BASF SE

November 2025 Position on the EU’s Circular Economy Act Key messages BASF welcomes the European Commission’s ambition to make Europe a global leader in the circular economy by 2030. To reach that ambition, BASF believes that the upcoming EU Circular Economy Act (CEA) should: • Provide a coherent and up-to-date legislative framework to support both cross-cutting and sector-specific measures, aligning upstream…

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

BASF Battery Materials welcomes the opportunity to contribute to the call for feedback on the Industrial Accelerator Act (IAA). The initiative has the potential to create a decisive stepchange in establishing a circular battery value chain in Europe. Strong and predictable demand signals across all stages of this value chain are essential to unlock the significant investments required for its scaleup.

BASF supports the goal of a climate-neutral Europe by 2050 and is actively committed to climate-neutral and circular production. We aim to actively and responsibly shape this transition towards a climate-neutral and circular society and aspire to become the preferred supporter of decarbonization in our customer industries. Details: See attachment.

As a chemical company supplying into almost all industries and sectors, BASF is committed to create chemistry for a sustainable future and to combine economic success with environmental protection and social responsibility.

The European Biotech Act represents an opportunity to position biotechnology as a strategic enabling industry for EUs competitiveness, sustainability and economic security. This ambition is consistent with both the Draghi report, and the Commissions Competitiveness Compass which identifies simplification, innovation and frontier technologies, including biotech, as core drivers of EU competitiveness.

Biotechnologies play a vital role in achieving EU climate goals, addressing societal and environmental challenges, and enhancing economic competitiveness. In March 2024, the European Commission sent a strong signal to the biotech and biomass derived industries with the publication of the Communication on Boosting Biotechnology and Biomanufacturing in the EU.

BASF welcomes the opportunity to provide feedback to the Commissions Draft Proposal on the Revision of the benchmark values for free allocation of emission allowances (2026 - 2030). BASF is committed to achieving climate neutrality by 2050 across its global operations.

BASF welcomes the opportunity to contribute to the public consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. BASF supports the goal of a climate-neutral Europe by 2050 and is actively committed to climate-neutral production.

BASF supports the EU Bioeconomy Strategy and its upcoming Biotech Act II as a key instrument to accelerate the uptake of bio-based feedstock in European production and strengthen Europes sustainability, resilience, and industrial competitiveness. With its chemistry offerings, BASF is at the forefront of driving the green transformation across many industries.

Biotechnology plays a crucial role in strengthening EUs economic resilience and competitiveness. BASF Agricultural Solutions welcomes initiatives to address regulatory bottlenecks and to safeguard EU position in all biotechnology-related fields, especially plant biotechnology.

BASF Agricultural Solutions, a leading provider of innovative tools for farmers, is pleased to present its comments on the development of a renewable energy framework for after 2030. BASF supports farmers worldwide with crop protection toolbox, seeds and digital farming solutions.

BASF welcomes the opportunity to provide input to the Commissions Call for Evidence on the renewable energy framework after 2030. BASF is committed to achieving climate neutrality by 2050 across its global operations.

BASF welcomes the European Commissions upcoming European Innovation Act as this initiative has the potential to close the innovation gap between the EU and leading global competitors. We value the opportunity to contribute to the Call for Evidence and we have enclosed recommendations on the following aspects: Accelerating the Path from Knowledge to Market; Targeted, Outcome-based Regulation; A Holistic and European…

We welcome the clarifications provided by the DA to introduce targeted and limited technical fixes. At the same time, following the targeted stakeholder consultation by IEEP, an extensive review of Annex I is necessary to avoid serious disruptions in the supply chains, with potential unintended negative effects on the supply of essential goods for the European market.

Wooden packing material used for exporting other goods produced explicitly for export, thus neither placed on the market yet nor to be placed on the common market, to date, from the requirement to present a due diligence certificate, havent been excluded by the actual EU Deforestation Regulation nor by the actually proposed amendment of EUDR Annex I.

BASF welcomes the simplifications to the IED proposed by the European Commission. At the same time, further adjustments are needed to reduce administrative burdens and ensure a practical implementation for the chemical industry, contributing to strengthened industrial resilience. Please also refer to the attached document, which outlines our proposed amendments in detail.

BASF welcomes the initiative of the European Commission to develop a harmonised, fit-for-purpose and consistent framework for the interoperability and efficiency of Digital Product Passport (DPP). The current draft implementing decision highlights the risk that the EU may weaken its own industrial competitiveness by introducing increasingly detailed and complex regulatory requirements.

The proposal for an implementing decision (on rules for single-use PET bottles) is a landmark, legislative acknowledgement of the mass balance model which recognises its necessity for recycled content targets. The credit mass balance fuel-use excluded (FUE) approach is indispensable for gradually shifting from traditional fossil to circular feedstocks, while using our existing assets.

BASF supports the key objectives of the Digital Product Passport in ESPR, particularly those aimed at addressing the shortcomings of the current rules, enhancing the sustainability of products, and contributing to the European economys green and digital transition. This aligns with BASFs new strategy to support customers in their green transformation.

BASF welcomes the European Commissions Advanced Materials Act and its goal to strengthen Europes advanced materials ecosystem. However, the current regulatory environment is fragmented and extra cautious, which slows innovation and market entry. For the Act to be successful, it must address major challenges faced by European companies as they research and invest in new materials.

BASF fully supports efforts to strengthen GHG accounting under the RED. To ensure a robust and trustworthy framework that accelerates the decarbonisation of European industry, we urge the Commission to prioritise: Updated and harmonised default values, including electricity grids; Flexible co-digestion accounting to preserve low-CI biomethane markets; Recognition of voluntary LDAR guidelines; Barrier-free, aligned…

BASF SE response to the European Commissions consultation on the legal framework for the possible use of international carbon credits towards the 2040 EU climate law target BASF welcomes the opportunity to contribute to the Commissions consultation on the possible role of international carbon credits in meeting the EUs 2040 climate target.

BASF welcomes EU Commissions aim to develop EU-wide end-of-waste (EoW) criteria for plastics waste which is essential to foster circular economy. Herewith, we would like to provide input to the public consultation on the draft Commission Implementing Regulation. In the short term, it is essential to set EU-wide EoW criteria for various waste streams entering various recycling routes.

Response to the Public Consultation of the Delegated Act establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries BASF welcomes the introduction of the Product Carbon footprint (PCF) requirements for EV batteries to maximize the decarbonization potential of the battery value chain in Europe.

The European Commission strives for scaling fiber-to-fiber recycling to tackle the increasing amount of textile waste in Europe. Hence, we propose to oblige textiles producers to explicitly declare the recycled content derived from post-consumer garment waste. This would significantly increase transparency and enable consumers to make informed buying decision.

BASF supports the objective of improving transparency and sustainability of iron and steel products under ESPR. However, future requirements should remain technology-neutral, build on existing industrial data systems and avoid disproportionate administrative burden. Carbon-footprint methodologies require further harmonisation before being used as regulatory benchmarks.

The Agricultural Solutions division of BASF is active in breeding, seed production and marketing of varieties of vegetables and field crops, in Europe and globally. It is holder of multiple PVP and it is well aware how IP protection of seeds materials offers benefits for all players in the agriculture value chain.

As a large multinational company, BASF operates several fully Good Laboratory Practice compliant Test Facilities in Europe with a focus on chemicals, crop protection including seeds and traits and toxicology. Size of the Test Facilities is up to several hundred employees, with some facilities operating in addition to GLP under other quality systems, eg. ISO norms.