REACH Costs Acceptable

The German Advisory Council on the Environment believes claims that the European Commission's chemical policy reforms pose a risk to the German chemicals industry and to Germany's economic development are unjustified. Studies commissioned by trade and industry associations on the economic impact of the reforms are methodologically unreliable in that they systematically overestimate the costs of the reforms and neglect the opportunities it brings.
With REACH (Regulation, Evaluation and Authorisation of Chemicals), the proposed regulatory approach aims to consolidate available knowledge on the properties, risks and uses of chemicals and to close the considerable gaps in knowledge on existing chemicals. An authorisation process is planned for substances that give cause for high concern. The Council sees REACH as a meaningful approach to reform that deserves further constructive development.
With a position paper published today, the German Advisory Council on the environment aims to help place the costs debate on a
more objective footing. Based on a critical analysis of the premises underlying the cost estimates, the Council's most significant findings are as follows:

• The existing cost estimates are systematically too high. The cost calculations take into account neither the opportunities for relatively cost-effective implementation provided for in the Commission's Consultation Document nor the savings made from using existing data.
• Considering the small scale of the costs incurred by REACH compared to chemicals industry sales, the feared impacts on the industry as a whole are hardly plausible. The underlying models have fundamental methodological weaknesses in that they systematically overestimate the economic impacts.
• Given its global impact, determined implementation of REACH system objectives could have positive outcomes in terms of competition and innovation. There is potential for worldwide replication and diffusion of the REACH system as a whole or of some of its key components.

With all the uncertainties surrounding cost-benefit estimation, more recent analyses indicate that the benefits to human health outweigh the costs incurred. The harm caused to animals and plants – not yet evaluated in monetary terms – would also need to be considered.

For further information please contact the Council's Secretary General, Christian Hey, on +49 (0)30 263696-110.

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