Key Comments of the European Chemical Industry on the Commission's Draft Legislative Proposals on Reach

In May 2003, DG Enterprise and DG Environment of the European Commission published their draft text for the new chemicals legislation on the internet for public consultation. The European chemical industry supports the political objectives of the new chemicals legislation as stated in the White Paper. Of particular importance for industry is to ensure the protection of human health and environment and to create a more efficient regulatory framework. However, the proposed system Is unworkable. It will have a negative impact on the competitiveness of the European chemical industry in the global market, its contribution to the economic wellbeing of the EU and its ability to finance innovation. The proposals go far beyond what was initially proposed in the White Paper on the future
strategy for chemicals in 2001. This deviation from the original objectives is unjustified and fails to recognize the reality of problems with existing legislation which need to be overcome, and the finite resources available in business and government.