Cefic

Europes transition towards climate neutrality and a sustainable circular economy requires a rapid and ambitious scale-up of the biomass-derived sector, supported by robust and consistent policy starting with a strategic framework for a competitive and sustainable EU Bioeconomy. To be a global leader in circular bioeconomy, the EU must move beyond incremental measures.

APAG Oleochemicals Europe, a sector group of Cefic, represents the European industry that uses plant oils and rendered animal fats (category 3) to produce oleochemicals and stands as a pillar of the European bio-based and circular economy. Oleochemicals are bio-based chemicals derived from fats & oils. They serve as alternatives to fossil-based chemicals contributing to a greener future.

The Circular Economy Act (CEA) is expected to become a cornerstone of the EUs Clean Industrial Deal, reinforcing Europes strategic autonomy, competitiveness, and sustainability through systemic circularity reforms.

BioChem Europe supports the objectives of the IAA and calls for targeted measures to ensure that biomass-derived chemicals and materials can fully contribute to Europes climate neutrality, industrial competitiveness, and strategic autonomy.

The competitiveness of the EU chemical industry is under pressure due to soaring energy prices, growing regulatory burdens and unfair competition. Available data show a marked increase in subsidy allocation in China and in other major economies between 2009 & 2022 (IMF, 2024).

Incorporating non-price criteria in public procurement can stimulate demand for low-carbon and circular products from parts of the EU chemical industry by incentivising downstream companies to use these materials in their final products when participating in tenders. Cefics feedback outlines the sectors perspective.

I. Need for Broad Demand-Creation Policies By leveraging their purchasing power, governments and public institutions can create and support demand for circular and low-carbon materials. Such a contribution to a steady and minimum demand for more sustainable products would not only support the transition of European industries but also foster innovation and economic growth.

Strengthening EU Public Procurement to Prioritise Sustainable and Biomass-Derived Products Governments and public institutions can use their significant purchasing power to drive demand for circular and low-carbon materials, including biomass-based chemicals.

APAG Oleochemicals Europe, a sector group of Cefic, supports a modernised and coherent EU public procurement framework that creates lead markets for sustainable, innovative products and strengthens economic security and contributes towards autonomy while preserving a level playing field across the EU Single Market.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns, and provides the following recommendations: Climate Delegated Act Address inconsistencies with the EU ETS Support the retention of current GHG emission thresholds Maintain use of ISO standards to calculate life-cycle GHG emissions until PEF-related shortcomings are…

BioChem Europe welcomes the European Commissions continued efforts to refine the EU Taxonomy framework and acknowledges the positive recognition of biomass-based pathways in the draft revisions of the Climate and Environmental Delegated Acts (DA). Particularly, the explicit reference to sustainability criteria under the Renewable Energy Directive (RED III) is an important step toward policy coherence.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

The EU Taxonomy is intended to define criteria for environmentally sustainable economic activities and to guide investments toward the EUs green transition. The biomass-derived chemicals sector plays a central role in enabling a sustainable, circular, and competitive European economy by providing renewable, high-performance materials.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

Cefic welcomes the European Commission proposal on the Green Claims Directive and supports the overall objectives of this ambitious initiative. We want to collaborate with the European Commission and the entire value chain to make the Green Claims Directive effective in product differentiation and providing accurate information to consumers while ensuring a level playing field for all players across the industry…

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new regulatory initiative on substantiating green claims regarding Environmental performance of products & businesses in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value) The European chemical industry represented by Cefic, is highly…

Compared to other transport operators, shippers follow a different modus operandi within the supply chain which significantly depends on markets, products, production, and distribution networks. As a result, shippers have different expectations for road transport regarding volumes, distances, safety, and operational requirements.

Biotechnologies are crucial for the EU chemical industry, driving economic growth, innovation, and sustainability. Cefic shares the overall objective of the Biotech Act to improve the size and competitiveness of the biotechnology and biomanufacturing sector in the EU while maintaining high safety standards and to ensure that the EU makes the most of the biotech revolution for the benefit of society, the environment…

The proposed benchmarks reduction particularly the 50% cut to fallback heat and fuel benchmarks is unrealistic, disproportionate, and disconnected from current technological, infrastructure, and investment realities. These changes would significantly increase carbon costs for an already struggling chemical sector, worsen carbon leakage risks, and reduce the capacity of companies to invest in the climate transition.

Safeguarding the chemical sector from an unintended CBAM scope expansion Cefic briefly responds to the consultation of CBAM downstream goods scope expansion by requesting the Commission to avoid the inclusion of the chemicals NACE codes via a backdoor mechanism.

The Biotech Act II should strengthen the business case for the industrial bioeconomy and biomanufacturing. It should boost resilience and competitiveness while accelerating the scale-up of sustainable biomass-derived solutions across European value chains. Biotech Act II should go beyond biomanufacturing to provide a coherent framework for the wider industrial bioeconomy.

For the Biotech Act II to unlock the potential of biomass-derived chemicals, BioChem Europe calls to: Make the Biotech Act II the framework to enable the biomass-derived chemicals sector Ensure access to all types of sustainable raw materials Implement strong and effective market-pull measures, such as biomass-derived content targets Harmonise and add clear definitions Attached you will find our complete input to…

APAG Oleochemicals Europe, a sector group of Cefic, is a longstanding pillar of the European bioeconomy. As other regions already have policies in place with ambitious targets, Europe must shift from enabling conditions to deployment. The Biotech Act II is a strategic opportunity to strengthen competitiveness, reduce external dependencies and support resilient bio-based value chains.

Consultation Response April 2026 The Future of the Renewable Energy Directive Chemical Industry Views Persistent high energy and feedstock costs have reached an unsustainable level for the chemical industry. As the largest industrial energy & feedstock consumer in the EU (1193 TWh, 2023), the high costs compared to other regions present an existential challenge.

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

APAG welcomes the revision of the Renewable Energy Directive (RED) in the context of the post-2030 framework. To ensure coherence with circular economy objectives and the European Green Deal, the revised framework must maintain a level playing field between competing uses of biomass, including biofuels and bio-based chemicals.

Sustainable Fuels welcomes the opportunity to provide its input for the call for evidence and looks forward to continuing the conversation with the European Commission on the renewable energy content of ethers and in particular ETBE. We have uploaded our position statement as part of our submission.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns, and provides the following recommendations: Climate Delegated Act Address inconsistencies with the EU ETS Support the retention of current GHG emission thresholds Maintain use of ISO standards to calculate life-cycle GHG emissions until PEF-related shortcomings are…

BioChem Europe welcomes the European Commissions continued efforts to refine the EU Taxonomy framework and acknowledges the positive recognition of biomass-based pathways in the draft revisions of the Climate and Environmental Delegated Acts (DA). Particularly, the explicit reference to sustainability criteria under the Renewable Energy Directive (RED III) is an important step toward policy coherence.

Executive summary The following shortcomings within the EU Taxonomy framework translate in low and unreliable EU Taxonomy eligibility and alignment numbers: Complex and overly ambitious technical screening criteria (TSC) Unclear and ambiguous concepts, leading to uneven reporting practices Inadequate transition perspective EU Taxonomy figures should not therefore be considered as a metric to measure the…

CBAM design is not suitable to be extended to the complex value chains such as those of organic chemicals and polymers. Four key conditions a solution for exports, full value chain coverage, consideration of indirect carbon costs, and practical feasibilityremain unmet.

APAG & CESIO (Cefic sector groups representing the European oleochemicals and surfactants industries) welcome the clarifications provided by the Delegated Act to introduce targeted and limited technical fixes. We noticed two discrepancies in the draft delegated act: 1. HS code 382311 (stearic acid, industrial) is not listed in the draft delegated act, while being listed in the original Annex I list.

GME, the Gelatine Manufacturers of Europe (GME), is the leading association of Europe's foremost gelatine manufacturers. GME's mission is to serve the European gelatine industry, to support the products gelatine and collagen peptides and also to inform and communicate with customers, authorities and the media.

Cefic welcomes the Commission's proposal objectives to reduce administrative burdens and potential delays for operators, to harmonize the single market and especially foster the transition for the decarbonization of transports.

The European Chemical Industry (Cefic) welcomes the proposed initiative. The revision of weights and dimensions will contribute to a more efficient and low-emission transport system. As all transport modes need to deliver to the green deal objectives, the revision should aim to drastically improve efficiency and equipment utilisation in road and combined transport.

Input on the Environmental Omnibus Battery Regulation (Labelling of hazardous substances) Introduction The Environmental Omnibus proposes targeted amendments to the EU Batteries Regulation, including clarification of the scope of substances to be indicated on the battery label. In this context, the proposal introduces a reference to substances of very high concern (SVHC) for the purposes of battery labelling.

CBAM design is not suitable to be extended to the complex value chains such as those of organic chemicals and polymers. Four key conditions a solution for exports, full value chain coverage, consideration of indirect carbon costs, and practical feasibilityremain unmet.

Please find attached the contribution of the European Chemical Industry Council (CEFIC) into the stakeholder consultation for the Single Use Plastic Directive Implementing Act (SUPD IA). This contribution reflects the discussions and different positions of the Cefic members, who are engaged in different technologies.

Cefic welcomes the Commissions ongoing effort in preparing the Implementing Act laying down rules regarding the calculation, verification and reporting of data on recycled plastic content in single-use plastic beverage bottles under the Single Use Plastics Directive (SUPD).

Cefic Views on the EU Grids Package Adequate grid infrastructure is a precondition to industrial competitiveness and decarbonisation through direct/ indirect electrification. Yet the costs of its build-out will add to the energy cost burden of industrial users, deteriorating their competitiveness and the business case for electrification. Cefic looks to the EU Grid Action Plan to help navigate this trade-off.

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

CONSULTATION RESPONSE October 2025 Cefic Consultation Response – Electrification Action Plan Persistent high energy costs have reached an unsustainable level for the chemical industry. As the largest industrial consumer of electricity (149 TWh, 2023), the high costs compared to other regions present an existential challenge. A rising number of chemical site closures attests to that.

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

Advanced materials provide innovative solutions for a more efficient, sustainable, and competitive industry, playing a key role in achieving the EU objectives of strengthening competitiveness and achieving climate neutrality by 2050. BioChem Europe strongly welcomes the upcoming Act and its objective to reinforce the European Unions leadership in innovation, sustainability, and industrial competitiveness.

As the EU prepares to launch the Advanced Materials Act, APAG Oleochemicals Europe, a sector group of Cefic, is calling for recognition as a strategic player that deploys high-performance applications to the market: -Polymers: Beyond its well-established applications as stabilisers and lubricants for polymers, oleochemicals are renewable building blocks used to create biodegradable polymers.

CONSULTATION RESPONSE September 2025 CO2 transport, the way forward for the chemical industry The chemical industry and many everyday products depend on carbon molecules. That carbon is and will remain at the very heart of our processes in the chemical sector. On the path towards climate neutrality, industrial carbon management and the EU CO2 market become ever more important to reduce and remove emissions.

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

APAG supports the Commissions review of Annexes V and VI and the reliance on the JRCs scientific expertise. At the same time, APAG calls for a clear and explicit limitation of the proposed animal fats pathway values to Category 1 and Category 2 animal fats only; and careful consideration of policy coherence and market impacts when revising GHG accounting rules.

Fertilisers Efficiency Enhancers, a sector group of Cefic, represents the value chain of nitrogen stabilisers and other efficiency enhancers in Europe and promotes the agronomic and environmental benefits of nutrient enhancers in fertiliser applications.

Executive summary Delivering the ambitious target of climate neutrality by 2050 and the proposed 2040 intermediate target will require a post 2030 climate policy framework that is environmentally robust, economically feasible and capable of attracting investment in Europes industrial base.

Peroxygens, a Cefic sector group, represents the European producers of hydrogen peroxide, we welcome the European Commissions evaluation of the Biocidal Products Regulation and the opportunity to contribute to this exercise, which assesses the Regulations fitness for purpose after more than a decade of implementation, in line with the Better Regulation Guidelines.

Biocides for Europe, a sector group of Cefic, would like to take this opportunity to present our 4-point action plan to simplify the BPR. The document outlines key actions and enablers to enhance the EUs competitiveness, improve time to market, remove uncertainty, and strengthen the innovation framework. The document draws on the experience of the Biocides for Europe membership and reflects our initial findings.

Cefic welcomes the opportunity to provide input to the public consultation on the draft Commission Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for plastics from mechanical and solvent-based recycling . We recognise this as a positive step towards harmonisation, regulatory certainty, and the development of a well-functioning internal market for recycled plastics.

CBAM design is not suitable to be extended to the complex value chains such as those of organic chemicals and polymers. Four key conditions a solution for exports, full value chain coverage, consideration of indirect carbon costs, and practical feasibilityremain unmet.

The Titanium Dioxide Manufacturers Association (TDMA) is a sector group of the European Chemical Industry Council (Cefic) and represents the leading producers of titanium dioxide (TiO). The unique properties of TiO in combination with other colours gives intensity and brightness to decorative cosmetics, as well as allowing manufacturers to create many different shades to suit all skin types.

Feedback from the European Chemical Industry Council (CEFIC) on the proposals for the re-attribution of scientific and technical tasks to the Agencies: Cefic welcomes the Commission's efforts to improve and enhance the safety assessment of chemicals across EU legislation with the One Substance, One Assessment legislative package.

TDMA see an added value in having more streamlined scientific assessments though having a more detailed description of one substance one assessment (OSOA) would be helpful. The current information we have on OSOA is limited to the general documents on the Chemicals Strategy for Sustainability (CSS), the short description in this consultation, and the presentation to the Advisory Committee for the Competent…

Food Contact Additives (FCA), a Sector Group of the European Chemical Industry Council (Cefic), welcomes the opportunity to provide input to the Commission’s call for evidence “Chemicals – making best use of EU agencies to streamline scientific assessments” and would like to provide the attached comments

1 December 2025 Cefic Input to the Public Consultation on the proposal for a Regulation on the European Chemicals Agency (ECHA Basic Regulation) Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. Any new task needs to be linked with ECHA’s vision and mission with appropriate human and financial resources allocated.

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

Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. These tasks will become even more complex and challenging following the implementation of the EU Chemicals Strategy for Sustainability (CSS).

EFCTC contribution to the Commission Public Consultation on the proposal for a basic regulation for the European Chemicals Agency INTRODUCTION The European FluoroCarbons Technical Committee is a Cefic Sector Group.

In the Single Market Strategy, the European Commission suggests establishing the EU Market Surveillance Authority. Cefic fully supports this goal. The current enforcement practice lacks resources and expertise and is structurally too fragmented to cope with the exploding volume of products from third countries, many of which do not comply with EU rules.

Cefic, the European Chemical Industry Council, welcomes the opportunity to contribute to the public consultation on the Critical Raw Materials Act implementing regulation laying down the list of products, components and waste streams considered as having potential to recover critical raw materials.

Whilst there is further detailed reasoning in the attachment, to ensure harmonised and successful enforcement of the global Stockholm Convention decision on MCCP, as European manufacturers of chlorinated paraffins, we request that: 1) All specific exemptions of MCCP, listed in the Stockholm Convention decision are included in the EU POP Annex I listing with their recommended exemption timings; 2) The 3% threshold…

APAG, a sector group of Cefic, welcomes the opportunity to contribute to the public consultation on Products derived from animal by-products as component materials in EU fertilising products and wishes to highlight a critical inconsistency in the treatment of glycerine streams under Regulation (EU) 2019/1009 and Commission Delegated Regulation (EU) 2023/1605.

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…

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.

Bisphenols Europe, representing EU manufacturers of BPA, BPS and BPF, fully supports the objective of protecting childrens health and safety. To ensure this objective is achieved effectively, the proposed REACH restriction would benefit from further refinement to improve clarity, consistency and proportionality. Main concerns.

Cefic considers it essential that these sustainability criteria are designed to be technology-neutral and aligned with the PPWR definition of high-quality recycling (Recital 30 and Article 3(41)), ensuring that all recycling technologies, including chemical recycling technologies, are assessed based on what they deliver in practice.

Cefic fully supports the Commissions work to strengthen the framework to prevent the misuse of drug precursors for illicit purposes, while reducing obstacles for legitimate trade. The EU chemical industry has a long-standing Responsible Care® commitment for safe, secure, responsible and sustainable production and use of chemicals, and shares the objective of ensuring that regulatory measures remain effective…

The European Chemical Industry fully supports EU legislation regulating the trade of drug precursors both intra EU and with non-EU countries. Our support is in line with our industrys Responsible Care® commitment to ensure safe, secure, responsible, and sustainable production and use of chemicals.

Cefic supports the Commission Services in removing any reference to chemicals in Ecodesign requirements for electronic displays, as they are better addressed under the proposed Ecodesign for Sustainable Products Regulation (ESPR).

Bisphenols Europe appreciates the opportunity to comment on the draft Commission Delegated Regulation amending Regulation (EU) No 649/2012 as regards the listing of pesticides and industrial chemicals. We support the objectives of the PIC Regulation and the Rotterdam Convention to promote shared responsibility and informed decision-making in the international trade of hazardous chemicals.

CONSULTATION INPUT AUGUST 2026 CASG, a Cefic sector group representing MCCP (medium chain chlorinated paraffins) EU manufacturers, welcomes the opportunity to contribute to the open consultation on the inclusion of substances in the Annexes of Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals (PIC). The following key points have been identified by the group: 1.

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

Cefic supports the objective of strengthening controls against designer precursors under the EU Drug Precursor Regulations, while ensuring that any new controls remain legally clear, implementable and enforceable for legitimate operators and authorities. In particular, substances should be scheduled individually and identified through clear, unique identifiers such as CAS numbers.