Select Committee on Science and Technology Written Evidence


Memorandum from BASF


  BASF is the world's largest chemical company. From its headquarters in Germany it operates globally. BASF has been present in the UK for over 100 years and has continuously grown in the past 50 years to become one of the UK's major manufacturers and sellers on chemicals in the UK market. I have worked for over 30 years in the UK chemical industry and have been with BASF for 26 years.

  BASF has been actively lobbying on the EU Chemicals Policy Review as a Company throughout Europe and through UK and European trade bodies.

  I have not repeated in this submission information that has been presented before but rather I have tried to indicate areas of concern to BASF that still need to be addressed and could be considered important to the Science and Technology Committee.

  I have concentrated on two specific areas: the impact on human health and the environment, and the impact on industry competitiveness.


  The protection of human health and the environment is the primary objective of the proposed EU Chemicals Legislation.

  The chemical industry supports this objective unequivocally. The industry, through companies and trade associations, has repeatedly said that it wants and needs effective and efficient legislation, and it wants it quickly. Existing legislation is inadequate.

  The industry has perhaps failed to communicate this message strongly enough and perhaps needs to demonstrate more clearly what it has achieved in improving human health and reducing its environmental impact.

  There are clearly many factors affecting human health and the environment and there is no doubt that chemicals are one factor.

  A key factor here is risk and I do not believe the proposed EU Chemicals Legislation has placed enough emphasis on a risk based approach in the identification of priorities. Too much emphasis has been given to volume.

  I believe that much of the gap that exists today between the views of the chemical industry and some opposing external stakeholders, such as green NGOs, could be bridged relatively easily.


  Much has been said about the negative impact of the proposed legislation on the future competitiveness of one of Europe's most successful industries. I will not repeat these arguments. The proposal published by the Commission on 29 October 2003, COM (2003) 644 final, did itself recognise the need to maintain and enhance the competitiveness of the EU chemical industry. It also recognised the fact that the chemicals industry is at the heart of the community's sustainable development strategy.

  Most of the arguments proposed against the regulations concern loss of jobs and migration of companies from Europe.

  I do not believe enough emphasis has been given to the role and positive impact the chemical industry has, and will have increasingly, on sustainable development; and perhaps even more importantly from a UK perspective, on innovation.

  Chemistry is a fundamental and enabling science that is involved in nearly all industrial sectors. The UK will not achieve its objectives on innovation, and hence future competitiveness, nor will it achieve its sustainable development targets without a strong and vibrant chemistry base.

  The chemical industry has called for an extended impact assessment of the REACH proposals before they are finalised. This has been supported in writing by Mr Blair, President Chirac and Chancellor Schroeder. The UK Government is conducting its own impact assessment.

  We are concerned that none of the impact assessments that have been or are being conducted are wide enough. They are concentrating on the direct impact of the REACH proposals on the chemical industry without considering the wider impact along the supply chain or the socio-economic impacts.

January 2004

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