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Tony Blair Prime Minister of the United Kingdom

Jacques Chirac President of the French Republic

Gerhard Schröder Federal Chancellor of the Federal Republic of Germany

Berlin, September 20, 2003

Dear President,

On our initiative on 21 March 2003, the European Council sent out a clear signal for strengthening the industrial competitiveness of the EU. We agreed that we had to reduce the bureaucracy that European companies encounter and decisively improve the regulatory framework within which our companies, faced with strong competition, must manoeuvre.

To achieve this, we must ensure we do not place unnecessary burdens on industry. We continue to call on the Commission to conduct an analysis of current market and competitive conditions. We will therefore suggest to our partners that the Commission present a report to the European Council at its December meeting containing suggestions for the optimization of industrial framework conditions in order to avoid risks of de-industrialisation.

It is also essential to comprehensively assess all important Community projects with respect to their potential effects on industrial competitiveness.

The review of EU chemicals policy provides the first concrete opportunity to apply the described principles in a manner that could serve as an example for other areas of industry.

A future EU chemicals policy must be designed in such a way as to ensure environmental, health and consumer protection without endangering the international competitiveness of the European chemical industry. We would also want the new regulatory system to keep animal testing to an absolute minimum.

The Consultation Document published by the Commission in May 2003 contains certain positive elements in this regard. However, the ideas currently being considered give us cause for concern. In particular, we consider the envisaged registration procedure to be too bureaucratic and unnecessarily complicated. We are concerned in addition that the proposed regulatory system does not prioritise sufficiently between the handling of substances, that it will as a result not be workable in practice and that it will be difficult to convince stakeholders that we have created an effective system for targeting and handling those substances which present real safety or environmental concerns. It is still a long way from being the fast, simple and cost-efficient procedure that was promised.

For this reason, France, Germany and the United Kingdom have brought forward comments on the workability and impact of proposals made in the consultation document. We made suggestions for substantial changes to the proposals so that they can be an effective approach for sustainable development.

We are also concerned about the potential impact of the new requirements on the competitiveness of EU businesses exporting to Third Country Markets, and about the position of EU businesses competing in the EU with Third Country suppliers able to avoid these requirements when sending products to our markets.

We must ensure that the proposals do not disadvantage legitimate EU business interests in the global market by imposing requirements which are not pertinent to protecting health and environment. With this in mind, the Commission should carry out a full evaluation of the concrete effects of the planned regulations on the European chemicals industry, as well as on the economy, taking account of the effects throughout the supply chain. The proposals presented to the European Parliament and the Council should create an effective framework which allows EU business to continue to thrive.

To this end, the Commission must work with the Presidency of the Council to ensure that the Competitiveness Council - in accordance with the European Council decision - plays an effective role in the handling of this legislation.

We would be grateful if you could take up these proposals and help contribute to making the planned new regulation of the chemicals regime a successful example of our joint efforts to strengthen the industrial competitiveness of the EU.

Yours sincerely

Tony Blair

Jacques Chirac

Gerhard Schröder

Prof. Romano Prodi

President of the European Commission