Leather itself is classed as product and is not covered under the regulations although the leather chemicals used in the leather and leather product sectors do. Buljan also confirmed that the regulations only apply to the EU however, virtually every country would be affected by REACh if their products were subsequently sold in European markets.
During the discussion following the presentation, Elton Hurlow, marketing manager of chemical producer Buckman said that the cost and administration burden of the regulation was being borne largely by the chemical companies, but that tanners should obtain letters from their chemical suppliers showing that the chemicals they were buying were compliant with REACh regulations. He estimated that between $50,000 to $150,000 in extra work and compliance will be added to the cost of each low risk product that would be absorbed into chemical maker’s general overheads. He also confirmed that chemical companies were working together to avoid duplication of work on many products and across industrial sectors and that this will keep costs down.
It was mentioned that there may be a few chemicals used in the tanning industry that might be regarded as high risk and could have significant compliance costs as additional data would be required from an independent source. This could run into the millions of dollars in the worse cases.
Biocides used in the leather industry, such as fungicides and bactericides, are an example of substances requiring additional testing and data, but they are already covered outside of REACh through the Biocidal Product Directive legislation.
Tanners with any major concerns about the regulations should consult their chemical suppliers or a professional organisation that has knowledge of the regulations.
