Greening the supply chain: protecting consumers - and retailers - through an improved REACH

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Greening the supply chain:

protecting consumers - and

retailers - through an improved


Michael Warhurst

EU Chemicals Policy

WWF European Policy Office, Brussels

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Why is WWF interested in chemicals?

Problems with greening the supply chain

REACH - how can it help?

Optimising REACH - improvements needed

Realism on impact assessment of REACH

REACH priorities for retailers and the supply



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Why is WWF interested in


The problems caused by toxic chemicals are a global

priority for WWF

Wildlife - and humans - throughout the world are

contaminated by industrial chemicals

And there is considerable evidence of wildlife (and human)


WWF is working to support a more sustainable production

and use of chemicals

We consider that REACH is a key part of this work

WWF has therefore launched an international campaign in

favour of a strong REACH:

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Contamination - part of the problem

A growing number of industrial chemicals are known to

contaminate wildlife and people, for example:

Brominated flame retardants

Contaminating people and wildlife across the world

Two phased out in Europe (penta and octa)

Deca is in increasing use, despite contamination of polar

bears, birds of prey and people

Even though industry claimed it wouldn’t accumulateThe EU decided in May not to phase out Deca, in the face of

aggressive industry lobbying

Perfluorinated chemicals (PFCs)

Including PFOS (Scotchguard) PFOA (used in teflon

manufacture and telomers (used in coatings, break down into PFOA)

Contamination by PFOS and PFOA exists across the world

PFOS has been voluntarily phased out, PFOA and telomers are

in widespread use


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My perfluorinated chemicals

From WWF’s sampling of the blood of 47

people for 101 chemicals.

All 45 samples (including mine) analysed for

PFCs contained these 7 PFCs:



All unregulated in EU

A liability in future?

Perfluorooctanoate (PFOA) F F F F F F F F F F F F O-F F O F

Perfluorooctane sulfonate (PFOS)

F F F F F F F F F F F F F F F F F S O O O www .p anda .o rg /d etox


34%of samples contained ‘Deca’, including one with the highest concentration ever published. O Br Br Br Br Br Br Br 2,2',3,4,4',5',6-Heptabromodiphenyl ether (BDE183)

O Br Br Br Br Br Br

2,2',4,4',5,6'-Hexabromodiphenyl ether (BDE154)

O Br Br Br Br Br Br O Br Br Br Br O Br Br Br Br Br O Br Br Br Br Br

2,2',4,4',5,5'-Hexabromodiphenyl ether (BDE 153) 2,2',4,4',6-Pentabromodiphenyl ether (BDE 100) 2,2',4,4',5-Pentabromodiphenyl ether (BDE 99) 2,2',4,4'-Tetrabromodiphenyl ether (BDE 47)


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Current problems with

greening the supply chain

Poor information flow

Difficult for downstream users and retailers to find put

what chemicals are in the products they buy

Difficult for producers to find out how their chemicals

are used

Lack of good quality safety information on chemicals

Lack of information on alternatives

Hard to make decisions on substitution due to

pervasive lack of safety data on existing chemicals

Even if information exists, it may be difficult to get hold

of, as there is no single source

A system biased against new substances

New substances require safety data, existing

substances don’t, so new substances are penalised.

Slow regulatory action on the worst chemicals

Very slow processes to evaluate and restrict existing

chemicals do not protect consumers or users

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REACH - how can it help?

Improved transparency and communication through the

supply chain:

On chemical properties flowing down the supply chain,

creating a more educated market

On chemical uses, flowing up the supply chain, giving

suppliers a better understanding of what services are needed

Easier introduction of new chemicals onto the market, and

removal of the perverse subsidy on older chemicals

An authorisation system which will promote - and

sometimes oblige - substitution of chemicals with the

worst properties

Strengthening this will increase the driver for green chemistry

REACH will ensure safety information is available on


Producer responsibility on the chemical industry, providing

protection for downstream users

Improved public confidence in the use of chemicals,

leading to improved investment and recruitment.


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Optimising REACH

-improvements needed

Our highest priority is to improve the authorisation


We must ensure that it is an


method to


the worst chemicals

and then

push for their phase out

wherever safer alternatives are available


An increase in openness and transparency

Provision for information flow in the article supply


In current REACH text information flow ceases once

chemical or preparations enter article, e.g. fabric

Consumer Right to Know

Improved control of chemicals in imported articles

See next page

A restoration of recently removed safety tests for

1-10t chemicals, and independent auditing of

registration dossiers

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Chemicals in imported articles


comes in at REACH+11 years


The current text will allow articles to be imported into

Europe containing unregistered chemicals.

It only requires notification if there is a known release of a

dangerous chemical which is present in more than 1 tonne per ‘article’, and which “may cause harm to human health or the environment”.

This approach will be unworkable

E.g. Enforcement will be tied up in arguments about the

definition of individual articles

E.g. red chairs vs blue chairs

A more workable and enforceable approach:

Importers must register if >1 tonne in all the articles they


consistent with legislation on imported substances and preparations

We would expect importers to operationalise this in a

straightforward way:

Specifying to suppliers to use chemicals registered in REACH (& listed in internet database)

If not possible, should start dialogue with importer re registration

This solution could also resolve concerns in current text re


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Realism on impact

assessment of REACH (I)

Which policy would cause:

very large

” costs leading to “

redesign and

re-equipping of large sectors of vital industry...,smaller

firms going out of business...and an effect on inflation

and employment nationally and internationally

According to CEFIC ???


Phase out of CFCs in order to protect the ozone layer

These impacts did not happen

Industry has a long history of exaggerating impacts

of future legislation

see WWF “Cry Wolf” report, on the DetoX campaign

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Realism (II)

Many claims have been made about the costs of


Notably by BDI/ADL (Germany) & Mercer (France)

These studies have been heavily criticised by economists,

and are extremely misleading.

They have been extremely politically effective, and are still


Commission impact assessment:

Direct costs of REACH to the chemicals industry of €2.3

billion over an 11 year period€0.5 per person per year for the EU

the amount the European Chemical Industry spent in 1999 on environmental improvements relating to waste.

Costs to downstream users are estimated to be between

€2.8-5.2 billion, including €2.3 billion passed on from the chemical industry.

Many other assessments now exist too

some even mention health and environmental benefits!

general message - REACH costs are small compared

with other cost variabilities e.g. oil, exchange rates


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REACH priorities for retailers

and the supply chain?

Ensure producer responsibility remains in place

With no data no market - CEFIC is undermining this:

CEFIC paper: “Do: ensure that the registration system

becomes a pure database, with no banning of substances

Ensure decision making is not captured, and

enforcement capacity exists at Member State level

Ensure balance maintained between Agency and

Member States

Improve Authorisation:

So it can deal with all chemicals of very high concern

So it pushes substitution

Improve information flow, including from substances

in articles

Improve process for dealing with substances in

imported articles

Don’t lobby for them to be ignored

Remember your interests are not the same as the

chemical industry’s

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The current regulatory system makes it very difficult to

green the supply chain

E.g. Lack of information flow, new substances penalised

REACH has the potential to improve this, but needs to be

improved to ensure that:

The worst chemicals are identified and then phased out if

safer alternatives are available.

Improving controls on chemicals in imported articles

To create an more open and transparent system, maximising

information flow to all parties.

E.g. information flow on substances in articles

The REACH debate has been distorted by exaggerated

impact studies - it is time to return to the real world.

Retailers and downstream users need to be aware of

that their interests differ from the chemical industry’s

If REACH is not effective and precautionary, NGOs will

need to start a campaign for a new chemicals policy

It is crucial to finish REACH, so we can all benefit

from the improvements it should bring.




Related subjects : Retailers and consumers