Protection of workers from the risks related to exposure to carcinogens or mutagens at work

While we fully support the goal of protecting workers' health, the OEL value of 0.00007 mg/m³ for benzo[a]pyrene (BaP), as proposed by the Commission in the Proposal for a directive - COM(2025)418 is technically and operationally unachievable for coke oven operations, even when using the best available techniques (BAT).

Członek Europejskiej Rady Przemysłu Chemicznego CEFIC Warszawa, 21.10.2025 r. PIPC/116/2025 Stanowisko Polskiej Izby Przemysłu Chemicznego dotyczące Dyrektywy Komisji Europejskiej i Parlamentu zmieniającej dyrektywę 2004/37/WE w odniesieniu do dodania substancji i ustalenia wartości dopuszczalnych w załącznikach I, III i IIIa W związku z trwającymi konsultacjami Dyrektywy Komisji Europejskiej i Parlamentu…

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the European Commission proposal for the VI revision of the Carcinogens, Mutagens and Reprotoxic substances Directive (CMRD) issued in July 2025, specifically the inclusion of welding fumes. The role of welders in the EU industry is indispensable, as they are crucial to the manufacturing and construction sectors, which form the backbone of industrial development.

European Respiratory Society and European Lung Foundation Response to the Public Consultation on Protecting Workers against Cancer-Causing Substances at Work The European Respiratory Society (ERS) and European Lung Foundation (ELF) appreciate the opportunity to provide feedback to the consultation on Protecting Workers against Cancer-Causing Substances at Work and the ambition shown to protect workers from exposure…

The European Cancer Organisation welcomes the opportunity to provide feedback to the consultation on Protecting Workers against Cancer-Causing Substances at Work and the ambition shown to protect workers from exposure to carcinogenic, mutagenic and reprotoxic substances .

European Aluminium represents the entire Aluminium value chain in Europe, from refiners and smelters to manufacturers of semi-finished products, recyclers, and national aluminium associations. European Aluminium fully supports the protection of workers through Union legislation on occupational health and safety.

The European Steel Association, EUROFER, welcomes the opportunity to provide a response to the Public Consultation on the Occupation Exposure Limit (OEL) for Benzo(a)pyrene (BaP), launched by the European Commission with its draft proposal COM (2025)418. Our detailed comments are included in the attached document.

The European Association of Paritarian Institutions (AEIP) considers the revision of Directive 2004/37/EC a crucial step to strengthen worker protection against carcinogens, mutagens and reprotoxic substances, with welding fumes, polycyclic aromatic hydrocarbons (PAHs) and cobalt compounds being particularly relevant for the construction sector.

Jastrzębska Spółka Węglowa S.A. (JSW) appreciates the opportunity to contribute to the public consultation on the establishment of an occupational exposure limit (OEL) for polycyclic aromatic hydrocarbons (PAHs).

Legnica, 21st October 2025 ZPPM / 23S / X / 2025 European Commission Secretariat-General Rue de la Loi 200/ Wetstraat 200 B - 1049 Brussels Belgium Position of the Polish Copper Employers Association on Proposal for a Directive of The European Parliament and of The Council amending Directive 2004/37/EC as regards the addition of substances and setting limit values in its Annexes I, III and IIIa (SEC(2025) 217 final}…

Cobalt is an EU critical and strategic raw material, as well as being classified as a NATO critical mineral given its essential role in defence. Europes political goals security, circular economy, energy transition, and strategic autonomy all necessitate a growing cobalt sector in Europe. This can be done safely. We support a 20 μg Co/m³ (inhalable) Occupational Exposure Limit for cobalt.

The European Association for Coal and Lignite (EURACOAL) welcomes this opportunity to contribute to the European Commissions public consultation on establishing an occupational exposure limit (OEL) for polycyclic aromatic hydrocarbons (PAHs).

20 October 2025 European Commission Brussels, Belgium RE: Jervois Submission to European Commission (EC) on its sixth revision of the Carcinogens, Mutagens and Reprotoxic substances Directive (CMRD) Jervois is deeply alarmed at the well-meaning but misguided EC proposal to set operational exposure limits (OELs) for cobalt at levels that would effectively decimate Europe’s cobalt industry and its downstream European…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EFBWW welcomes the ECs 18 July 2025 proposal revising Directive 2004/37/EC on carcinogens, mutagens, and reprotoxic substances. According to EU-OSHAs 2024 WES, over 60% of construction and wood workers face multiple carcinogen exposures, often on mobile sites, short-term contracts, or as self-employed, with insufficient protection.

Occupational Exposure Limits for PAHs that support workers’ safety Legal justification • There is no evidence that there is a need for EU wide harmonised legislation. National limit values are in place and exposure is closely monitored. The need and benefits of a harmonised specific OEL on PAHs has not been assessed. • No economic assessment of the transition values to the final target value has been carried out.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We know that cigarette smoke is harmful, and measures exist to reduce its impact on public health. Yet surgical smoke (produced during 85% of surgical procedures(1)) is just as dangerous, and healthcare workers remain largely unprotected. Surgical smoke contains biological compounds that are irritating and carcinogenic.

FEFAC representing the EU manufacturers of premixtures and feed for food-producing animals welcomes the initiative of the EU Commission to propose the setting of Occupational Exposure Levels for cobalt compounds for the sake of harmonised rules for enhanced worker protection at the EU level.

Please refer to attached PDF file of ITIA Comments to the "European Commission Proposal for a Cobalt Occupational Exposure Limit (OEL) (amending Directive 2004/37/EC as regards the addition of substances and setting limit values in its Annexes I, III and IIIa"

Umicore is a global advanced materials and recycling group. We reduce harmful emissions, power the vehicles and technologies of today and tomorrow and give new life to used metals. Cobalt is a critical and strategic raw material essential to key European industries, including electric vehicles, renewable energy, and aerospace.

Occupational Exposure Limits for PAHs that support workers’ safety Legal justification • There is no evidence that there is a need for EU wide harmonised legislation. National limit values are in place and exposure is closely monitored. The need and benefits of a harmonised specific OEL on PAHs has not been assessed. • No economic assessment of the transition values to the final target value has been carried out.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position of the Polish Non-Ferrous Metals Association /IGMNiR on the Protection of workers from carcinogenic substances at work - Initiative 13606 About IGMNiR IGMNiR is a nationwide industry association representing producers, processors and recyclers of NF metals.

This initiative will improve workers’ health & safety by revising for the 6th time Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens, mutagens and reprotoxic substances at work.

Filed in Italian · English published by the European Commission

Coal Chemistry Europe response to the European Commission Public Consultation on the Occupational Exposure Limit (OEL) for Polycyclic Aromatic Hydrocarbons (PAHs) Benzo[a]pyrene (BaP) draft proposal COM(2025)418 Coal Chemistry Europe, a sector group of Cefic, appreciates the opportunity to provide comments on the intended introduction of a binding Occupational Exposure Limit (OEL) for Polycyclic Aromatic…

The German Social Insurance Agency (DSV) welcomes the European Commission’s objective of continuously improving occupational safety and health. The protection of workers from carcinogenic, mutagenic or reprotoxic (CMR) substances is an essential contribution to the prevention of work-related diseases.

Filed in German · English published by the European Commission

Catalysts Europe, a Sector Group of Cefic, is the voice of European catalyst manufacturers. Our members include companies active in the research, development, manufacture and use of catalysts across a wide range of industrial applications. Catalysts are a cornerstone of Europes industrial base and play a decisive role in achieving the European Unions environmental, energy, and competitiveness objectives.

We wish to highlight that, while of course supporting in general the idea of increased worker protection, we have concerns with regard to stricter limit values in the context of Cobalt. Cobalt is used in a number of applications in the defence industry, namely (but not exhaustive): 1) In defence products, many cadmium-chromium electric connectors were replaced by zinc-cobalt electric connectors.

KGHM Polska Miedź S.A. (KGHM) is one of the world's leading companies involved in the extraction and production of copper and silver. The company also produces other associated metals, which results from the properties of the polymetallic deposit it exploits. KGHM's most important and largest production facilities are located in Lower Silesia, Poland.

The Federation of European Producers of Abrasives (FEPA) represents over 90% of EU production, with more than 130 plants and 16,500 employees. Cobalt is a critical input in high-performance grinding tools indispensable to European manufacturing. FEPA supports the Commissions goal of protecting workers from harmful exposures and agrees that cobalt requires careful regulation.

A.I.S.E., the detergents sector association representing the European cleaning and maintenance products industry, fully supports the protection of workers through Union legislation on occupational health and safety. In this context A.I.S.E.

We fully support efforts to set an EU-wide occupational exposure limit for cobalt to ensure worker safety. However, we are concerned that setting an OEL below a realistic and robust level of 20 µg Co/m³ (inhalable) could have severe unintended consequences for European industry, jobs, security and the EUs long-term strategic goals.

Securing Europe's Industrial Future: A Pragmatic Approach to Cobalt Exposure Limits About CERATIZIT: The CERATIZIT Group, headquartered in Mamer, Luxembourg, is a global leader in the development and manufacturing of hard material products for cutting tools and wear protection with strong presence in the defence, medical, hygiene, food, agriculture, construction, automotive and aerospace industry.

Such a low cobalt limit will be very difficult to comply with. Even enclosed machines have to be opened from time to time to set up a new tool, clean the machine or perform maintenance. The introduction of a 10 µg/m3 limit will lead to relocation of the production to countries with higher limits. The manufacture of SmCo magnets or their processing in Europe will become much more difficult.