Environmental Engineering Reference
In-Depth Information
are oil industry byproducts from Trinidad and Tobago and from Equatorial Guinea, two
oil-producing nations.
REACH compliance appears to be well within the abilities and
fi
nancial resources of
the large
fi
rms that account for almost all of ACP's relevant exports. Not only are the com-
panies su
ciently large to understand and comply with European regulations; the
a
ected products are, in large part, familiar ones whose properties are well known. No
one expects that REACH will lead to a ban on aluminum, platinum, or copper imports,
nor on well-known oil byproducts such as ethanol and methanol. Indeed, many of the test
results required under REACH may already be available for some of ACP's leading
products.
However, there is one small category of 'chemical' exports subject to REACH that
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ts
the classic image of struggling local enterprises, namely the essential-oils industry.
Essential oils are products of plants giving the odors and tastes characteristic of the par-
ticular plant, such as cinnamon and lavender. ACP as a whole exported
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26 million of
essential oils to EU, and six ACP countries averaged more than 50 tonnes of essential-
oil exports to EU in 2002-04. We examined the industry in Madagascar and Comoros;
in both cases, the sector appears to consist entirely of small to medium-sized farmers
and manufacturers. Madagascar is ACP's largest essential-oils exporter after South
Africa.
Essential oils of cloves and vanilla are among the country's most important exports;
other essential oils produced in Madagascar include ylang ylang, palmarosa geranium,
niaouli and helichryse. Madagascar has at least 20 small to medium-sized companies
that produce essential oils or related substances. Comoros, sometimes called the Perfume
Isles, exports 80 percent of the world's supply of ylang ylang essence, a main ingredient
in many perfumes. The essential oils of vanilla and cloves are other important exports.
Local distilleries use their own crops but also buy additional supplies from smaller
farmers.
The European Federation of Essential Oils, which represents importers to the EU and
producers in the EU, has emphasized that their 150 members are mainly small and
medium-sized enterprises and would have di
€
culty complying with REACH. They advo-
cated, unsuccessfully, for exempting essential oils from REACH. However, the overall
costs of REACH compliance for the essential-oils industry will be low, since only a limited
number of essential oils are exported from ACP to the EU in quantities a
ected by
REACH. According to one estimate, 300 essential oils are sold in the EU, of which 170
are exempt from REACH because they are produced in amounts less than 1 tonne per
year. Another 120 essential oils produce below 100 tonnes per year and face limited testing
requirements. Only ten essential oils fall in the higher-volume range requiring more exten-
sive testing. Safety and toxicity information is already available for many of the best-
known products, reducing the burden of additional testing.
This example, it should be emphasized, is the exception, not the rule: essential oils com-
prise less than 0.5 percent of all ACP exports that are subject to REACH, a mere
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26
€
million (not billion!) per year - and we did not discover any other sectors a
ected by
REACH that are dominated by small ACP exporters and small EU importers. It might
be reasonable to expect the EU to provide assistance in cases of burdensome impacts on
small ACP exporters; the cost of such assistance would be quite limited because there are
so few actual cases.
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