The goal of the EU's REACH legislation is to increase information on chemicals and their effects on human health and the environment. The Finnish Forest Industries Federation considers this a worthy goal that should be supported. However, it is important that legislation is as clear and effective as possible so that environmental and health objectives can be achieved without weakening industry's competitiveness. During the reading process the proposal has developed in the positive direction.
It is important for the forest industries that pulp and recycled paper be excluded from REACH. The forest industries in Finland use about 1.2 billion euros worth of materials classified as chemicals a year. About 75% of this consists of harmless natural materials - clay, talc and chalk. The forest industries' goal is not to compromise on environmental protection, although the importance of cost effectiveness is emphasized.
The REACH proposal has significant cost effects for the forest industries. The proposed legislation will put pressure on the price of chemicals, weaken the availability of small-volume and special chemicals, and lengthen the period required to bring new products to market. The forest industries operate on global markets and cannot simply add extra costs to the prices of products.
One problem with the REACH proposal is that its definitions are not suitable for natural materials and cause interpretation difficulties. In Britain's compromise paper the definition of natural materials does not cover pulp. It would be clearest if pulp were excluded from REACH's scope. Another possibility would be to redefine natural materials.
Secondly, recycled paper is an important raw material for the forest industries, and continuing its use must be protected in the REACH legislation. It appears that waste will be excluded from the application area, but the provisions for materials contained in products would apply to products containing recycled paper. With regard to recycled paper the flow of information in the supply chain, which is a key principle in REACH, breaks when it reaches the consumer. In this respect the proposal's provisions are open to interpretation and difficult to put into practice.
Thirdly it is important to set a limit of 0.1% for the obligation to indicate materials contained in products, as Britain's compromise paper proposes. The obligation to indicate materials should also be limited to materials that are subject to permit procedures.
Veera Eskelin, Development Manager, Finnish Forest Industries Federation, tel. +358 40 561 6638, firstname.lastname@example.org