This could create enormous difficulties "because there may well not be substitutes or it may take longer than five years to approve a substitute." Mr Newbould said that even if companies did not use many authorisable
substances in their products, "as you go back up the supply chain you'll find authorisable
substances two or three steps further back and so the fear we have in the industry is about the collapse of the supply chain." By contrast the ministers' common position took a more flexible case-by-case approach which did seek to make substitution mandatory and did not set a fixed period for the authorisation.