REACH Impact Assessments
The Commission’s impact assessment on the REACH Regulation The Commission has carried out various studies
to assess the impact of the REACH Regulation:
Analysis of studies
discussing benefits of REACH Various studies have been carried out to
determine the costs of REACH for businesses and the European
economy at large, however, the description and quantification
of benefits for human health, the environment and for businesses
has been addressed to a much lesser degree. Well funded information
on benefits of REACH is scarce. This is due to the lower emphasis
on benefit assessment and the various difficulties connected
to benefit estimation - such as the dependency of impacts
on the behaviour of industry actors, the lack of data on cause-effect
links, current chemicals related damage or baseline information
at enterprise level. However, the fact that benefits are created
is substantiated at qualitative and quantitative level by
the studies analysed on the request of the Commission. The
report identifies the types of benefits linked to actual mechanisms
or policy outcomes of REACH and extracts how those benefits
have been assessed and quantified. Since the realisation of benefits largely
depends on enterprises taking their responsibility for safe
products, the study recommends to motivate companies by quantifying
expected benefits based on case studies. Furthermore, an illustration
of how enterprises could integrate REACH mechanisms in their
business strategies in such a way that benefits would be generated,
might encourage enterprises to be pro-active, foster quality
differentiation in the market and thus promote the implementation
of REACH in their own supply chains. The study was performed
by the German Institute for Environmental Strategies, Ökopol,
and finalised in February 2007. Full
study (pdf 634KB) "Announcement
effect" in the market related to the candidate list of
substances subject to authorisation Substances identified under REACH as 'substances
of very high concern' (SVHC) will be gradually included in
Annex XIV of the REACH Regulation: Substances subject to authorisation.
One aim of the authorisation is that these substances are
progressively substituted with safer alternatives where economically
and technically viable. To announce the potential substances
for authorisation beforehand on a publicly available candidate
list might be an incentive for producers and users of these
substances to start proactively looking for safer substitutes. Especially companies representing the end
of the supply chain are highly interested in an EU wide harmonised
list of substances regarded as very dangerous. With regard
to the different roles in the supply chain, it seems as if
it will be mainly the task of formulators to substitute SVHC
in their preparations and that they will often react to a
strong demand by their customers. It is yet not clear to what
extent the manufacturers and importers of chemicals will invest
in the development of alternatives. They might not behave
proactively if they see no incentives (like a strong customer
demand or the potential to capture new markets) to invest
in risk reduction as long as it is not legally required. However, importers, producers and professional
recipients of articles will prefer articles without substances
of very high concern. The retailers and owners of consumer
brands may demand SVHC-free products from their suppliers
to ensure product safety and give no reason for criticism.
The study was performed by the German Institute for Environmental
Strategies, Ökopol, and finalised in January 2007. Full
study (pdf 333KB) Environmental
benefits of REACH Within the framework of the further work
on impact assessment, the Commission had also launched a study
to assess the benefits of REACH on the environment. The study assessed the impact of current
chemicals releases on the environment and on humans who are
exposed via the environment. The long-term benefits of REACH
were estimated to be up to €50 billion over the next 25 years,
depending on the method used. The benefits have been calculated
by three different approaches: via the willingness of citizens
to pay for avoiding the environmental damage, via an identification
of monetary costs caused by environmental damages, and via
an estimation of the current costs that could be avoided if
the release of chemicals would be better controlled (e.g.
less expensive drinking water purification). The study was
performed by the Danish environmental consultancy DHI between
October 2004 and September 2005. Executive
summary (pdf 45KB)
- Full
study (pdf 523KB) Further Work on impact
assessment Subsequent to the publication of the REACH
proposal in October 2003, several impact assessments commissioned
by stakeholders appeared. The estimates of the costs in these REACH
impact assessment studies varied widely. As a result of the
discussion with stakeholders, the Commission agreed to undertake
further impact assessment work, complementary to its extended
impact assessment. Two major studies were conducted under a Memorandum of Understanding (pdf 139KB) between the
Commission and the industry associations UNICE and CEFIC.
Commissioned by the industry associations, KPMG consultants
elaborated detailed business case studies in the sectors of
inorganics, automotives, flexible packaging and high tech
electronics. Another study by the Joint Research Centre of
the Commission (DG JRC/IPTS) focussed on the situation in
the new Member States, through business case studies and surveys
in the chemicals sectors of Poland, Estonia and the Czech
Republic. Environment Commissioners Stavros Dimas and
Enterprise and Industry Commissioner Günter Verheugen jointly
chaired a High Level Group which discussed the results of
these further impact studies and drew specific conclusions (Press
release of April 2005) Extended impact assessment Before adopting its proposal on REACH in
October 2003, the Commission published an extended
impact assessment (pdf 114KB) which assessed the benefits for health as well as the
costs for industry and the future Chemicals Agency of the
proposed Regulation. Total costs were estimated between €2.8
and 5.2 billion over 11 and 15 years respectively. Health benefits were estimated in the order
of magnitude of €50 billion over the next 30 years. This figure
was based on an illustrative scenario which had been developed
with the support of recognised international organisations
such as the World Bank and World Health Organisation. A series of further analyses and a Commission
funded study (Report
of March 2003 pdf 337KB) broadly confirmed
these results. The additional benefits to the environment
were expected to be significant but were not quantified (Report
of June 2003 pdf 2,5MB). In view of the expected economic, social
and environmental impacts of REACH, the Commission considered
that the balance required by the EU Sustainable Development
Strategy had been achieved. Disclaimer: Note that the reports herein
referred to were prepared by contractors at the request of
the European Commission and do not necessarily represent the
views of the European Commission. |