Far Reaching Consequences

Following negotiations that lasted some three years, on December 18, 2006 the Council of the European Union unanimously adopted the REACH (registration, evaluation, authorisation and restriction of chemicals) Regulation. With the stated key objectives of REACH being the registration of chemical substances and to transfer a measure of responsibility for the safe use and handling of chemicals and hazardous substances from EU member states to those companies producing and importing such substances, this is a piece of legislation that the tyre industry cannot ignore. And it comes into effect on June 1.

As a tyre wears the chemicals contained within are released back into the environment, and while research indicates that the pollution created by tyre wear particles accounts only a small proportion of traffic pollution, there are numerous substances involved. According to the 2006 annual report released by the European Tyre and Rubber Manufacturers’ Association (ETRMA), the European tyre and rubber industry utilises approximately 4,000 raw materials, of which 90 per cent are preparations. Therefore it is perhaps not surprising that the report also indicates the industry has been identified as belonging amongst the five downstream users to be most heavily affected by the REACH provisions.

Companies will be required to register the chemicals they use with the Helsinki based European Chemicals Agency, and only those substances that have completed the registration process will be granted the necessary authorisation to be manufactured within or imported into the EU. The Commission estimates the economic cost of the registration process for all industries as being approximately somewhere between £1.6 and £3.5 billion over an 11 year period, however these figures are disputed by independent studies, such as those conducted by Mercer in France and ADL/BDI in Germany that claim the actual figure will be somewhat higher. Taking into account the very high number of individual chemicals used in the manufacture of tyres and related products, the costs involved could add up very quickly, with obvious knock-on effects for the European tyre industry. As Franco Bisegna, a senior counselor for CEFIC (the European Chemical Industry Council) stated during discussions on REACH, “a tyre is composed of caoutchouc (natural rubber) and a lot of chemicals. If I have to add the cost of registering all these substances the price is so high that I could decide [it] is less expensive to produce it out of the European Union and then to import it.”

A paradox of the REACH Regulation is that completed tyres manufactured outside of the EU are exempt from REACH, whereas the individual components that go into the manufacture of a tyre are not. The European Rubber Chemicals Association (ECRA) believe this will make it much easier for car manufacturers to import tyres rather than acquire them from European producers, and job cuts will most likely follow. “We are concerned that the alarming results of the business impact studies conducted by ADL/BDI for Germany and by Mercer for France will become reality. ERCA expects that REACH will be particularly devastating for the rubber industry.”

Striking an appropriate balance between environmental and economic considerations will never be a straightforward task, and there is no disputing some of the merits of the REACH Regulations. However it would appear that REACH does little to address tyre-related environmental degradation while doing much to harm the industry. Tyre wear particles will still be released into the atmosphere at similar levels to now – the only difference being that the particles will more likely come from tyres manufactured outside of the EU. Tyres & Accessories has spoken to a leading European manufacturer regarding the anticipated impact of REACH from their perspective, and will report on this in an upcoming issue.