O o d h e a d p u b L i s h I n g L i m I t e d

3.3
The growing importance of European
legislation
The powerful influence of European Union (EU) environmental and product
standards on International textile processing and production is beginning to
be noted. Kanwar (2008) notes that
European environmental and safety rules conceived in Brussels are
increasingly becoming de facto Asian standards in the factories that churn
out the televisions, clothing and furniture that fill most homes. The weight
and size of the European Union’s expanded market – about 450 million
people, compared with 300 million in the United States – has lifted the
profile and application of EU rules.
… If you manufacture globally, it is clearly simpler to be bound by the
toughest regulatory standard in the supply chain. As China and other
sourcing countries lean towards the European approach, US companies
are also beginning to work to EU rules.
One of the major tools will be the recently introduced REACh legislation
(Registration, Evaluation, Authorisation and Restriction of Chemicals, EU
Regulation, 2006). This complex legislation replaces 40 existing laws. REACh
was adopted into EU legislation on 1 June 2007 despite extensive lobbying
by chemical interest groups. A special agency (European Chemicals Agency,
ECHA) has been established in Helsinki to manage the procedures and was
operational from 1 June 2008.
A pre-registration period, from June to December 2008, allowed the
continued production and import of chemicals during the transitional phase.
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Because of the amount of work involved, the ECHA will prioritise the
assessment of chemicals of greatest concern and chemicals produced in the
greatest volumes.
November 2010 is the registration deadline for:
• high-volume chemicals (quantities of 1000 tonnes and above, chemicals
in peak production);
• carcinogens, mutagens and substances toxic to reproduction above 1
tonne/year; and
• substances classified as very toxic to aquatic organisms (R50/53) above
100 tonnes.
Medium production chemicals (produced in quantities of 100 tonnes and
more) must be registered by May 2013, while May 2018 is the registration
deadline for quantities of 1 tonne and more (low production). The extent of
toxicology testing increases progressively as the tonnages increase from 1
tonne to 1000 tonnes. Certain ‘low-risk’ chemical substances will be excluded
from registration under REACh.
Substances of very high concern (SVHC) are:
• carcinogens;
• mutagens;
• substances which are toxic to reproduction;
• persistent, bio-accumulative, and toxic substances (PBTs);
• very persistent and very bio-accumulative substances (vPvBs); and
• substances causing equivalent concerns (such as endocrine disruptors).
Currently 900 SVHCs are listed and another 600 SVHCs are expected over
the next 11 years.
REACh raises a number of supply chain reporting issues, even for products
manufactured outside Europe. All importers of goods into the EU are
required to register all substances in their imports that exceed 1 tonne per
year. They must notify ECHA if the imports contain substances that are
dangerous and the concentration of the substance is higher than 0.1% of the
weight (Weyler, 2007).
Additional concerns for the textile industry are that specialty chemicals,
such as wool-specific dyeing assistants, will need additional toxicity testing.
Around 90% of the 1500 textile specialty chemicals are produced in volumes
below 100 tonne a year. Examples of textile materials used in Europe in
higher quantities include certain carriers (250 tonnes per year) and reactive
black cotton dyestuff (more than 1000 tonnes per year). Manufacturers will
either need to increase prices to cover toxicology testing, possible reformulation
costs and licensing fees or withdraw the chemicals from the market. There
are additional reporting obligations on users of the chemicals (Sedlak and
Pellizari, 2005; Nuthall, 2007; Weyler, 2007.
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REACh is currently causing concerns through the global textile chains.
Briefings to the trade have been made in China, and several articles have
appeared in recent months in the international textile trade magazines. Concerns
have also been raised at World Trade Organization (WTO) meetings that
REACh could restrict access to EU markets. Issues have been raised concerning
the complexity and ambiguity of REACh, issues of inconsistent implementation
across member states and problems for SMEs. Twelve of the major trading
countries, including the United States, Argentina, Australia, Japan, Korea,
China, Mexico and Thailand, have threatened to launch a disputes case
based on WTO technical barriers to trade, asking the EU to liberalise REACh
(Hogue, 2007).