EUParl Pres 31Aug04 finalhome.kpn.nl/REACH/downloads/euchemicalspolicypresentationarthur… ·...
Transcript of EUParl Pres 31Aug04 finalhome.kpn.nl/REACH/downloads/euchemicalspolicypresentationarthur… ·...
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New Proposals for Chemicals Policy:Effects on the competitiveness of the chemical industry(Project EP/IV/A/2003/07/03-2)
Presentation
Brussels,August 31, 2004
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The conducted study concentrates on the effects of the intended REACH legislation on the competitiveness of the Chemical industry
Objectives of the Study
The objective of the study is to specifically examine the competitiveness of the European chemicals sector in the future taken into account the amended REACH
proposal
The presentation of the results is structured in:
� Summary of results
� REACH-targets / comparison between the actual situation and the introduction of the framework legislation
� Definition of the chemical industry
� Approach for investigation
� Results of the analysis
� Consequences and recommendations
Arthur D. Little has been asked to conduct this study using its experience gained during the specific study on the potential effects of REACH on the German economy
EWG 04/165 (EU Chemicals Policy)
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The study shows significant risks for competitiveness of European chemical industry by REACH
Results of the Study
�The effects of REACH on the chemical industry strongly depend on the effects on the downstream users and their reactions
�Applying today's legislation proposal, the calculation model simulating this dependency to the downstream users reveals severe potential production and GDP losses for the chemical industry (incl. pharmaceuticals):
– GDP loss 2,9 %
– Production loss 24,7%
�The sub-sectors are touched in different strengths:
– Base/ Fine / Specialty Chemicals : 25% production loss (main sector being touched will be Fine and Specialty Chemicals)
– Consumer Chemicals: 50% production loss
�Interpreting the four relevant influence parameters of REACH (costs, time to market, duty to authorize, duty to disclose), concrete recommendations to minimize the risks of competitiveness decrease can be given
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Sustainable Development
The future EU chemicals policy targets to protect human health and environ-ment and to maintain/enhance the competitiveness of the EU chemistry
� Protection of human health and the environment
� Maintenance and enhancement of the competitiveness of the EU chemistry
� Prevention of fragmentation of the internal market
� Increased transparency
� Integration of international efforts
� Promotion of non-animal testing
� Conformity with EU international obligations according to the WTO
REACH Objectives
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REACH applies the principles of the existing regulation for new substances to all substances
Existing substances
Production quantity
(tonnes per annum)
Present requirement
New substances
Requirement according to REACH
for all substances
Comparison of existing and new EU legislation
< 0.01 none none none
0.01-0.1 none very limited "base set" testing2)
none
0.1-1 none limited "base set" testing3)
none
1-10 none "base set" testing data on physico-chemical, toxicological and ecotoxicological properties
10-100 data on hazard classes and use to ECB 1), 4)
"base set" testing "base set" testing
100-1000 data on hazard classes and use to ECB 1), 4)
"base set" testing +"level 1" tests
"base set" testing +"level 1" tests
> 1000 data on hazard classes, use, physico-chemical properties, toxicity, ecotoxicity to ECB 1), 4)
"base set" testing +"level 1" tests + "level 2" tests
"base set" testing +"level 1" tests + "level 2" tests
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REACH demands evaluations of intrinsic properties and expositionscenarios for each substance independent of the exposition risk
EU legislation versus legislation outside Europe
EU (fixed) Japan (risk contingent) USA (risk contingent)
Base SetTests
Level 1Tests
Level 2Tests
Bio-accumulation
Test
Chronic Toxicity Test
Screening Toxicity Test
Chronic Toxicity Test
Non-Biodegradable
BiodegrationTest
Safe Chemical
Non-Bioaccumulative
Bio-accumulative
Class I Specified Chemical
Class II Specified Chemical
Safe Chemical
ToxicNon-Toxic Toxic Non-
Toxic
ToxicNon-Toxic
Structure Activity Meeting
StandardReview
(Risk Ass. II)
Regulatory Action
Early Drops from Further
Review
ChemicalReviewMeeting
� Focus Drops� Exemptions
(Grant or Deny):– Test
Market– Low
Volume– Low
Exposure
FocusMeeting
(Risk Ass. I)
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The portfolio of the chemical industry can be divided in four sectors
Portfolio of the Chemical Industry
• Base chemicals 37.7% • Specialty & fine chemicals 28.8%• Pharmaceuticals 23.3%• Consumer chemicals 10.2%
Four sectors of chemical industry(portion in %)
Perfumes & cosmetics
Soaps & detergents
Pharmaceuticals
Crop protection
Paints & inks
Other specialty chemicals
Fine chemicals
Fertilizers
Industrial gases
Other basic inorganics
Man-made fibres
Plastics & synthetic rubber
Petrochemicals
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Drivers of competitiveness in the chemical industry have to be considered on basis of the specific sectors
Consumer Chemicals
Fine and Specialty
Chemicals
Base Chemicals
Price, Location Differentiation, Value added Performance
Speed, Flexibility, Management of
Complexity
Scale, Technology Cycle
Management
Co
mp
an
y I
nte
rnal D
rivers
Business Relevant Drivers
Drivers of Competitiveness of the Chemical Industry
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Percentages shares
The chemical industry mainly acts a producer and supplier of inter-mediates within the overall industry
Application Areas of the Chemical Industry
Construction
Manufacturing
Agriculture
Service & administration
Final consumption
5,4%
6,4%
16,4%
30,3%
41,5%
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The EU chemicals policy influences almost all industrial value chains – far beyond the chemical industry!
Value portion of final product
1 %
0 %
Material
10 %
100 %
Components
Sub-System
System
Final Product
Piezo-Ceramics
Ceramic Valve
Direct Injection
DieselEngine
� Reduction of gas consumption
� Reduction of emissions
Substance
Chemicalsubstance
Value Chain
Electronic/mecha-nical equipment
AutomobileOEM
Material producer
Chemical Industry
CompanyType
Automotivesupplier
Chemical Industry in the Value Chains
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Corporate strategies
EU chemicals policy
Effects Effects Effects Effects
Industry value chain
Key success factors for the industry
– Legislative implementation
Industrialadded value
Regulatory environment
schematic
Success and per-
formance
The potential consequences have to be investigated by the key success factors for the different industries and their dependencies on chemicals
Basic Framework for the Approach
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Levers of the EU Chemical Policy
Results of the Analysis
ParameterPositive Conse-
quences (examples)Negative Conse-
quences (examples)
Costs Savings due to increases in volume limits and simplification
Increase due to REACH load on today's EINECS substances
� Execution of the registration process
� Execution of the authorisation process
� Number of intermediates to be registered
� Number of use categories (intended vs. unintended)
� Degree of disclosure
Time Savings due to simplification in case of new registration
Loss by internal and external efforts for REACH
Duty of Authorization
Harmonisation of product portfolio
Potential ban of certain substances
Degree of Disclosure
Increase for interested stakeholder
Loss of know-how
Four critical parameters have been identified – their consequences will be directly dependent on the execution pattern of the EU chemical policy
Levers of the Chemical Policy
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The estimates are based on a calculation model specifically developed on the basis of a bottom-up analysis
Design of the Community legislation
Scenario variables
Consequences for the German economy
Changes in gross added value
Calculation Model
Scenario facts
Industry data
Change in production volume of considered industries and value chains
Change in gross added value and production volume for German manufacturing industries
Scenario variables
Change in gross added value for German economy
Calculation Model
� Same/similar industry structure within the different industry sectors in EU as considered for Germany
� Same/similar ratio between end user chemicals and intermediates in EU as in Germany
� Same/similar reaction of industry towards the new legislation in EU as experienced in Germany during the study by the interviews – as a consequence, the same production losses for each industry sector as derived for the German manufacturing industry are assumed for the sectors on the European base
The model has been developed on basis of data gathered in Germany for the relevant industries. To apply this model several conditions have to set:
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The model results in a production loss of about 25% for the complete category of chemical industry which includes Pharmaceuticals
Production and GDP Losses
Manufacturing industry within the EU 15 12.6 10.6
Food and tobacco industries
Textile and apparel industry
Leather industry
Wood industry (excluding furniture manufacture)
Paper, publishing and printing industry
Coking, oil refining, production of fertile materials
Production of rubber and plastic goods
Glass industry, ceramics, processing of rock, stone and mineral products
Metal production and processing, manufacture of metal products
Mechanical engineering
Production of office equipment, data processing equipment; electrical engineering
Vehicle construction
Production of furniture, jewellery, musical instruments, recycling
0.4 3.6
1.4 38.8
0.5 57.2
0.1 5.9
1.7 19.6
0.7 33.1
2.9 24.7
2.1 44.6
0.1 1.5
0.6 4.6
0.3 2.2
0.8 5.1
0.4 2.9
0.2 5.9
Change in gross value added (%)
Production loss (%)
Chemical industry incl. Pharmaceuticals
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For further analysis the sectors of chemical industry according to the calculation model have to be evaluated
Manufacturing IndustryUsers outside the
Manufacturing Industry
Chemical Industry
Manufacturing Industry without Chemical Industry
Chemical Industry
� Industrial gases
� Dyes/pigments
� Primary materials
� Plastics
� Rubber
� Paints and coatings
� Pharmaceutical primary materials
� Adhesives
� Essential oils
� Man-made fibres
� Chemical finishing products
� Other chemical products (excluding building chemistry)
� Fertilisers
� Crop protection
� Soaps
� Personal hygiene products
� Photographic chemistry
� Data carriers, blank
� Building chemistry
Examples:
� Agricultural sector
� Other production activities
� Service providers
� Final consumers
Chemicals Sectors as defined in the Calculation Model
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The consumer chemical industry will suffer significant production losses by REACH
Manufacturing IndustryUsers outside the
Manufacturing Industry
Chemical Industry
Manufacturing Industry without Chemical Industry
Chemical Industry
The production loss has been derived as the consequence of the downstream user industry. Basis has been the input-/ output data
No quantitative differen-tiation between Base Chemicals and Fine/ Specialty Chemicals can be done by this approach
The production loss has been calculated on basis of market analysis, industry data etc.
Examples:
� Agricultural sector
� Other production activities
� Service providers
� Final consumers
Production loss:25.0%
Production loss:50.7%
Consumer Chemicals
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The production losses result from different contributions of the four identified parameters
Effect of the four Parameters
Chemical (sales outside manufacturing industry without pharmaceuticals)
22.5% 29.2% n.a. 10.0% 50.7%
Rubber 3.6% 36.2% n.a. 10.0% 44.6%
Textile 16.8% 25.7% n.a. 31.3% 57.2%
Semi-conductors 4.6% 16.0% n.a. 22.5% 37.9%
TotalDegree of
Disclo-sure
Duty of Authori-zation
TimeCosts
Production loss due to the parameter
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The fine and specialty chemical industry will be touched by effects of all four parameters while the basic chemical industry is not strongly influenced
Business relevant drivers of competitiveness
REACH Parameters
Price� Costs
Differentiation Value Added Performance
� Time to market
� Duty of authorization
� Degree of disclosure
Industry
Chemical industry delivering in price sensitive areas with
high volume usage of
specialty chemicals
� Fine / Specialty Chemicals
Chemical industry delivering in areas with high innovation force� Fine/Specialty Chemicals
Base/ Fine/ Specialty Chemicals
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The high risk of competitiveness decrease of the chemical industry by REACH is forecasted – recommendations for lowering risks are obvious (1)
Consequences / Recommendations
The time demand and cost of the system must be kept as low as possible to limit the burden on industry without losing sight of the objectives of the White Paper. The aims should be, e.g.:
� to limit the number of necessary test
� to reduce administration costs both within companies and externally
� to limit registration maintenance costs
� to take account of existing information as far as possible
� ….
The number of registered uses can be limited, for example, by introducing exposure categories.
Testing and evaluation of substances must be directed towards specific risks and guided by existing measures to use test resources optimally; exclusive orientation towards intrinsic substance properties or production quantities cannot be recommended.
The time periods required by the system (information/data generation, processing by the authorities) before the intended manufacture or use takes place must be kept short. They should not delay the market entry of new products.
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Authorisations should be risk-based, if possible in conjunction with positive lists for categories of use.
The process and product knowledge of companies must be optimally protected – disclosure must be made with the participation of the affected companies
To limit the negative effect on the competitiveness of German industry, the EU should strive to achieve standard regulations for substances worldwide.
The high risk of competitiveness decrease of the chemical industry by REACH is forecasted – recommendations for lowering risks are obvious (2)
Consequences / Recommendations
Further concrete formulation of legislation proposal and/or REACH implementation processes enables additional simulation and information
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ERMA-conference_031010.ppt/w-af 20The Architects of Your Success
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Contact partners
Arthur D. Little
Arthur D. Little
Ralf BaronPractice Manager General and Process Industries
Arthur D. Little GmbH Martin-Luther-Platz 26D-40212 Düsseldorf
Tel: +49-211-8609-511Fax: +49-211-8609-511email: [email protected]
Dr. Christian WeigelPractice Manager Chemistry
Arthur D. Little Austria GmbHKärntner Ring 6A-1015 Wien
Tel: +41-1.515.4132Fax: +41-1.515.4123email: [email protected]
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Top Management Consulting
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