Strategically important metals - Science and Technology Committee Contents

Supplementary written evidence from Professor Robert Watson, Chief Scientific Adviser, Department for Environment, Food and Rural Affairs (SIM 00a)

Please find the responses to the questions from Graham Stringer, MP.


The primary aims of REACH are to enhance protection of human health and the environment, and to increase industry competiveness and innovation. This is done by making industry responsible for what they place on the EU market through the hazard assessments and advice on safe use and risk management they include with their registrations.

Manufacturers or importers of so-called "new substances" have had to notify data on potential risks since the 1980s.  However, there are also about 30,000 chemicals on the EU market that predate that requirement for notification and which are manufactured or imported in amounts of 1 tonne or more a year. Only a few hundred of those "existing substances" have been subject to full risk assessment and there are significant gaps in publicly available knowledge about even the highest production volume substances (1,000+ tonnes). That is an alarming knowledge gap that REACH exists to fill.

It is too early to say to what extent the aim of increasing industry competiveness and innovation will be achieved. By placing new and existing substances on an equal footing, REACH removes a strong signal against innovation. In addition, REACH puts a much greater emphasis on finding safer alternatives for dangerous chemicals, which will also be a strong incentive for innovation through the supply chain.


An importer or manufacturer of a substance, eg titanium, must register it with the European Chemicals Agency (ECHA) in Helsinki. Registration means producing a dossier of information, including:

  • intrinsic properties and hazards of the substance;
  • amount of manufacture/import;
  • identified uses and uses advised against;
  • guidance on safe use; and
  • information on exposure.

One of the key objectives in REACH is to obtain and share information about the properties of substances being manufactured, supplied and used in the EU. This ensures that registrations use existing data rather than commissioning new studies. REACH prohibits the duplication of animal testing.  This data sharing can then be followed up by a joint registration. Alternatively a registrant can go it alone.

A registrant has to pay a fee to ECHA. The highest fee payable is €31,000 (by a large company which manufactures/imports more than 1,000 tonnes of a substance each year and which chooses not to participate in a joint registration). A range of reduced fees is available for joint registrations, lower tonnages and smaller companies, with €120 being the lowest fee.

No registration fees or licences are required under REACH before a downstream user can handle a substance.

REACH provides for manufacturers and importers of a substance to join together in Substance Information Exchange Forums in order to share data, avoid duplication of any new testing, and prepare a joint registration. However, in addition manufacturers of some substances have set up consortia to manage the data gathering, although these are not a requirement of REACH. Letters of access to unofficial consortia cannot be policed by REACH although they would, of course, be subject to competition law.


A specific reference to Thallium going to landfill was also made. Under REACH, restrictions can be placed on the manufacture, marketing or use of dangerous substances.  No such restrictions exist in the case of thallium or its compounds. In addition producers of recovered substances do not have to register under REACH if the substance has also been registered as a virgin material. It is therefore difficult to see how REACH can be responsible for thallium waste ending up in landfills.

More generally on the avoidance of strategic metals going to landfill, one of the alternatives approaches we do favour is improved resource use and secondary recovery as a way of companies both handling risk and developing alternative sources of supply for key materials. We need to do more to move the focus up the waste hierarchy to prevent waste originating and to increase secondary recovery of valuable materials.

This is something we are already examining. For example, we have tasked WRAP, in our draft strategic steer, to increase their focus on materials efficiency, thus avoiding waste at the very outset, but also ensuring maximum economic benefit from those materials used. They are working with businesses and looking at the opportunities presented by new business models and the barriers to the recycling of precious metals, such as actual product design to aid in the easy separation and recyclability of materials. 

Professor Robert Watson
Chief Scientific Adviser
Department for Environment, Food and Rural Affairs

16 March 2011

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Prepared 17 May 2011