ICC views on the European Commission REACH proposal

WSSD highlighted the synergy among development, trade, commercial activity and environmental protection, emphasizing implementation that integrates economic, social and environmental considerations, built on cooperation and partnership. In our view, the REACH proposal risks undermining existing international negotiations and cooperative ventures on chemicals in international commerce.

The REACH proposal does not adequately reflect economic, development and trade aspects of sustainable development, and would have negative economic impacts throughout the global economy with questionable environmental benefit. ICC is particularly concerned by its lack of consideration for trade impacts and the special circumstances of developing countries.

ICC's main concerns with the REACH proposal are the following: - the questionable cost effectiveness and unnecessary increase of costs for chemical producers, users, and the general public; - its potential for trade discrimination against non-EU companies in many sectors; - the negative effect that such a unilateral EU initiative could have on existing global harmonization and cooperation efforts on chemicals; and - the market access barriers and negative impacts on developing countries seeking to export chemicals or manufactured goods to the EU.