APPENDIX 13
Memorandum from BASF
INTRODUCTION
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.
HUMAN HEALTH
AND THE
ENVIRONMENT
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.
INDUSTRY COMPETITIVENESS
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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