COTANCE Round Table - 27 October Bologna - Alex Föller1 Making REACH less threatening for EU suppliers and downstream users - Current activities of TEGEWA related to leather chemicals - Dr Alex Föller Director TEGEWA

COTANCE Round Table - 27 October Bologna - Alex Föller2 - surfactants - paper chemicals, - textile auxiliaries - leather and fur auxiliaries, - colourants for leather, textile, paper - complexing agents, - antimicrobial products, - polymeric flocculants, - cosmetic raw materials, - pharmaceutical excipients - and allied products Performance chemicals and auxiliaries for industrial downstream users - substances - polymers - mixtures - reaction masses - preparations TEGEWA = Association of manufacturers of

COTANCE Round Table - 27 October Bologna - Alex Föller3 Key questions for Downstream users  Will REACH costs of the supplier be passed on along the supply chain?  Will substances / formulations been withdrawn from the EU markets?  Will suppliers of substances consider the uses within the leather manufacturing by providing appropriate Exposure scenario for the downstream communication?  Will leather manufacturers have to consider specific duties under REACH?

Impact on the product price Price Testing costs per product Sales price, apportionment of reg. costs for 5 years per kg1.40 €2.44 € 1.89 € (+35%) Quantity 40 t/a 56,000 €97,600 € The impact on calculation, example: water repelling agent for the leather industry (on the basis of the REACH text according to COM proposal 2003) 4COTANCE Round Table - 27 October Bologna - Alex Föller

Individual submissionJoint submission 1-10 t1, €1, € t4, €3, € 100-1,000 t11, €8, € > 1,000 t31, €23, € Standard fees Indiv. Medium-Joint Medium-Indiv. Small-Joint Small-Indiv. Micro-Joint Micro ,00 €16.275,00 €12.400,00 €9.300,00 €3.100,00 €2.325,00 € Reduced fees for micro, small and medium-sized enterprises (case of ≥ 1,000 t) -25 % -30 %-60 %-90 % Registration fees 5COTANCE Round Table - 27 October Bologna - Alex Föller

6 Current activities  TEGEWA/CESIO model agreements for consortia formation (‚Redeker model agreements‘)  Support pre-registration for auxiliaries and specialty chemicals which need identification and grouping  Implementation of an organisation and selection of consultants for project management and administration of co-operations  Other activities – branch-specific exposure scenario, platform to exchange information and experiences TEGEWA  support members to implement REACH

COTANCE Round Table - 27 October Bologna - Alex Föller7 Support of pre-registration activities  „Strategy“ for pre-registration of fat liquors on the basis of  Fish oils  Animal oils (except fish)  Vegetable oils  More than 300 substances have initially been reported to TEGEWA… …which will probably be registered within some 20 co-operations …in the field of leather chemicals

COTANCE Round Table - 27 October Bologna - Alex Föller8 Exposure scenario  Elaboration of five Exposure scenario relevant to different stages of the leather manufacturing process  …project supported by suppliers and tanners  …final report available soon  …guidances can be derived from the final report to be used by suppliers and their customers …in the field of leather chemicals

COTANCE Round Table - 27 October Bologna - Alex Föller9 Co-operation TEGEWA - AISPEC  Aim: to development standard solutions (best case)  …common strategy for pre-registration  …information exchange on the development of Exposure scenario  …common sense on open questions, e. g. pre- registration for Caseinates appropriate or not? …in the field of leather chemicals

COTANCE Round Table - 27 October Bologna - Alex Föller10 Duties of manufacturers of articles  Major requests from manufacturers of articles and retailers: REACH par. 7 and 33 - par. 7 (1): Intended release  (pre-)registration - par. 7 (2): SVHC substances  notification - par. 33: SVHC substances  consumer rights to know

COTANCE Round Table - 27 October Bologna - Alex Föller11 REACH – Impact on the portfolio strategies  Assumption: all existing chemical substances will be pre-registered, as companies want to support and maintain their current markets (even if some companies may abstain from pre-registration in single cases)  It may as well be expected that large-volume substances (≥ 1,000 t) will be registered (question: will each use be covered in the registration dossier?)  Thus, no severe changings in the EU substance portfolio to be expected before Withdrawal of substances due to registration … …some conclusions (1)

COTANCE Round Table - 27 October Bologna - Alex Föller12 REACH – Impact on the portfolio strategies  Will ECHA be able to cope with all claims and demands in time (registration dossiers and evaluation of the large volume substances, authorization)?  Will the Review of the regulation (2011 or 2012?) affect the conditions for the registration of the small volume substances…in a positive way?  Will industry as well as authorities be in a better shape (learning curve) to get along with the registration duties? Withdrawal of substances due to registration …some conclusions (2) – What will happen beyond 2013?

COTANCE Round Table - 27 October Bologna - Alex Föller13 REACH – Impact on the portfolio strategies  What is the overall market situation beyond 2013?  Will other regions of the world copy REACH?  …or will they produce better regulations?  very difficult to forecast the withdrawal of small volume substances due to REACH Withdrawal of substances due to registration …some conclusions (3) – What will happen beyond 2013?

COTANCE Round Table - 27 October Bologna - Alex Föller14 Thank you very much for your attention Any questions? Dr Alex Föller Verband TEGEWA e. V. Frankfurt, Germany Phone +49 – 69 –