1. ETUC Conference on REACH - 11-12 March 2005 Improving REACH ETUC proposals for REGISTRATION Werner SCHNEIDER DGB, Germany

2. ETUC Conference on REACH - 11-12 March 2005  general obligation for manufacturers and importers  to obtain information on their substances and  to use this knowledge to manage them safely  applies to 30 000 substances manufactured or imported into the EU in quantities > 1 tonne per year  Failure to register means that the substance cannot be manufactured or imported Registration

3. ETUC Conference on REACH - 11-12 March 2005 Registration Deadlines Yr 0 Yr 0 +3Yr 0 + 6Yr 0 + 11 (2017+) >1000 t + CMR 100 - 1000 t 10 - 100t 1 - 10 t

4. ETUC Conference on REACH - 11-12 March 2005 Registration requires manufacturers and importers to submit:  Technical Dossier: starting at 1 tonnes per year identity physiochemical properties toxicological data ecotoxicological data  Chemical Safety Reports: starting at 10 tonnes per year hazard classification (human health and environment) PBT and vPvB assessment if dangerous or a PBT or vPvB :  exposure assessment incl. exposure scenarios  risk characterisation The larger the volume, the greater the amount of data to be supplied

5. ETUC Conference on REACH - 11-12 March 2005 Loopholes in the REACH proposal Registration Dossier Quantities (t / y)Nb of Substances Technical DossierCSR 1 -1020,000YESNO 10 - 1004,600YES 100 -10002,800YES > 10002,600YES  No Chemical Safety Report for 20,000 out of 30,000 substances to be registered  Lack of basic information in the 1-10 t range

6. ETUC Conference on REACH - 11-12 March 2005 ETUC proposals  CSR for all registered substances  To ensure possible risks are controlled for 30 000 substances.  To achieve a better balance between costs and benefits.  To increase the synergy between REACH and OSH legislation.

7. ETUC Conference on REACH - 11-12 March 2005 ETUC proposals  Acute toxicity and biodegradability tests for substances in the 1-10 t range  To ensure proper classification for 20 000 low volume substances.  To enable very basic level for protecting workers, consumers and the environment.

8. ETUC Conference on REACH - 11-12 March 2005 OSOR : One Substance, One Registration  ETUC welcomes this proposal aimed at reducing the implementation costs to EU industry and the authorities.  ETUC’s precondition for supporting OSOR is that producers (manufacturers/importers) and downstream users remain fully responsible and legally liable.