REACH 评估.pdf
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1、5/7/20071REACH Impact Assessment in REACH Impact Assessment in retrospectretrospectSome selected topicsSome selected topicsPublic hearing EESC Public hearing EESC CCMICCMI“Evolution of the European Chemical IndustryEvolution of the European Chemical Industry”Dresden Dresden 3 May 20073 May 2007Paul
2、Arnoldus Paul Arnoldus European Commission,on behalf of DG ENTR,unit G1(REACH)European Commission,on behalf of DG ENTR,unit G1(REACH)This presentation does not necessarily reflect This presentation does not necessarily reflect the official opinion of the Commissionthe official opinion of the Commiss
3、ionEuropean Commission5/7/20072OutlineOutline1.1.IntroductionIntroduction2.2.Impact Assessment:Impact Assessment:from White Paper to Consultation Documentfrom White Paper to Consultation DocumentBusiness Impact Assessment;work at ECBBusiness Impact Assessment;work at ECB3.3.Extended Impact Assessmen
4、t October 2003Extended Impact Assessment October 20034.4.Further work on Impact AssessmentFurther work on Impact AssessmentKPMG,IPTS and Textile studyKPMG,IPTS and Textile study5.5.Benefits studiesBenefits studiesRPA,Sheffield,DHI,RPA,Sheffield,DHI,OekopolOekopol6.6.Critical look on cost estimates C
5、ritical look on cost estimates 7.7.Concluding remarksConcluding remarks5/7/20073IntroductionIntroductionREACH Impact Assessment was part of policy preparationREACH Impact Assessment was part of policy preparation Meant to inform the decisionMeant to inform the decision-making processmaking process B
6、ased on various preliminary REACH versions and not the Based on various preliminary REACH versions and not the finally adopted Regulation!finally adopted Regulation!Based on limited set of data and on assumptionsBased on limited set of data and on assumptionsHow useful afterwards?How useful afterwar
7、ds?Overall picture rather than precise predictionsOverall picture rather than precise predictions Source of data on characteristics of the sector:Source of data on characteristics of the sector:products,supply chains,companies,markets products,supply chains,companies,markets?Can still be used,also f
8、or new purposes,Can still be used,also for new purposes,but only when its limitations are understood&respectedbut only when its limitations are understood&respected5/7/20074In the beginning In the beginning The Impact Assessment work on REACH started The Impact Assessment work on REACH started alrea
9、dy at the time of the White Paper(2001)already at the time of the White Paper(2001)Just before the Commission launched Just before the Commission launched the the“Better RegulationBetter Regulation”initiative&COMinitiative&COM s IA Guideliness IA GuidelinesThroughout the process:Throughout the proce
10、ss:?Combination of contract work and inCombination of contract work and in-house workhouse work?Stakeholders consulted Stakeholders consulted?Data limitations encounteredData limitations encountered?Attention for methodologyAttention for methodology5/7/20075Business Impact Assessment(BIA)Business Im
11、pact Assessment(BIA)by RPA&Statistics Swedenby RPA&Statistics SwedenTwo phases in the work:Two phases in the work:20022002-2003 2003“Original Business Impact AssessmentOriginal Business Impact Assessment”on the basis of the White Paper proposalson the basis of the White Paper proposals 2004:2004:“Re
12、visedRevised Business Impact AssessmentBusiness Impact Assessment”on the basis of the proposal put up for Internet Consultationon the basis of the proposal put up for Internet ConsultationPioneer work,still source for data on Pioneer work,still source for data on“baseline situationbaseline situation
13、”e.g.how many firms,of which sizee.g.how many firms,of which sizehow many substances and in which volume,et cetera.how many substances and in which volume,et cetera.and for information on the buildand for information on the build-up of the cost appraisalsup of the cost appraisalsWork still available
14、 on Work still available on EuropaEuropa Internet pages DG ENTR,Internet pages DG ENTR,but but see for short update/overview RPA study Dec 2006see for short update/overview RPA study Dec 20065/7/20076ECB assessment of testing costs ECB assessment of testing costs Elaborate calculation framework Elab
15、orate calculation framework based on wide array of economic and toxicological data based on wide array of economic and toxicological data Original aim was to show Original aim was to show the cost saving effect of the cost saving effect of QSARsQSARs&other alternatives to testing&other alternatives
16、to testingSee See Europa Internet pages on REACH Impact Europa Internet pages on REACH Impact AssessmentAssessment forforthe original paper the original paper“Additional testing needsAdditional testing needs”Later also used in the First Reading(end 2005)for new costs apLater also used in the First R
17、eading(end 2005)for new costs appraisalspraisalsin particular on the registration requirements for low volumesin particular on the registration requirements for low volumes(prioritisation in the volume band of 1 to 10 tonne/year)(prioritisation in the volume band of 1 to 10 tonne/year)See See REACH
18、Impact REACH Impact AssessmentAssessment InternetInternet-page for page for a short note reporting on such an exercisea short note reporting on such an exercisewhich does not fully reflect the final registration arrangementswhich does not fully reflect the final registration arrangements!5/7/20077Ch
19、aracteristics of early Characteristics of early Commission appraisalsCommission appraisals Much weight on registrationMuch weight on registration,as first requirement,involving most substancesas first requirement,involving most substances Focus on Focus on Direct CostsDirect Costsi.e.the costs which
20、 follow directly i.e.the costs which follow directly from regulatory requirementsfrom regulatory requirements Orientation on substancesOrientation on substances,rather than firmsrather than firmse.g.assumption on rather effective registration consortia,e.g.assumption on rather effective registration
21、 consortia,with some assumed duplicity of work.with some assumed duplicity of work.Typical estimates combined unit costs with unit volumesTypical estimates combined unit costs with unit volumesrepeated for all identified subrepeated for all identified sub-tasks of an requirementtasks of an requireme
22、nt5/7/20078Hurricanes on the Horizon?Hurricanes on the Horizon?Meanwhile,in the outside world Meanwhile,in the outside world 2 alarmist studies got much attention2 alarmist studies got much attention1.1.Study by Arthur D.Little(ADL)Study by Arthur D.Little(ADL)1 1ststversion Dec 2002version Dec 2002
23、commissioned by BDI commissioned by BDI(German Manufacturing Federation)(German Manufacturing Federation)2.2.Study by Mercer,for French industry Study by Mercer,for French industry-1 1ststversion April 2002version April 2002Whereas NGOs had very high expectations of the benefits of Whereas NGOs had
24、very high expectations of the benefits of REACH(e.g.WWF study)REACH(e.g.WWF study)The ADL study has been reputed for:The ADL study has been reputed for:1.1.Predicting very strong negative Predicting very strong negative“knockknock-onon”effects,effects,up to 2.3 up to 2.3 mlnmln job losses,in Germany
25、 alone(!)job losses,in Germany alone(!)2.2.Allegedly containing very serious methodological flawsAllegedly containing very serious methodological flaws5/7/20079Commission Extended Impact AssessmentCommission Extended Impact Assessmentaccompanying COM proposal of October 2003accompanying COM proposal
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