Select Committee on Science and Technology Sixth Report


114. A number of impact assessments have considered REACH since the White Paper in June 2001.[160] These can be divided into four types:

    a)  Testing and registration (direct) costs;

    b)  Impacts on downstream users (indirect costs);

    c)  Innovation effects;

    d)  Health and environmental benefits.

Industrial competitiveness

115. The direct costs incurred by industry as a result of REACH have been estimated by the Commission to be around €2.3 billion over 15 years, a €10.6 billion reduction on the calculations based on the consultation text.[161] These savings have been achieved by reducing the requirements for Chemical Safety Reports, the exclusion of polymers, increased use of QSARs, reduced requirements for production volumes between 1 and 10 tonnes and lighter requirements for transported intermediates.[162]

116. More contentious are the indirect costs. The European Commission now estimates the maximum overall cost of the revised Proposals to be €7.5 billion, significantly lower than the €18-32 billion previously estimated. A key issue for industry is that the REACH Proposals will impose costs on companies that will undermine their competitiveness. The Bundesverband der Deutschen Industrie (Federation of German Industries) commissioned a report from Arthur D Little, which claimed that job losses could be up to 2,350,000 in Germany. A similar French study found that up to 670,00 jobs could be lost.

117. The WWF denies that REACH will be economically damaging and cites Adair Turner, former Director General of the CBI, who states in his book, Just Capital, that "There is no evidence that increasing environmental constraints have slowed overall growth rates, and no evidence that higher environmental standards in some developed countries have disadvantaged them economically versus others". WWF points out that the costs will be spread over the phase-in period for REACH, representing 0.12% of the chemical industry's annual turnover.[163] It also argues that REACH will provide new markets for environmentally friendly products.[164]

118. WWF reports that the Arthur D Little report, commissioned by the Federation of German Industries, has been "severely criticised by a group of leading German economists, drawn together by the German Environment Agency" and concludes that industry groups have been "engaged in scare-mongering tactics", that the cost burden to industry has been used as "a barrier to moving forward" and described the chemical industry as a "dinosaur industry".[165] This seems to reflect a deep-seated hostility to chemical companies rather than a rational assessment of an industry, which has, according to Dr Delbeke of DG Environment, spent substantial amounts on tackling environmental problems.[166] Commissioner Liikanen described WWF as "more diplomatic in their tone" than other groups; nevertheless, insults and point-scoring are not consistent with constructive discussions about how to improve.[167] Mike Barry from Marks and Spencer has mixed feelings about the chemical industry:[168]

    "My greatest frustration is that the chemical industry is perhaps the greatest achievement of the UK in the twentieth century. It is one of our greatest success stories; and yet it is on the back foot every day of its life because systematically it has mismanaged the whole concept of trust in the last twenty years. To put itself on the front foot and access the benefits of the twenty-first century, it has got to re-build trust in itself, and REACH is a necessary compromise."

119. A report produced for WWF concluded that there was little evidence that environmental legislation had any impact on employment and that "the negative impacts on innovation, competitiveness and employment have been overstated in industry-funded studies, and that insufficient account has been taken of broader social and environmental benefits".[169] Dr Delbeke pointed out that the companies which had been producing CFCs were largely the winners when it became necessary to substitute them with HCFCs.[170] A further factor in the costs is the effect on liability. Commissioner Liikanen pointed out that REACH introduced a duty of care principle, which would protect companies from expensive liability suits.[171]

120. Judith Hackitt from the CIA told us, "I think it is all to do with whether legislation is well designed or not. Good legislation should not harm growth rates".[172] Mike Barry agreed that REACH would drive innovation in the chemical and retail industries if it was "done properly".[173] Conclusions on the impact of environmental legislation cannot be generalised and to do so confuses the arguments as to how REACH can be improved to optimise competitiveness and benefits to human health and the environment.

121. The Environmental Industries Commission, a trade association for the environmental technology and services industry, points out that "the Proposals will require considerable analysis work - some of it on the environmental impacts of chemicals. UK environmental laboratories are well placed to undertake this work both in the UK and abroad. The REACH Proposals, therefore, will generate jobs and profits in a fast growing and highly skilled industry in which the UK has a strong market position". We agree with this conclusion, but it is important to recognise that job creation can sometimes result from unfortunate events.[174]


122. An argument has been made that EU producers will benefit in the long term owing to the added value that inclusion within the REACH Proposals will give them.[175] This is contested by the industry, the principal arguments being that the Proposals' provisions for chemicals in finished articles will not impose the same level of regulatory burden on non-EU producers. Dr Delbeke from DG Environment rejected these arguments and suggested to us that the complaints from industry reflected the painful process of restructuring in response to competition from China and other countries.[176]

Substances in articles

123. The CBI is concerned that the wording of Article 6 is open to subjective judgement and will be difficult to enforce.[177] The CIA says that it will be possible for articles (such as computers, household products, cars, toys, packaging and clothes) to be manufactured outside the EU using a wider choice of materials and with fewer controls. This, it is claimed, will lead to the migration of production outside the EU borders. Leigh's Paints reports "a growing concern that REACH will drive the chemical producers out of the EC, into regions where the costs of development and production are already low by EC standards. If this move takes place, there will be less and less incentive to register raw materials in Europe, and manufacturers who rely on chemicals - including all paint manufacturers - will themselves have to consider whether EC manufacture is a viable option".[178]

124. Commissioner Liikanen told us that the Proposals would not affect EU competitiveness since the same rules applied to imported goods.[179] Judith Hackitt felt that if imports were not adequately policed, manufacturing would move out of the EU in order to avoid some of the costs of testing.[180] Exporting companies will also be disadvantaged, according to John Kemp from Infineum. He told us that even a medium-sized company such as his exported 25% of its products outside the EU, and that he would be competing with products whose component chemicals may not have been tested to the same standards.[181]

125. The CIA and the CBI argue that the current Proposals place EU-manufactured finished articles (products) at a commercial disadvantage to the same article manufactured outside the EU.[182] As the legislation currently stands, it will be possible for articles to be manufactured outside the EU using a wider choice of non-EU registered chemicals and with fewer controls. The CIA believes that these articles would be cheaper than equivalent articles produced within the EU.[183] The EEF also argues that finished articles should come within REACH and cites other EU legislation - the End of Life Vehicles Directive and the Cosmetics Directive - as examples where importers must require declarations from suppliers that components do not contain banned substances.[184]

126. Different requirements for EU and non-EU manufactured goods concern Mike Barry from Marks and Spencer. He told us that if he imported a suit into the EU containing 30 different chemicals, he was quite happy to declare what those chemicals were but "What I do not want to do is a separate scientific risk assessment to prove that just because they were made in China they are safe. I want to ensure that if that chemical is coming into the EU in this [suit], it has been properly risk-assessed against the REACH model… import is the biggest fundamental concern we have got".[185]

127. WWF also considers this to be a key issue: and is "extremely concerned that the current proposal will allow unregistered, dangerous, or banned chemicals to be brought into Europe from 'outside' the REACH system".[186] It argues that Article 6 should be amended so that any producer or importer of articles would have to submit a Registration to the Agency for any substance contained in those articles, if it was present in those articles in cumulative quantities over 1 tonne per producer or importer per year.[187] Even if this amendment were introduced, the issue of other chemicals used in the production process but not present in the finished article remains.

128. The Government identified its concerns about Article 6 in its consultation, in particular it says there could be confusion over what constitutes the same article type. It also questions whether the supplier of articles is best placed to make an assessment of whether the quantity of substance released may be of concern to human health or the environment.[188]

129. Conversely, there have also been complaints from outside the EU that the Proposals will discriminate against non-EU producers. In a letter to the EU in March 2004, Asia-Pacific Economic Cooperation (APEC), an inter governmental grouping with 21 members, including the USA and Japan, expressed serious concerns about the REACH Proposals:[189]

    "Smaller foreign producers, including specialty chemical suppliers and downstream suppliers simply do not have the capacity for the data generation required under REACH. As a result, there is a potential for EU importers to deselect imported supplies, which are not only chemical substances but also articles containing chemical substances. Thus, REACH may create an inherent bias in favour of domestic EU suppliers."

130. The issue of finished articles is particularly problematic. To treat imported goods in the same way as EU-manufactured articles could impose a huge burden on small importers in particular, and would be very difficult to police. The SMMT argues that the ideal solution is for REACH to become the norm internationally.[190] The CBI agrees that "The only effective solution is to ensure a globally harmonised system and the EU should seek to work on this".[191] This would have obvious advantages and we would be pleased to see the EU argue the benefits this could have on international trade. We must accept that a global REACH is not on the horizon, however.

131. We believe that the REACH Proposals could have a significant adverse impact on trade with the US and Asia. This should be borne in mind by the Commission, the European Chemical Agency and Member States in the assistance they give to industry complying with REACH.


132. Leigh's Paints believes that REACH will lead to the withdrawal of some products. It cites the example of the Biocidal Products Directive, which was associated with a fall in the number of available products from 1,600 to 350. The Commission estimates that 1-2% of substances currently on the market will be lost. The Royal Society of Chemistry argue that this may be a significant underestimation since there will be cases when a producer would have to spend a large amount of money to test a low economic value substance for the purposes of Registration.[192] Judith Hackitt of the CIA suggests that the figure could be in the range 20-40%.[193] WWF disagrees and Andrew Lee told us, "Our view at WWF is quite clear: that if there is a chemical which is safe, produced in very small volume and for which there is an overwhelming need because it has a unique property that is needed for something that is very important, the market will deliver the result because the price mechanism will operate. The consumer pays for the safety, if you like, and for the use of the chemical".[194] REACH may lead to the loss of products, at least in the short term. Given that one of its aims is to remove dangerous chemicals from the environment, this is not necessarily a bad thing. Of greater concern is that very useful products will be withdrawn by companies rather than being put through the Registration process, regardless of whether they pose any danger to human health or the environment.


133. Nigel Smith of the British Retail Consortium (BRC) said that there was a lot of confusion in the sector.[195] Mike Barry from Marks and Spencer told us that his company sold 34,000 products and that the effort of tracking these products across the globe imposed a huge burden. He wanted to see "one, trusted, robust system in the middle for us all to use and share the costs across".[196] Nigel Smith explained that retailers wanted certainty and that the BRC was trying to be proactive, ahead of REACH, by drawing up a list of 25-30 chemicals that needed to be addressed in the supply chain.[197] Mike Barry explained that while consumer awareness of the legislation is "virtually nil", he is concerned by the prospect of an increasingly fickle consumer and he would rather spend now to put a trusted system of regulation in place than wait for a reaction in a few years' time. Mike Barry drew parallels with foot and mouth, for which the costs of addressing the problem were far in excess of the actual health risk.[198] He described REACH as "hugely imperfect [but] … the least bad option that people are offering me at this moment in time".[199]

134. The BRC, in its response to the Commission's internet consultation, believes that the obligations on retailers as downstream users and vendors of articles are likely to lead retailers towards reconsidering the manner in which they source products, switching their buying patterns in favour of EU importers rather than importing directly from manufacturers based outside the EU in order to ensure compliance with REACH at reasonable cost (leading to the increased cost of products to the consumer). The BRC sought clarification on whether retailers would be considered as downstream users. This would affect their REACH obligations.

135. The BRC states in its consultation submission that "If a substance is already registered in REACH it should be possible for other importers to make use of a very simplified Registration process, which demonstrates that use of the chemical is consistent with the rules, restrictions and purity of the existing Registration, but does not require submission of a chemical safety report or any additional data. This will reduce the burden of administration for the Agency and the importer, though careful consideration would be required on how to share costs with the original registrants".[200]

136. Leigh's Paints points out that the coatings industry operates on extremely low margins. It reports that the industry uses 10,000 chemicals to make 500,000 products and the company is concerned about the costs incurred in producing risk assessments in each case. It suggests that a single risk assessment could result in a document of up to 150 pages.[201] The Society of Motor Manufacturers and Traders (SMMT) reflects many of the concerns among downstream users of chemicals. It points out that they will be responsible for demonstrating the safety of chemicals and disclosing the information to the public. While it recognises the public's right to know the hazards associated with chemicals, it argues that the flow of information should impose as little burden on downstream users as possible. As an example, the SMMT points out that an average vehicle comprises 10,000 substances. [202] The SMMT has particular concerns about the need to specify uses of chemicals. Currently, the Proposals state that downstream users must either inform producers or importers of their intended uses or submit a Registration of their own. The SMMT would rather see standardised exposure categories used as it sees three problems with the proposed system:[203]

    a)  Confidentiality. Downstream users may not want their suppliers to know how a particular substance is used.

    b)  Flexibility. Downstream users may want to use a substance for a specific use not originally communicated to the supplier of chemicals.

    c)  Workability. A small European firm, which lacks relevant staff time and training, may find it impossible to communicate all the uses of a substance to an overseas importer of chemicals.


137. The turnover of the chemicals industry in the accession countries is estimated at some €16 billion (roughly 4% of the production of the EU15).[204] Opinion is divided over whether these countries are well prepared to implement this legislation. One view is that they already have regulatory mechanisms and bodies and that adapting to EU legislation will not cause too many problems. Conversely, there is concern that awareness is low. Public bodies from only three of them - Latvia, Lithuania and Poland - made a submission to the internet consultation. The Minister told us that the accession countries were "slightly nervous about REACH".[205] Dr Delbeke from DG Environment told us that "The accession states have a fairly limited chemical sector… But we know that generally, in the field of the environment, the higher your income is, the higher the concern is with your health… I would invite you to contribute your concern for that into the awareness raising and the general attitude towards the environment which is quite different there".[206] The implication is that the poor people in the accession countries are less concerned by health and the environment issues but this does not mean that EU law should not protect them. We believe that the Commission should work harder to ensure that the accession countries are more fully and better prepared for the introduction of REACH.


138. Following the internet consultation, the Commission made new provisions for innovation. Article 7 states that substances used for product—and process-orientated research and development will be exempted for up to 5 years. There is no explicit exemption for scientific R&D below 1 tonne per year because production, import and use of substances is already outside the scope of the Registration obligation. The Commission lists on its website the ways in which the Proposals fulfil the objectives of REACH to promote R&D and innovation:

139. Despite this, concerns have been expressed about the likely impact of the Proposals on innovation. These fall into four categories:

  • Loss of intellectual property rights;
  • Cost of new Registrations;
  • Restrictive provisions for R&D; and
  • Decreased competitiveness will lead to reduced R&D investment.

140. Leigh's Paints argues that uncertainty over IPR will be a disincentive. It also points out that the protection of new chemicals only lasts while R&D is in progress, and thereafter when production is in small quantities. New chemicals will only be developed if the predicted market is likely to be large, it suggests. [207] The CIA believes that, under REACH, there are instances in which confidential information could become public: the classification and labelling inventory, the sharing of data within consortia, and in the Chemical Safety Report.[208] In principle we support a presumption of openness. Given current concerns about the impact of reduced IPR protection it is important that companies can withhold data in some cases. This should be subject to review.

141. The CIA argues that different regulatory environments give rise to contrasting levels of innovation. It points out that, between 1987 and 1996, EU companies notified 274 new chemicals per year, Japanese companies made 265 notifications annually, and the number of new chemical substances notified per annum in the USA was 1,720.[209] Few would dispute the potential impact of regulation on innovation but these figures should be used with caution. At the very least they present an argument for change, which is just what is happening.

142. Depending on the enforcement of substitution, REACH should provide increased pressure on producers to develop new chemicals.[210] According to the Environmental Industries Commission (EIC), this presents opportunities in R&D. These include work to:

    a)  Establish the properties of chemicals and formulations;

    b)  Establish the environmental fate and behaviour of chemicals and formulations;

    c)  Establishment of environmental quality standards;

    d)  Monitoring of chemicals in the environment;

    e)  Develop new test methods in environmental toxicology; and

    f)  Develop, validate and apply QSARs.

143. The CIA believes that the provisions for R&D into new chemicals are too restrictive: "Research and development substances should have neither weight thresholds nor time limits as long as specified criteria are met, documented and retained for future inspection".[211] The Royal Society of Chemistry is concerned that the Commission's Proposals to encourage innovation focus on substitution as a driver. It argues that substitution is unlikely to lead to truly innovative products that contribute to the profits needed to underpin sustainable development.[212] Andrew Lee from WWF insisted that "strong regulation will drive innovation because it will create a guaranteed market for safe chemicals in the future".

144. Little of the evidence we have received focuses on the impact of REACH in the context of existing legislation. Mike Barry from Marks and Spencer told us that the current regulation stifled innovation. While there were large numbers of chemicals the company would like to use in its products, it was unsure of the reaction from consumers.[213] The Department of Trade and Industry's (DTI's) Chemicals Innovation and Growth Team concluded that while the UK chemical industry has a long tradition of innovation, its recent record was less strong.[214] The REACH Proposals are not perfect and will force change on the European chemical industry. The UK chemical industry has a poor record of innovation in recent years and REACH provides an opportunity to reverse this trend. British companies should see it as an opportunity, not a threat.

145. The EIC concludes that the Government "should review spending of research and development to ensure the UK is well placed to make the most of this business opportunity". It suggests the formation of a UK Centre for Chemicals Management, established as a centre of expertise to help ensure that the UK benefits from the business opportunities provided by REACH. We agree with this suggestion. In addition, the Government should complement this with measures to strengthen academic chemistry and chemical engineering. Academic chemistry in the UK has been suffering in recent years, with a string of closures of university chemistry departments. The Government must act to reverse this trend and support British industry in its attempts to compete successfully in the REACH environment.

Health and environment

146. There is increasing evidence that background pollution is having health and environmental effects. The EC's Extended Impact Assessment (EIA) noted that chemicals are linked with a considerable number of diseases including respiratory and bladder cancers, leukaemia, mesothelioma, skin disorders, respiratory diseases, eye disorders and allergies. It states, however, that there is frequently not enough information to be clear about the epidemiology, making it very difficult to link many so-called "modern diseases" to particular chemicals.[215]

147. The EIA found that while gaps in data prevented a comprehensive quantitative picture of the environmental impacts of chemicals, it concluded that "the impacts of chemicals on the environment are potentially large".[216] The Scientific Alliance expresses doubt over the projections for health improvement, based on assumptions made about the negative effects of chemicals and the economic benefit of reducing them.[217]

Table 1: Examples of types of environmental impacts

Observation/impact Species
Large-scale effects
Eggshell thinning Guillemot, eagle, osprey, peregrine falcon
ReproductionSeal, otter
Skeletal malformation Grey seal
Pathological changes Seal
PCB, DDT, metabolites
Reproduction Mink
Reproductive disturbances Eagle
Reproduction (M74 syndrome) Salmon
Chlorinated substances
Imposex Molluscs e.g. dog whelk
Impairments in wildlife in relation to endocrine disrupting chemicals
Sperm quality, cryptorchidism Panther
Population decrease Mink, otter
Female reproductive disorders, Seal
Eggshell thinning Birds
Embryotoxicity and malformations   
Reproductive behaviour   
Microphalli and lowered testosterone Alligators
Vitellogenin Fish
Reduced testis size   
M74 and early mortality syndromes   

Source: Extended Impact Assessment, European Commission, {COM(2003)644 final}. Original data from European Environment Agency, 1998 (large-scale effects); Swedish EPA, 1998 (impairments in wildlife in relation to endocrine disruptors.

*1 = no observed association, 2 = suspected association, 3 = weak association, 4 = clear association, 5 = significant association.

**DDT = 1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane; DDE = 1,1-dichloro-2,2-bis(p-chlorophenyl)ethylene; PCB = Polychlorinated Biphenyl; TBT = tributyl tin

148. The UK Environment Agency argues that REACH will help to generate data that are useful in targeting monitoring programmes. It is also concerned that existing systems will not prove adequate for identifying substances of concern to the environment.[218] There is evidence that a number of chemical compounds are having significant environmental impacts but in too many cases the associations are poorly understood. If REACH is to be effective in protecting human health and the environment, it must be supported by good basic science and monitoring. We urge the Government and the Commission to give research in this area a high priority.

149. Most of the benefits arising from the REACH Proposals are expected to be as a result of a substantial reduction in occupational diseases. The WWF reports that "dangerous substances currently contribute significantly to the 350 million days lost through occupational ill health, and to the 7 million people suffering from occupational illnesses".[219] We have listed some of the health and environmental impacts in Table 1. WWF points out that the "full extent of the problem is unclear because adequate toxicity data are only available for a small percentage of the many thousands of chemicals in everyday industrial and domestic use".[220] A report commissioned by WWF concluded that the health benefits could result in savings of £180 billion across Europe, with £50 billion in the UK alone. (These estimates were based on the consultation text and the WWF says that the Proposals have been "watered down" to the extent that benefits on this scale will not be realisable.[221]) The Commission's extended impact assessment suggests that "the total health benefits would be in the order of magnitude of €50 billion over the next 30 years" based on a 0.1% reduction in the burden of disease. The Commission stresses that this figure is not an estimate of the benefits of REACH, but rather an illustration of their potential scale".[222]

150. CIA has "serious doubts about the magnitude of the benefits being claimed".[223] Calculations are necessarily dependent on the validity and reliability of the testing regimes.[224] The Scientific Alliance argues that projections for health improvements are extremely doubtful, both in terms of the dubious assumptions made about the negative effects of chemicals and the net economic benefit of reducing them.

Further impact assessments

151. Industry has expressed the view that the impact assessments performed so far have been inadequate and that a further study is necessary. The CBI argues that "The impact assessments performed to date … have taken a limited and closed view of the impact on European businesses" and that the extended impact assessment does not reflect:

152. The CIA agrees, arguing that an independent third party should conduct a new study.[226] We pressed the CIA about from whom such an independent study could be commissioned. Judith Hackitt told us that "I think there are any one of several consultants out there who could do the impact assessment. I think it is immaterial to us in industry who does that".[227] We do not doubt that many consultants have the competency to do such a study but our scepticism is based on the fact that the impact assessments conducted so far have tended to support, very conveniently, the views of the commissioning organisation. There is a real danger that any future impact assessment would be dismissed by anyone whose views it did not support. Commissioner Liikanen is right to suggest that it is first necessary to get broad agreement on the methodology to be employed before the study has started.[228] This begs the question as to why this was not done before the Commission's Extended Impact Assessment was undertaken. A further impact assessment looks increasingly necessary if the legislation is to attain the confidence of all parties. It is unlikely that the European Parliament will give the legislation its first reading before the end of the year. This gives the Commission ample time to agree a methodology with interested parties and to undertake a further study which has widespread confidence.

153. In 1998 the Prime Minister announced that no proposal for regulation which has an impact on business, charities or voluntary bodies, should be considered by a Ministers without a regulatory impact assessment (RIA) being carried out. A "draft partial" RIA was published in March 2004 with the Government's consultation.[229] This estimates a direct cost to UK industry of £515 million, and £2.4 billion total for the EU as a whole.[230] This follows a first partial regulatory impact assessment by the Government on the White Paper published in May 2001.[231]

154. The WWF argues that, while there will be costs to industry, the benefits in terms of environment and health will outweigh this and cites studies concluding that the industry has overstated the costs.[232] The Commission estimates total current worst case costs of REACH, both for producers and downstream users, to be €5.2 billion spread over the phase-in period of REACH, with health benefits roughly estimated to be €50 billion over 30 years. A report commissioned by WWF, suggests that the value of the health benefits could be far higher, and easily exceed €100 billion.

155. Dr Delbeke from DG Environment told us that the Commission "sometimes feel a bit sorry that the debate is focusing too much about the costs and possible problems than about the benefits".[233] He went on to tell us that the Proposals were guided by the results of the cost analysis, in which case, it is not surprising that this has continued to be a source of contention.[234] It was pleasing to hear Dr Delbeke reveal that the subject was not closed and that the Commission would be establishing a round table involving all the players to establish a more sophisticated understanding of the impacts on industry.[235] We sympathise with suggestions that further impact assessments should be undertaken but endorse Commissioner Liikanen's comment that "the easiest political initiative is to say that you should do more counting".[236] We accept that it is often difficult to quantify impacts, but establishing figures to a reasonable level of accuracy is important in getting the balance right between workability and environmental protection. We welcome the Commission's efforts to acquire a more sophisticated understanding of the complex chemical industry and the impact of REACH upon it.

160   These are summarised in Presentations from Stakeholder Workshop held by the European Commission on 21 November 2003. Back

161   Q 163 Back

162   European Commission, REACH Extended Impact Assessment, October 2003, section 5.2 Back

163   Ev 80 Back

164   Ev 72 Back

165   Ev 80, Q 6 Back

166   Q 122 Back

167   Q 155 Back

168   Q 71 Back

169   Ev 81 Back

170   Q 114 Back

171   Q 168 Back

172   Q 222 Back

173   Q 60 Back

174   Ev 98 Back

175   Ev 81 Back

176   Q 127 Back

177   Ev 93 Back

178   Ev 57 Back

179   Q 187 Back

180   Q 223 Back

181   Q 223 Back

182   Ev 68, Ev 92 Back

183   Ev 68 Back

184   Ev 64 Back

185   Qq 72-73 Back

186   Ev 77 Back

187   Ev 77 Back

188   DEFRA, UK Consultation paper on the New EU Chemicals Strategy - REACH, March 2004, para 52 Back

189 Back

190   Ev 105 Back

191   Ev 92 Back

192   Ev 87 Back

193   Speech to DEFRA's New EU Chemical Strategy Stakeholder Consultation Conference, 27 April 2004 Back

194   Q 34 Back

195   Q 61 Back

196   Q 26 Back

197   Q 63 Back

198   Q 67 Back

199   Q 68 Back

200   British Retail Consortium Submission to Reach Regulation Public Internet Consultation, July 2003 Back

201   Ev 56 Back

202   Ev 104 Back

203   Ev 105 Back

204   European Commission, REACH Extended Impact Assessment, October 2003, section 4.1 Back

205   Q 298 Back

206   Q 148 Back

207   Ev 56 Back

208   Ev 69 Back

209   Ev 68 Back

210   Ev 61 Back

211   Ev 69 Back

212   Ev 87 Back

213   Q 54 Back

214   Department of Trade and Industry, Enhancing the Competitiveness and Sustainability of the UK Chemicals Industry, a report by the Chemicals Innovation and Growth Team, December 2002, p 37 Back

215   Q 109 Back

216   European Commission, REACH Extended Impact Assessment, October 2003, section 6.2 Back

217   Ev 101 Back

218   Ev 62 Back

219   Ev 81 Back

220   Ev 22 Back

221   Ev 82 Back

222   European Commission, REACH Extended Impact Assessment, October 2003, section 6.3 Back

223   Ev 68 Back

224   See paragraphs 93-97 Back

225   Ev 91 Back

226   Ev 68 Back

227   Q 219 Back

228   Q 169 Back

229   DEFRA, UK Consultation paper on the New EU Chemicals Strategy-REACH, March 2004, para 12 Back

230   DEFRA, UK Consultation paper on the New EU Chemicals Strategy-REACH, March 2004, p 62 Back

231   Q 259 Back

232   Ev 80-81 Back

233   Q 108 Back

234   Q 118 Back

235   Q 116 Back

236   Q 169 Back

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