics, textile, car accessories and iron and steel industry  Very strong impact on the whole industry and economy:  Direct costs of tests  Indirect consequences on the whole supply chain:  Global impact in 10 years’ time: 1.6% of the French GDP (28 billion euros)  Loss of 360,000 jobs for the whole French economy

UIC – 29 & 30 May 2006 UIC key issues (1/2)  Make REACH simple, efficient and workable, in particular for SMEs, through a risk-based approach  OSOR: opting-out clauses on joint submission of information more workable; possibility to opt-out for sharing non-vertebrate animal studies  Agency: a Central Agency responsible for, and coordinate, both dossier and substance evaluation.  Authorisation/substitution: authorisation granted if risk is adequately controlled and with no time limit; substitution as a principle not as a systematic requirement./..

UIC – 29 & 30 May 2006 UIC key issues (2/2)  Intermediates: no additionnal requirements (compared to the COM proposal) for registration of intermediates  CBI: protect know-how, intellectual property and Confidential Business Information; right to appeal  Duty of care: no reference to duty of care in either the recitals or the legal text. A workable, coherent and user-friendly system enabling industry, Competent Authorities and the Agency to fulfill their part of the task is the only way we will be able to realize the true benefits that we all stand to gain from a workable REACH on improving human health and the environment.

UIC – 29 & 30 May 2006 Since October 2003 Telephone/ answers to questions mainly from UIC members (on co decision process, scope, requirements…) Awareness workshops at local level on behalf of UIC and local UIC associations: 5 a year (50 participants each time from Chemical Companies and Downstream Users) 2-day training sessions twice a year - 5th session in March 2006 (100/150 participants a day) Dedicated courses (i.e. for a group of SMEs at local level…) A few audits to evaluate the economic impact of REACH on business From now on Need to set up a structure to reinforce supporting actions toward Companies in providing early advice and tools to fulfil their duties under REACH Preparing industry for REACH – UIC actions

UIC – 29 & 30 May 2006 Partnership between UIC and the French Ministry of Industry, with technical expertise from the Ministry of Environment Public launch: 16 May 2006 Mainly SMEs from Chemical Industry and Downstream Users (painting and metallurgical industries, aeronautics… distributors) Objective: 800 Companies Issues covered : at first REACH… then GHS, SDS… Joint initiative REACH & SMEs (1/2)

UIC – 29 & 30 May 2006 Proposed actions: 1.Raising awareness (half a day): to make companies aware of the challenges presented by REACH and of the need to prepare themselves (regardless of the area of activity, size of the company, its REACH status: producer, importer, downstream user, distributor) 2.Collective training (2 days): to help companies understand the requirements of REACH and to prepare key areas for its implementation by defining action plans. 3.Training by supply chain: to help companies understand and evaluate the specific impact of REACH and define a targeted action plan 4.Individual on site assistance for SMEs: to review the existing situation so that an SME can establish action plans for the actual implementation of REACH. Tools / information to be made available: pedagogic kits, regular Newsletters, leaflets, list of laboratoires / organisms having expertise in testing / dossier constitution… Numerous actions already planned in 2006 and 2007 Joint initiative REACH & SMEs (2/2)

UIC – 29 & 30 May 2006 Next steps: UIC  To continue to develop proposals for an improved and workable REACH at the edge of the 2nd reading  To reinforce/develop actions to help Companies to prepare themselves to implement REACH, in partnership with authorities and sector groups  to contribute with Trade Unions to a successful implementation of REACH in particular through sharing with other sectors the joint long experience on best practice

UIC – 29 & 30 May 2006   micals micals  REACH: more info - useful websites 6th training session on REACH: 28 & 29 June in Paris