TOWARDS A WORKABLE REACH

Dr. Mari Pantsar-Kallio

UPM-Kymmene, Environmental Affairs

UPM 2

Basic assumptions of REACH

REACH uses definitions and concepts from the existing chemicals legislation and applies them also to not man-made chemicals.

Supply chain assumption

Chemicals producers

ProducersFormulators

Downstream users

Articles

Paper

Producer of recovered

paper?

Paper makers

Producer of virgin pulp? X

UPM 3

Outcome of the KPMG study

REACH requirements, as they stand today, impose a high level of uncertainty on recycling/recovery business.

"The case study for (in)organics (metals, paper and cement) showed that REACH definitions and concepts are difficult to be applied to the highly complex primary and recycled / recovered materials as their exact composition is not known.

If recovered materials remain within the scope of REACH and frequent analyses for them were required, the increased costs could, in the worst case, push companies to shift back to the use of virgin materials."

UPM 4

Plenary voting in the Parliament

+ Cellulose pulp is included in Annex 2

+ Waste is clearly exempted

+ New recital: (28a) … wastes and materials used as secondary raw material or as a source of energy should exempted...

and this Regulation must not introduce requirements which reduce the incentives for such recycling and recovery.

+ Concentration limit 0.1 % for substances in articles

- Concentration limits in 6.2 do not apply if the producer cannot exclude any exposure of the public or the environment

- Recovered paper is not clearly exempted.

UPM 5

CEPI Amendments to the Council

- To include Cellulose pulp in Annex 2

- Recovered paper must stay outside the scope of REACH.

- To delete the narrow definition for substances which occur in nature

- Retain the draft proposal of the Council for Article 6.2.

Cellulose fibers

UPM 6

CONCLUSIONS

If the right pieces are put in the open places in a puzzle…

… the paper industry is on a way towards a workable REACH