EU New "Chemicals Policy": Comments of the American Metal and Metal-using Industries
On July 10 the Ad Hoc Metals Coalition, a group of metal producing and using industries based in the United
States that concerns itself with environmental and health issues, submitted comments on the draft Chemicals
Policy of the European Union. NiDI is a member of the Coalition.
The Chemicals Policy is often referred to as REACH, reflecting the hierarchy of requirements for chemicals:
Registration, Evaluation, Authorization of
Chemicals. It is an ambitious undertaking that, inter alia, places on industry the
burden of demonstrating that the "chemicals" (broadly defined) it uses are safely produced and managed
through their life cycles.
Nine specific areas were noted and suggestions offered to improve the current draft. Of chief importance
were:
Treatment of minerals, ores and mineral concentrates: These raw materials come from nature
and are not "chemicals" until subjected to various metallurgical processes. Moreover, organic raw materials
such as natural gas, crude oil and coal are unconditionally exempted from the chemicals policy requirements.
This exemption should apply to inorganic raw materials as well.
Treatment of wastes destined for recycling: The Coalition notes that "wastes" currently
destined for recycling apparently fall within the new regulation whereas wastes destined for disposal (e.g.,
landfill) do not. Given the cost and complexity of complying with the Policy, it will become more economic to
dispose of wastes than to recycle them. This is a perverse outcome that could be avoided if wastes destined
for recycling were exempted from the Policy.
For a more detailed discussion of these and other issues raised by the Ad Hoc Metals Coalition, go to Comments.
To visit the consultation site on the new Chemicals Policy, go to http://europa.eu.int/comm/environment/chemicals/whitepaper.htm
