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A presentation on EU GSP Plus: Opportunities for Pakistan

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1 A presentation on EU GSP Plus: Opportunities for Pakistan
Pakistan Institute of Trade and Development, Islamabad.

2 Scheme of the Presentation: (Contnd)
Introduction Qualification Criteria Pakistan’s Position under Qualification Criteria List of GSP+ beneficiary countries Pakistan’s Export Profile to EU Sectoral Coverage under GSP Plus Potential for Pakistan’s Exports under GSP Plus along with tariff rates vis-a-vis other countries

3 Scheme of the Presentation:
Key Advantages Rules of origin in EU Required Standards and Regulations in EU Opportunities for Pakistan GSP+ Challenges Sector Specific Challenges

4 Introduction: (Contd)
GSP+ is a scheme of preferential tariffs, unilaterally extended with the objective of increasing trade capacity among developing nations. The EU GSP is extended through three arrangements: GSP, GSP Plus and Everything But Arms (EBA). GSP+ is not extended automatically, countries have to apply and then it is subject to the EU Parliament’s approval under the given eligibility criteria which is binding on the requesting state. The EU Parliament passed the Scheme and final count of voting was 409 in favor and 182 against. EC introduced GSP in 1971. GSp benificiaries….. GSP Plus : 10 EBA: The European Parliament is made up of 766 Members elected in the 28 Member States of the enlarged European Union. Since 1979 MEPs have been elected by direct universal suffrage for a five-year period. To beef up the lobbying effort further Minister of State for Commerce Engr. Khurram Dastgir Khan toured various EU Capitals to meet with EU Ministers and other stakeholders He also spent two days meeting MEPs in Strasbourg where EU Parliament was in session. Governor Punjab also came to Strasbourg to lobby with MEPs

5 Introduction: Government of Pakistan through its diplomatic and trade circles made intensive efforts to get this legislation passed through EU Parliament Under GSP Plus, 6274 tariff lines are eligible, of which 6269 are duty free. Textile products are classified as “sensitive” (HS Code chapters and 61-63) under GSP Plus. GSP Plus will result in duty free access in EU for 91% of its total imports GSP Plus beneficiaries must ratify and implement 27 international conventions. click here GSP Plus status will be awarded for a period of 10 years and its status is reviewed after every three years. Product coverage The general arrangement covers over 6200 tariff lines out of a total of approximately 7100 tariff lines with non-zero tariffs. Roughly 2300 lines are not covered by the scheme as standard tariffs (so-called “most favoured nation” or MFN) are already at 0. Products are split into non-sensitive and sensitive categories:  Non-sensitive products enjoy duty-free access, and represent about 2400 lines;  Sensitive products (a mixture of agricultural, textile, clothing, apparel, carpets and footwear items) benefit from tariff reductions (typically 3.5 percentage points on ad valorem duties) compared to the standard most favoured nation tariff. These represent about 3800 lines.

6 GSP Plus: Qualification Criteria
Tariff preferences are conditional to commitments for ratification and implementation of 27 international conventions * (16 relating to human rights and labor rights (11 relating to governance and development issues). GSP Plus is extended to countries considered “vulnerable” in their trade profile. Share of seven largest GSP sections: For exports to the EU, the share of top 7 sections should be greater than 75% of the total exports of that country to EU Share in the total GSP imports to the EU: In order to remain eligible for GSP Plus the share of total imports from one country to EU should not be more than 2% of the total imports of EU. Regulation (EU) No 978/2012 of the European Parliament and of the Council of applying a scheme of generalized tariff preferences and repealing Council Regulation (EC) No 732/20081 establishes eligibility criteria for special incentive arrangement for sustainable development and good governance (GSP+). According to point (a) of Article 9(1) of this Regulation a GSP beneficiary country may benefit from the tariff preferences provided under GSP+ if it is considered to be vulnerable due to a lack of diversification and insufficient integration within the international trading system. The countries meeting the vulnerability criteria2, as defined in Annex VII of Regulation 978/2012 are listed below. Vulnerable countries must meet the criteria listed in Article 9(1) of the Regulation before they are granted GSP+.

7 Pakistan’s Position under Qualification Criteria
GSP + criterion Pakistan’s position The exports of beneficiary country for seven largest sections should be greater than 75% 94.6% Per capita income to be less than US$ 4000 (Not to be high middle income country) US$ 1,260 Import Vulnerability threshold (2%) 1.60%

8 List of GSP+ beneficiary countries
Armenia Azerbaijan Bolivia Cape Verde Costa Rica Ecuador Pakistan Mongolia Paraguay Peru Georgia GSP+ – deep tariff cuts for 10 countries which ratified and implemented international conventions relating to human and labour rights, environment and good governance;

9 Pakistan’s Export Profile to EU
The total Pakistani export to the European Union in 2013 was US$ 6.58 billion. Total imports of EU-27 countries in 2012 was US$ 5.71 trillion. Pakistan has been struggling to improve its exports to the EU as compared to other developing countries. Grant of GSP Plus status is a significant development and big opportunity for Pakistan to enhance its exports to EU. Bangladesh being an LDC had duty free access and its exports to the EU were US$ Billion in 2012 Our products like home textiles and garments faced tariffs up to 9.6%, fabrics etc 6.4% Footwear up to 12%, Leather up to 5.5%, Stiff competition from most of our competitors because they had more preferential access

10 PAKISTAN-EU BILATERAL TRADE
YEAR EXPORTS (US $ MILLION) IMPORTS (US$ MILLION) TRADE BALANCE (US$ MILLION) 2,770.50 2,050.80 719.70 3,066.80 2,049.00 1,017.80 3,726.90 2,390.80 1,336.10 4,073.40 3,138.80 934.50 4,247.70 4,966.80 (-) 4,627.30 4,756.50 (-) 5,185.40 5,222.00 (-)   4,412.40 5,645.40 (-) 4,599.54 4,542.32 57.22 6,181.00 4,383.90 5,358.42 4,518.46 839.96

11 Sectoral Coverage under GSP Plus:
The GSP+ provides tariff concessions in 6200 plus tariff lines. These products fall in the following sectors: Agricultural Products Mineral Products Chemical and Related Products Non - Consumable Animal and Plant Products Textiles and Apparel Non - Metallic Mineral Products Metals and Manufactured Articles Made Mostly of Metal Other Highly Manufactured and Special - Purpose Goods

12 Chapters covered under GSP Plus with Pakistan’s exports and tariff
Pakistan’s Exports to EU for Chapters covered under GSP Plus is US$ 5.27 billion and chapter wise tariff and Exports are given. Click here

13 Total ad valorem equivalent tariff Ecuador's Exports to EU in 2012
High Potential Chapters for Pakistan covered under GSP Plus (MFN tariffs are above 15%)  All Values in USD Million    Top three competitors S. No Product code Product label Pak's Exports to EU in 2012 EU's total Imports in 2012 Total ad valorem equivalent tariff Peru's Exports to EU in 2012 Ecuador's Exports to EU in 2012 Costa Rica's exports in 2012 1 '04 Dairy products, eggs, honey, edible animal product nes 0.05 38% 0.16 0.00 2 '02 Meat and edible meat offal 0.07 3 '17 Sugars and sugar confectionery 9.97 34% 0.89 3.61 3.89 4 '24 Tobacco and manufactured tobacco substitutes 4.12 29% 0.74 14.39 0.15 5 '20 Vegetable, fruit, nut, etc food preparations 8.79 22% 231.95 75.57 99.55 6 '01 Live animals 0.08 7 '11 Milling products, malt, starches, inulin, wheat gluten 1.42 20% 2.53 0.44 0.01 8 '10 Cereals 67.87 16% 14.93 0.98 9 '16 Meat, fish and seafood food preparations nes 0.90 36.31 525.58 0.48 10 '07 Edible vegetables and certain roots and tubers 5.31 15% 164.29 26.37 24.02 Total 98.50 451.88 646.94 128.10

14 Considerable Potential Chapters for Pakistan' covered under GSP Plus
32 chapters covered under GSP Plus where MFN tariff ranges from 5% to 15% and Pakistan is tapping the EU market of US$ 3.74 billion. Where as the total EU imports of these chapters are of US$ 1.39 trillion. The list of trade, tariff and competitors for these chapters can access here

15 Average Potential Chapters for Pakistan covered under GSP Plus
45 chapters covered under GSP Plus where MFN tariff ranges from 0% to 5% and Pakistan is tapping the EU market of US$ 1.42 billion. Where as the total EU imports of these chapters are of US$ 3.62 trillion. The list of trade, tariff and competitors for these chapters can access here

16 Key Advantages of GSP Plus:
The scheme will no longer end every 3 years,. Rather, it will last for 10 years. Better focus on those countries most in need By getting preferential access to the Union market, the scheme will assist developing countries in their efforts to reduce poverty and promote good governance and sustainable development The scheme’s tariff preferences should focus on helping developing countries having greater development, trade and financial needs. not be classified as a high middle income country and 5 largest sections of its GSP exports be more than 75% of total GSP covered exports to EU (lack of diversification in exports) Its GSP covered exports to EU be less than 2% of total EU GSP covered imports

17 Rules of Origin under in EU under GSP+
Products originate in a particular beneficiary country if they are: - wholly obtained in that country, or - sufficiently worked or processed there. In general terms, products are wholly obtained in a particular beneficiary country (or in the EU, in the case of bilateral cumulation) Globalization of manufacturing processes has resulted in many products being made from parts, materials etc. coming from all over the world. Such products are not of, course, wholly obtained but they can nevertheless obtain originating status. WHAT ARE 'WHOLLY OBTAINED PRODUCTS'? (ARTICLE 75): In general terms, products are wholly obtained in a particular beneficiary country (or in the EU, in the case of bilateral cumulation) if only that country has been involved in their production. Even the smallest addition or input from any other country disqualifies a product from being "wholly obtained". Therefore, it applies mainly to things occurring naturally and to goods made entirely from them. What can be considered as "wholly obtained" in a beneficiary country, or in the European Union, is laid down in an exhaustive list in Article 68. WHAT ARE 'SUFFICIENTLY WORKED OR PROCESSED' PRODUCTS? (ARTICLE 76): In practice, except for naturally-occurring and related products, situations where only a single country is involved in the manufacture of a product are relatively rare. Globalisation of manufacturing processes has resulted in many products being made from parts, materials etc. coming from all over the world. WHAT IS MEANT BY "CUMULATION OF ORIGIN"? Bilateral Cumulation (Article 84) Under bilateral cumulation, materials originating in the EU, within the meaning of the EU GSP RoO, and further worked or processed in a beneficiary country, are considered to originate in the beneficiary country. However the working or processing carried out there has to be more than the "insufficient working or processing" explained in 2.6. This concept is also known as "donor country content". • Example: for embroidered handkerchiefs (classified HS 6213) to obtain GSP origin in a beneficiary country, the one of the criteria to be applied is " Manufacture from unembroidered fabric, provided that the value of the unembroidered fabric used does not exceed 40% of the ex-works price of the product "; meaning that non-originating unembroidered fabric may be used but representing a value not exceeding 40% of the exworks price of the product. However, if the fabric used originates in the EU, then the cumulation provisions allow it to be considered to be originating in the beneficiary country as the further manufacturing process goes beyond "insufficient" within the meaning of Article 68. See point 4.2 below for evidence of the EU origin for materials to be used for bilateral cumulation.

18 Rules of Origin in EU under GSP+
WHAT IS THE EU GSP PROOF OF ORIGIN? There are three principal forms of proof used in the context of the EU GSP: The certificate of origin Form A, used as proof of origin at import into the EU and in regional cumulation The Invoice Declaration, and which can be used for low value GSP exports The Movement Certificate EUR, which may be used as may an invoice declaration, when goods are exported to beneficiary countries from the EU in the context of bilateral cumulation HOW ARE THESE DOCUMENTS USED? The Form A and invoice declaration are used by importers in the EU for GSP imports as evidence in support of their request that the goods be imported at preferential rates of customs duty. They are therefore important documents and have a value equal to the amount of customs duty that is waived by the EU. There are three principal forms of proof used in the context of the EU GSP7: • The certificate of origin Form A, used as proof of origin at import into the EU and in regional cumulation, see point 2.7 above (Article 97l and Annex 17)8. • The Invoice Declaration, and which can be used for low value GSP exports (Article 97m and Annex 18). • The Movement Certificate EUR1, which may be used as may an invoice declaration, when goods are exported to beneficiary countries from the EU in the context of bilateral cumulation, see 2.7 above (Article 97v and Annex 21). HOW ARE THESE DOCUMENTS USED? The Form A and invoice declaration are used by importers in the EU for GSP imports as evidence in support of their request that the goods be imported at preferential rates of customs duty (often nil). They are therefore important documents and have a value equal to the amount of customs duty that is waived by the EU. In this sense they serve a similar function to a cheque, a banknote or banker’s draft and must be treated with similar respect. Like a banknote, the Form A must be printed to a very precise specification in terms of colour and background pattern (see Annex 17) and, like a cheque or banker’s draft, it must be carefully completed. Guidance on the completion of the Form A is given in point 5.6 below. The Form A is also used as evidence of origin for the purpose of applying the regional cumulation of origin provisions (see point 2.7). In a regional group, goods originating in country B (of the same regional group) for further processing before being exported to the EU (Article 72a(4)). The invoice declaration must also conform to a very precise formulation (see Annex 18 and below) and may be used by exporters in beneficiary countries when exporting goods of a low value (see point 5.12 below for further information) The movement certificate EUR.1 is used by exporters in the EU, as well as in Norway or Switzerland, when they send originating goods to beneficiary countries. EC exporters who are "approved exporters" may use an invoice declaration (instead of a movement certificate EUR.1), when exporting materials or parts of EU origin to a GSP beneficiary country for incorporation into a product there for export to the EU as an originating product under the EU GSP.

19 European Union Standards
Registration, Evaluation and Authorization of Chemicals (REACH): REACH requires all chemicals produced or imported into the EU in volumes above 1 ton per year to be registered. CE Marking: To sell certain products in the 28 EU member states, as well as in Norway, Liechtenstein, Switzerland, Turkey and Iceland, U.S. exporters are required to apply CE Marketing whenever their product is covered by specific product legislation.  EU Flammability Requirements: There are no harmonized EU flammability requirements for home and house textiles. Standards - European Union EU Member States have widely differing standards, testing and certification procedures in place for some products. These differences may serve as barriers to the free movement of products within the EU and can cause lengthy delays in sales due to the need to have products tested and certified to account for differing national requirements. Registration, Evaluation and Authorization of Chemicals (REACH)--REACH requires all chemicals produced or imported into the EU in volumes above 1 ton per year to be registered. This includes, all products, such as textiles and apparel, that may contain chemicals or chemical products. For more information, see the European Community-Enterprise and Industry REACH website. U.S. exporters may also find helpful information and assistance on the U.S. Commercial Service EU REACH webpage.  CE Marking--To sell certain products in the 28 EU member states, as well as in Norway, Liechtenstein, Switzerland, Turkey and Iceland, U.S. exporters are required to apply CE markingwhenever their product is covered by specific product legislation. The CE mark certifies that a product has met EU health, safety, and environmental requirements, which ensure consumer and workplace safety. All manufacturers in the EU and abroad must meet CE mark requirements where applicable in order to market their products in Europe. Once a manufacturer has earned a CE mark for its product, it may affix the CE mark to its product, and then the product may be marketed throughout the EU without having to undergo further modifications in each member state. Unfortunately, there is no comprehensive list of the products that require a CE mark. Therefore, it is the manufacturer's responsibility to determine if a product requires a CE mark from various directives issued by the European Commission. Some products require the conformance to more than one directive. For more information, see the Export.gov webpage on CE marking.  Carpeting sold in the EU must have a CE marking, as required under the Construction Products Directive (89/106/EEC). Under the directive, materials intended for construction must comply with health, safety and environmental requirements as follows: mechanical strength and stability; fire safety; hygiene, health and environment; safety of use; sound nuisance; and energy savings and heat retention. Attesting the conformity of a floor covering with the requirements of EN must be done in part by the producer, but may also require third party testing and certification. A construction product is defined as any product that is produced for incorporation in a permanent manner in a construction project, thus various other textile products could be covered. For more information, see the U.S. Commercial Service report on The European Union’s Directive on Construction Products.  EU Flammability Requirements--There are no harmonized EU flammability requirements for home and house textiles. Whereas curtains and drapes are not addressed by EU-legislation, carpets and rugs must meet specific flammability requirements. Where EU law is not available, national law is applied. For example, in Austria, certain textile products must meet OENORM standards, which are either defined by the Austrian Standards Institute or adapted from EU legislation. Textile floor coverings or curtains, for example, must pass several fire tests before they are admitted to the Austrian market. 

20 European Union Standards
Product Liability and Product Safety: The General Product Safety Directive (GPSD) aims to ensure that products placed on the market are safe, and places the obligation to place only safe products on the market on producers and to some extent on distributors. Biocidal products: Whenever biocidal products are added to textile and apparel products to give them specific properties (e.g. repel insects or avoid allergens) the provisions of the Directive 98/8/EC must be followed. Emission Trading System (ETS): The European Emission Trading System aims to improve and extend the greenhouse gas emission allowance trading scheme of the Community. Product Liability and Product Safety--The General Product Safety Directive (GPSD) aims to ensure that products placed on the market are safe, and places the obligation to place only safe products on the market on producers and to some extent on distributors. For more information, see the EUROPA Consumer Affairs GPSD webpage.  The GPSD provides the framework that covers flammability, though it does not specifically address requirements. The use of voluntary standards helps comply with the law. See the Consumer rights for child safety products - European Child Safety Alliance European Consumer Safety Association.  The European standards:BS EN Textiles - Burning Behaviour of Children’s Nightwear - Specification describes the requirements. BS EN 1103 Textiles - Fabric For Apparel - Detailed Procedure for Determination of the Burning Behaviour describes how to burn fabrics for compliance with EN Biocidal products--Whenever biocidal products are added to textile and apparel products to give them specific properties (e.g. repel insects or avoid allergens) the provisions of the Directive 98/8/ECmust be followed. For more information, see the European Commission Environment website on biocidal products. Emission Trading System (ETS)--The European Emission Trading System aims to improve and extend the greenhouse gas emission allowance trading scheme of the Community. In this framework, textile companies can be impacted by the ETS directive if they have combustion installations with a total rated thermal input exceeding 20MW.  Local standards organization and other resources: European Committee for Standardization - CEN European Commission - Enterprise and Industry European Standards Commission’s Technical Regulations Information System - TRIS (technical regulations) U.S. Commercial Service-U.S. Mission to the European Union: EU Standards and CE Marking.

21 Testing and Certification Mechanism in Pakistan
Pakistan National Accreditation Council (PNAC) has achieved a milestone of Mutual Recognition Arrangements (MRAs) with International Laboratory Accreditation Cooperation (ILAC) and Asia Pacific Laboratory Accreditation Cooperation (APLAC).Now Pakistan is included in the list of countries having equivalence status for accreditation of testing and calibration laboratories all over the world. Accredited In Pakistan, Accepted Everywhere In The World can access here Testing & Calibration LabsEngineering & Calibration Labs The department of Engineering and Calibration labs is headed by a director to undertake the following activities.The accreditation of calibration and testing labs in different disciplines including but not limited to Engineering, metrology, electronics, mechanical, Textile etc. in accordance to ISO/IEC Matters pertaining to APLAC. Industrial Labs The department of industrial labs is headed by a director to undertake the following activities.The accreditation of testing labs in different disciplines including but not limited to chemical, microbiological, pharmaceuticals, food, agriculture, vetenary, fuel etc. in accordance to ISO/IEC Matters pertaining to ILAC.

22 Opportunities for Pakistan (Cntnd…)
Pakistan can earn more than USD 1 billion worth of goods by expansion of product lines through the GSP Plus duty-free status. Competitors in the T&C sector; China, India, Vietnam, Thailand, Indonesia have no duty free access as well as no preferential access – 10% to 14% duty advantage. In chapters 61 and 62 (knitted and woven apparel), an additional US$280 million can be earned in the first year (13.5% of current exports of products within the 6% threshold. In leather products (chapters 41 & 42), an additional US$97.1 million (17.5% of existing import levels) in the first year can be earned. For all other products, an additional US$ 250 million in the first year (17.5% of current exports) can be earned.

23 Opportunities for Pakistan
Massive opportunities to provide employment due to increase in exports. Increased revenue for the exchequer in form of taxes from enhanced trade opportunities. Massive possibilities to earn foreign investment by inviting entrepreneurs from China and other countries to invest in industries with potential for rapid export expansion through GSP Plus. China’s dwindling share in the global textile and clothing business, because of surging cost of production there, and Pakistan’s expected duty-free access to the European Union (EU) from next year, are being viewed by the textile industry as a ‘once-in-a-lifetime’ kind of opportunity for the country.

24 Challenges… Pakistan has been a large supplier of textile and leather goods to the EU for long time but quality control and product standards remain a concern Product concentration in textiles and clothing sector and leather sector The key challenges to increasing Pakistan’s exports to the EU are found to lie primarily within the border. Which include costs of production lower productivity volatile prices of raw materials in the textiles and plastics sectors difficulty in achieving the required market standards costs of certification lack of customer confidence due to the poor security environment Challenges for Pakistan: Pakistan has long been a supplier of textile and leather goods to the EU and other global destinations and therefore has quality and safety standards in place with deviations resolved at firms’ level, but no sector or regulatory level complaints of note. While quality control and product standards remain a concern for the producers, as indicated in the stakeholder consultations, product quality and testing will not be considered as specific to GSP+.

25 GSP Plus: Sector Specific Challenges
Textile sector Voluntary Social Standards (VSS) are compliance challenge for manufacturers and exporters Quality standards and certification Oeko-Tex 100 certification is awarded in four product classes only textile items for babies textiles used away from the skin furnishing materials Increasing demands for the EU Eco-Label Challenges of Textile sector Voluntary Social Standards (VSS) also known as “Private Standards” are also compliance challenge for manufacturers and exporters. These are social standards applied by major global buyers which their vendors globally are required to maintain as a condition for trade relationship. In general, these private standards more or less is in conformity with the buying or buyer’s country own legal requirements, especially in the areas of basic respect for worker rights, gender promotion and avoidance of child labour. According to the Small and Medium Enterprises Development Authority (SMEDA) the European Eco-Label is said to compare to Oeko-Tex 100, but reportedly less well known and less asked for in purchase requirements by European buyers.

26 GSP Plus: Sector Specific Challenges
Tanneries and leather sector NTB, Product standards are imposed on HS 4201, HS 4202, HS 4203. Lack of harmonization at the HS 8 digit level in leather goods and garments sectors Maximum Residue Levels (MRLs) standards Labor and environment related standards social accountability standards Challenges of Tanneries and leather sector The leather sector comprises a number of processes ranging from processing to finished goods and, as such, the sector is subject to different legislation covering agriculture, environment public health and consumerism. From the exporters’ perspectives, as in textiles, quality standards are the most important NTB. Product standards are imposed generally on saddler and harness products (HS 4201); trunks and suitcases, etc. (HS 4202); articles of apparel and clothing (HS 4203); and footwear (HS 64). There are also global standards on products such as safety shoes. There is no general obligatory labelling requirement covering all leather products at European level. EU labels borne by other leather products indicating leather as materials exists in some member states and on a voluntary basis. The EU leather association (COTANCE) has discussed the idea of harmonization of leather goods and garments sectors. Challenges of Ethanol sector On the regulatory side, Pakistan’s Ethanol sector is affected by REACH, as indicated by feed-back from the stakeholder review. Given the complications involved, leading ethanol manufacturers in Europe have formed an Ethanol REACH Association to enable the joint submission of a high quality dossier for registration. Ethanol manufacturers (EU and non-EU), importers and other entities that have interest in the registration of ethanol may join the Association. This platform would provide the Pakistan ethanol industry with technical input. On the production side, a number of sugar factories in Pakistan were cited in the last two years on environmental grounds and for posing a risk to public health (violations under Pakistan’s Environmental Act) with COD (chemical oxygen demand), BOD (biochemical oxygen demand), TSS (total suspended solids) and oil and grease higher than national environmental quality standards (NEQS). This aspect can be addressed under the existing mechanisms.

27 GSP Plus: Sector Specific Challenges
Plastic sector Lack of production compliances Testing and certification facilities Costs of compliance Heath Safety and Environment (HSE) and Occupational Health and Safety (OHAS) Frequent Asked Questions Click here for FAQ’s Challenges of Plastic sector Exporters to the EU will need to ensure compliance with the relevant legislation covering safety, health and environmental concerns. As for all other identified sectors, plastics will be subject to REACH, which has a direct impact on every member of the plastic supply chain, including additives producers, plastics producers, plastics converters and retail businesses. The Plastics Exposure Scenario Team (PEST) formed by the key associations representing the plastics supply chain has produced a list of Generic Exposure Scenarios that cover most of the known plastics uses and has translated them into “REACH use descriptors”.

28 Thank You


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