We need to focus more on the research because in the dyes industry very little data is available and we want to open a dialogue with the entire supply chain because the consequences will involve a much broader and strategic sector of the economy.

This is a summary of the message that we brought, as Dye-Staff, to the Prato conference on the 11th of February on sustainability and reduction of hazardous chemicals.

Here is the text of our speech.

“I will try to briefly outline the case involving the SMEs of the colorants industry.
In particular, I represent here 12 Italian SMEs (+1 foreign operator) working in the field of chemical dyes, whose production is destined to the textile, leather and paper sectors, which have teamed up into an international cooperation called Dye-Staff. The cooperation was established in 2012 to shed light on the situation of the sector following the entry into force of the REACH Regulation.

First of all I would like to point out that we fully agree with the purposes of the Regulations that bring to the centre stage the improvement of human and environmental health, but nevertheless we want to focus on the NON SUSTAINABILITY for SMEs, for the time being, in adopting the necessary tools to pursue these goals.

To do this, in 2012 we signed and submitted a petition to the European Parliament and Commission and in 2014 we submitted to the Ministry of Health and the Mise a study on the socio-economic impact on these Italian SMEs of the dyes registration according to REACH Regulation.
The competent Italian authorities for REACH have therefore decided to present the case in Brussels at Caracal composed by the Competent Authorities of all MS, EU Commission, ECHA and some selected stakeholders and all’ESPG bringing together the Ministries of Industry of the member states.

Making an estimate, the average cost for the registration of a substance below 10 tonnes, ranges from 25 to 35,000 euro, with peaks up to 200,000 Euros. A SME of this sector has on average a few hundred substances to register and it is clear that each enterprise has an interest in the registration of as many substances as possible in order to remain competitive on the market.

This figure alone is enough to illustrate the problem: SMEs in the sector are not able to deal with these costs and the application of the regulation, as is currently expected, seriously compromises their survival and that of jobs they generate.

It is true that the regulation affects all the European manufacturing realities in the sector, but the problem touches the Italian scenario more than any other, given the peculiarities of our country, leading the Eurozone for the quantity of SMEs (over 95%) and the undisputed leadership in the textile business in Europe .

Therefore, these facts have direct consequences:

• Closing a hundred companies in the sector across Europe,
• huge job losses,
• turnaround of the competitive scenario that would leave only the big players on the field.

Is this what the European legislator wanted when these these rules were written? We do not want to believe this to be the case, we’d rather think that the urgency of pursuing the principle of protection prevailed on a careful analysis of the possible consequences. In confirmation of this we uphold the attention we got from the European Commission or its individual members, each time we have shown, supported by figures, the scenario that is forthcoming between now and May 31, 2018, deadline for registration with the European CHemicals Agency (ECHA).

I referred to direct consequences, but I would like to draw your attention on the possible indirect consequences that would ultimately involve the entire production chain:

• As for today a true reduction of the number of substances registered (200 at least ) because of the high cost involved;
• increase of the costs of the dyes to amortize the costs to register them;
• reduced availability of dyes for industrial manufacturing;
• consequences on employment for the sector in Italy;
• increase in imports of finished articles containing unlicensed substances, reducing the quality and safety of products;
• reduced safety in some workplaces.

There are more areas in which these indirect consequences would have a greater prominence, areas that represent the excellence of our country. I am referring to the fashion industry.

A few days ago I was reporting this case to the editor in chief of a magazine and I told him: what if the thing we are famous all around the world, the creativity of Made in Italy, all of a sudden had to come to terms with the loss of some color.
It would be like asking if the Art Nouveau could have had much luck without the brilliance and evocativeness of theVictorian blue or without other bright tones, almost unnatural that were meant to transmit energy in those who watched them.

We therefore believe that the impact on the supply chain and fashion should be a common conclusion because the issue is not just some small chemical companies, the closure of which might be of interest to a few stakeholders, but it involves a much broader and strategic system for the economy of our country.
Therefore this is why we are actively working to converse with the most important brands of the Italian fashion.

Let me conclude by emphasizing our commitment to open as many windows as possible on a sector that has very little data available.
We are doing this by directly investing in RESEARCH, in particular with the Institute of Pharmacological Research Mario Negri in Milan.
Thanks to the research we can determine algorithms and not through livestock tests the reference values for many substances that might otherwise not be recorded.
Main objective of the Dye-Staff cooperation, as aforementioned, is the sustainability of the registration costs of REACH and this can be done through the development of family based dossiers.
The approach we propose in every venue – from the European Commission to the Ministry of Health, from the media, to this meeting – is to locate the families of dyes that can be grouped together based on their common characteristics, which should be relevant by the toxicological, ecotoxicological and environmental point of view. “