Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien
Brussels, 8 June 2004
A.I.S.E. POSITION PAPER ON THE COMMISSION PROPOSAL FOR REGULATION OF
THE EUROPEAN PARLIAMENT AND THE COUNCIL CONCERNING THE
REGISTRATION, EVALUATION, AUTHORISATION AND RESTRICTION OF CHEMICALS
(REACH) – COM (2003) 644
A.I.S.E. represents the Detergents and Maintenance Products Industry for household,
industrial and institutional use. These products support public health and hygiene to improve
the quality of life. This is why safety of our products to man and the environment is
paramount.
Therefore, A.I.S.E supports the overall political objectives of REACH to protect man and the
environment whilst maintaining the competitiveness of the whole European industry. As a
founding member of DUCC - the Downstream Users of Chemicals Co-ordination group – the
detergent and cleaning products industry is an active player in the debate on the EU
“Strategy for the Future Chemicals Policy”.
A.I.S.E. was pleased to note that some of the major concerns of downstream users, as
expressed during the consultation process, have been taken on board. In particular, A.I.S.E.
welcomes the explicit possibility for downstream users to participate at all stages of the
REACH process and to communicate uses of chemicals to their suppliers. A.I.S.E. also
welcomes the simplified reporting requirements.
However, A.I.S.E. would like to highlight the following areas of further development with a
view to strengthening the workability of the proposal and to minimise unnecessary
bureaucracy:
- A.I.S.E. welcomes the identification of uses to be submitted by downstream users to
the registrant. Moreover A.I.S.E. suggests to augmenting the concept of “undesirable
use” with “unsupported use”. “Undesirable use” should designate a use which the
registrant advises against only for safety reasons while “unsupported use” (an
additional term) would designate a use that is not supported by the registrant due to
the lack of data.
- A.I.S.E. strongly supports risk assessment as the basis for managing chemicals.
Indeed, both hazard and exposure must be taken into account as the risk of a given
chemical depends on how and where it is used (exposure) and not just on its intrinsic
property (hazard). This is the core concept of the joint A.I.S.E/CEFIC project entitled
“HERA – Human and Environmental Risk Assessment of ingredients used in
household cleaning products.” However, risk assessment requires appropriate
exposure information; hence the need to further define exposure conditions within the
context of the current proposal.
- For most downstream users in the supply chain a tiered approach on risk assessment
with simplified exposure information and going towards full exposure information (if
needed) is necessary to ensure workability for all parties involved. This is paramount
to ensuring the success of the system.
- A.I.S.E. favours grouping of substances for registration purposes.
- A.I.S.E. supports the use of dossiers required for other chemicals management
programmes (regulatory or voluntary, national or international) for submission under
REACH in their original format.
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A.I.S.E. still has concerns with regard to the authorisation and restriction processes
which should be based on risk assessment for all uses, including consumer products.
A.I.S.E. is also concerned that REACH may affect innovation, de-selection of
chemicals and higher costs for finished goods manufactured in Europe leading to
reduced market potential in particular for SME’s.
Taking note of the enlarged scope of activities for the EU Chemicals Agency, A.I.S.E.
still does not feel that the current proposal sufficiently allows the Agency to be an
effective player in the harmonised management of chemicals. Considering the
impending enlargement of the EU, a strong and effective Chemicals Agency is a
prerequisite to a workable and successful policy.
As a downstream user, the detergent and cleaning product industry has a critical role
to play in the chemical policy debate. A.I.S.E. is keen to contribute to further dialogue
with the European Institutions and interested stakeholders to achieve a regulation
which is truly workable despite being the most ambitious and far-reaching endeavour
in the field of health and environment.
-o–0–oNotes :
A.I.S.E. represents the Detergents and Maintenance Products Industry for household, industrial and
institutional use.
Through its 35 national associations in 30 countries, A.I.S.E. represents 900 member companies, of
which 60% are small and medium-sized enterprises. The soap, detergents and maintenance products
industry directly employs more than 150,000 people. The annual turnover in the 15 EU Member States +
Norway and Switzerland is 26,2 billion Euro (year 2001). It is estimated that the total market value
covered by the A.I.S.E.’s membership (30 countries) is about 35 billion Euro, both for consumer goods or
professional (industrial & institutional) applications (www.aise-net.org).
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DUCC (Downstream Users of Chemicals Co-ordination group) was founded in 2001 following the
publication of the European Commission's White Paper : "Strategy for a Future Chemicals Policy". The
group defines downstream users of chemicals as companies using chemical ingredients and formulating
those to place finished products (i.e. "chemical preparations") on the market. DUCC represents a variety
of associations currently totalling 7 members covering important industry sectors ranging from cosmetics
and detergents to aerosol, paints, adhesives, photographic and chemical distributors industries (see
attached DUCC leaflet).
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The objective of the joint A.I.S.E./CEFIC HERA project on “Human and Environmental Risk Assessment”
is to provide a common risk assessment framework for the household cleaning products industry. It
provides relevant safety information concerning the ingredients used in these products to the authorities
and the public, in an effective, efficient and transparent way (www.heraproject.com ).
-------------------------------For more information, please contact at A.I.S.E.:
A-M. Rodeyns
Deputy Director A.I.S.E.
Phone : + 32 2 238 83 71
anne-marie.rodeyns@aise-net.org