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Global chemicals giant BASF estimates it could cost around 75 million euros to comply with Britain's chemicals regime if it leaves the European Union
.
The post-Brexit plan largely replicates the EU's REACH regulation and aims to ensure regulatory coherence
.
The company estimates that, along with other industry associations, the average REACH registration cost per business entity is between EUR 50,000 and EUR 70,000 per substance
.
This registration cost includes the compilation of the dossier and the value of the data or research conducted to produce the dossier
.
“BASF continues to advocate for a pragmatic approach whereby existing EU REACH registrants should not pay again to access data from UK REACH
.
Drawing on his direct experience registering substances for BASF under REACH, he said these were "not unreasonable estimates"
.
In addition to this fee, which is conservatively estimated at 65 million euros, the UK government has also instituted a document processing fee in line with REACH
.
Hollis said the U.
K.
"has largely copied the EU's fee regulations without taking into account the smaller market size
.
He added: "We accept this cost for the EU market, but it is disproportionate to pay the same for the smaller UK market
.
"
The Withdrawal Bill encourages UK policymakers to replicate EU regulations as much as possible to avoid disruption
.
However, Hollis said: "In this area, the copy-and-paste approach does not take into account important factors, with the result that there are potential disruptions and higher costs to supply chains across the UK and EU
.
"
He added that the fee "does not result in any new information to protect consumers, workers or the environment.
.
.
[it] is merely an anti-pollution and recompiling of information already known and provided under EU REACH
.
"
In addition, the figure will have to be absorbed into the UK supply chain, he said
.
"It is not for me to decide whether BASF in the UK will be able to cover this cost on its own without passing it on to me, but the monetary burden may be shared
.
"
On the possibility of BASF profiting from UK REACH, as the company has a large amount of data registered under EU REACH, Mr Hollis said: "As far as I know, using regulated data ownership as a means to generate profits has never been the case for BASF.
goals
.
"
.
He said: "We are not in an opportunistic country, we are advocating within us joint registrations and consortia to enable those companies that have already paid for EU-REACH to continue to use UK-REACH
.
"
Mr Hollis said BASF would not decide on its own whether to register chemicals in the UK based on commercial viability
.
He added that UK chemical users could end up with a smaller choice of substances than those in the EU
.
"Essentially, BASF and its competitors are in business and when we consider whether to spend 50,000 to 70,000 euros to register a substance, we have to make sure that this is an economically viable decision," he said.
.
“For example, if we sell two tons of chemicals and generate a profit of 10,000 euros per year, but the registration cost is 70,000 euros, we have to ask ourselves, are we prepared to wait seven years to break even?”
Mr Hollis said that, as with the introduction of REACH, he and his colleagues would assess 1,300 substances and decide whether or not to register all of them
.
About 500 of these substances are in quantities below 10 tonnes, meaning the cost of registration may outweigh the return on investment
.
"There may be more grounds for these substances to be registered under possible UK REACH regulation," he said
.
He also recognises that BASF may not be the only supplier of these substances, however, even if the substance is still registered in the UK, there may be a reduction in the number of suppliers, which could also lead to supply chain disruptions
.
