EUROPA - Enterprise - REACH Regu

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					                   EUROPEAN COMMISSION
                   ENTERPRISE DIRECTORATE-GENERAL
                   ENV
                 IRONMENT DIRECTORATE-GENERAL



                        REACH REGULATION
                  PUBLIC INTERNET CONSULTATION


A - Contact details
(Please enter your contact details)

Name : Javie r Rivero
Organisation : Zinc Industrias Nacionales S.A. - ZINSA
Address : Av. Nestor Gambetta 9053
Post/zip code : Callao 01
City/Town : Callao
Country : PERU
Te lephone : (511) 577-6459
Fax : (511) 577-6452
E-mail: peru@zinsa.com.pe - www.zinsa.com



B - Confidentiality

       I would like my identity to be kept confide ntia l
       (please leave this box blank if you agree that your name and organisation
       will be identified on the Commission’s website for public access)



C - SME

       Are you a small or medium sized ente rprise?
       Medium Sized                                 (EC legal definition)
       please specify the number of members: 130



D - Description of your primary activities
(please select only one of the follow ing)

Industry

      Manufacture r
       Importer
       Downstream use r
       Distributor
       Trade assoc iation
       Other

NGO
       Environme ntal group
       Animal welfare group
       Trade union
       Consumer organisation                     Other




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                  EUROPEAN COMMISSION
                  ENTERPRISE DIRECTORATE-GENERAL
                   ENV
                 IRONMENT DIRECTORATE-GENERAL



Public authorities

        EU Membe r State government
        Other national government
        International organisation
        National or regional authority

Other

        Academic or technical institute
        Worker in c hemicals or downstream industry
        EU citizen
        Other



Please structure your response according to the following topic areas and
provide comments or proposa ls for amendments to the legislation. Please
comment on those topics that a re relevant to you.

When finished, please send your docume nt to the following addre ss:
entr-env-ec-reach@cec.eu.int.

Thank you in advance for your contribution.

E - Topics :

1.      Duty of care
2.      Chemical safety assessment
3.      Information flow
4.      Registration procedure
5.      Polymers
6.      Intermediates
7.      Data requirements
8.      Data sharing/consortia formation
9.      Procedures for dow nstream users
10.     Evaluation procedure
11.     Authorisation procedure
12.     Restrictions procedure
13.     The Agency
14.     Other


Othe comments:

Our Organization, ZINC INDUSTRIAS NAC IONALES S.A., - “ZINSA”, is a
Non Ferrous products manufacture r a nd exports its worldwide to more
than 47 countries directly to end-use rs, traders or through a gents.

One of our main products is Zinc Oxide and a lmost 35% of our
production is exported to Europe, a nd obviously to the EU. ( Belgium,
The Nethe rlands, Germany, Spain, France, U. K., Irela nd, Italy, U. K.).




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                 EUROPEAN COMMISSION
                 ENTERPRISE DIRECTORATE-GENERAL
                 ENV
                IRONMENT DIRECTORATE-GENERAL



Also we export to non EU member states that a lso trade & distrubute
this raw mate rial to EU members (suc h as Switze rla nd, Czech Re public,
Poland, Norway) .

We have read the complete REACH-project pape r a nd we think that it will
bring many problems not only to us but to all our c ustomers, distributors
and e nd-users in the EU.

Some of these problems will be :

  -   We would possibly have to sell our mate ria l at a much higher price
      due to the costs involved registering your product. This could the n
      have the effect that our prices could be uncompetitive in Europea n
      market and we could lose conside rable business and EU importers
      will also lose competitiveness with a n expe nsive ra w mate rial.

  -   The registration costs will cause that we have to lose staff
      members and employees in orde r to cover the costs of re giste ring.

  -   Smaller manufactures of certa in products outside the EU could go
      out of business and large European manufactu re rs that can a fford
      the registration costs would dominate the European ma rket a nd
      inc rease prices to whatever level they wish.

  -   All this reasons will lead to the c losing of severa l companies in the
      European market and there fore many people will loose the ir jobs.

  -   It will restrict Free Trade among foreign countries (Latin Ame rica,
      Andean Pact, Mercosur) with the EU, going against W. T. O. (World
      Trade Organisation) regulations.

  -   The EU regulation (White pape r) will not help
      European/Peruvian/Colombia/Bolivia fight aga inst the drug
      traffic , since many orga nisations in Latin Ame rica depend on their
      sales to the European ma rket, and if their prices are not
      competitive, they will have to close and in this way people will be
      unemployed. GSP grante d from EU to our countries will have no
      sense to exist and will motivate more “drug dea lers” worldwide,
      where Europe is a target ma rket.

Our ge neral thought is that REACH-project must be stopped, as it will not
only pre judice our EU c ustomers as we ll as the Europea n soc iety .

Best regards,
Javier Rivero

Managing Director
ZINC INDUSTRIAS NAC IONALES S.A.- ZINSA
Lima, PERÚ
www.zinsa.com
email: pe ru@zinsa.com.pe




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