10 CONCLUSION
168. Opinion is divided on the current Proposals.
While industry continues to argue that they remain unworkable,
environmental NGOs claim that further concessions to industry
risk undermining the legislation's effectiveness while still imposing
most of the burden. We have taken a pragmatic approach to this
legislation, to look at how the current Proposals can be optimised
in terms of health, environment and industrial competitiveness.
REACH is not perfect but any regulation is a compromise between
competing demands. We share the view that it is better than the
current EU legislation. There are concerns that the more risk-based
approaches to regulation in Japan and the USA have not been effective
in protecting human health and the environment from toxic substances.
We conclude that the Proposals offer a good basis for negotiation
during the co-decision process and have highlighted areas of concern;
for example, we would like to see a pre-Registration system to
identify substances of high and low concern and prioritise their
Registration accordingly. At the Evaluation stage, we would like
to see stronger oversight by the European Chemicals Agency. We
have not been convinced by the arguments of the environmental
NGOs that the current Proposals create insufficient provision
for the substitution of chemicals of concern. The predicted impact
of the Proposals has been extremely contentious and we believe
that a further impact assessment will be necessary to give all
stakeholders confidence in the legislation.
169. We agree with the Minister for Rural Affairs
and Local Environment Quality that "a number of changes have
been made which are moving towards more workability but I think
further improvements are necessary".[256]
The UK Government has adopted, for the most part, a sensible position,
which we attribute to a refreshingly objective stance to legislation.
We urge it to argue its case strongly at the Council of the European
Union and to use its influence when it assumes the Presidency
in the second part of 2005.
256 Q 256 Back
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