TOWARDS A WORKABLE REACH

1
TOWARDS A WORKABLE REACH

• Dr. Mari Pantsar-Kallio
• UPM-Kymmene, Environmental Affairs

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

Paper
X
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."

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.

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
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