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.

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.

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).

The European Oleochemicals & Allied Products Group (APAG) welcomes the revision of the Renewable Energy Directive (RED II). To ensure that the European Commission’s proposal on the revision of RED II is coherent with circular economy principles, the cascading use principle, and the waste hierarchy, we ask for a level playing field between the different uses of biomass such as for biofuels and bio-based chemicals.

EFG Ref. Ares(2021)7093760 - 18/11/2021 European Fermentation Group POSITION PAPER November 2021 European Fermentation Group’s views on the review of the Renewable Energy Directive The European Fermentation Group welcomes the ongoing revision of the Renewable Energy Directive (RED II).

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

POSITION PAPER OCTOBER 2021 Cefic views on the Commission proposal amending the Renewable Energies Directive (RED III) Cefic welcomes the Commission ambition to increase the use of renewable energies by 2030. Europe urgently needs to upscale renewable energies and prepare import routes, to lower the CO2 content of energy produced and help facilitate the transition towards a climate-neutral energy system.

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

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries, such as chemicals, are indispensable for Europe’s transition, as solution providers to multiple value chains, including renewable energy technologies and low carbon emission energy.

The European Oleochemicals & Allied Products Group (APAG), a sector group from Cefic, welcomes the forthcoming revision of the Renewable Energy Directive by the European Commission. APAG is a long-established sector of the European bioeconomy.

The Hydrocarbon Resins, Rosin Resins & Pine Chemicals Producers Association (HARRPA), a sector group of Cefic, welcomes the decision of the European Commission to launch a review of the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II). HARRPA represents the European based producers of resins.

The European Fermentation Group (EFG), a sector group of Cefic, welcomes the forthcoming review of the Renewable Energy Directive by the European Commission. EFG is the voice of the European fermentation industry vis-à-vis EU institutions, national governments, and civil society.

Sustainable Fuels response to the Inception Impact Assessment on REDII Sustainable Fuels, which represents leading producers of clean components for liquid transport fuels, strongly supports the objectives of the European Green Deal. We believe that raising the share of renewable energy used in transport is an important ambition, and only achievable through a variety of fuels and technologies.

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

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.

The Packaging and Packaging Waste Regulation (PPWR) is an opportunity to make waste a resource in the EUs circular economy. Ambitious recycled content targets in the PPWR will ensure that waste has value enabling the further scale-up of recycling in the EU. This benefits the environment, the economy and reduces the EUs reliance on imports of virgin fossil raw materials to produce plastics.

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to review the rules regulating the placing on the market of packaging with a view to make packaging increasingly sustainable and circular and minimize waste to preserve planet’s resources (materials, food, water, energy, etc.).

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…

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu regrets that Phosphorus (meaning elemental phosphorus, P4 and derivates) is not listed in the proposed Critical Raw Materials Act as a Strategic Raw Material, as the substance/component is crucial for fire safety in batteries, renewable energy, electrical systems, circuit boards, electronic, power and data cables…

The European Chemical Industry supports the objective to secure a sustainable supply of critical raw materials to support the green and digital transitions and strengthen EU resilience. Access to raw materials, feedstock and energy at economically sustainable prices will remain an important element of the EUs chemical industry competitiveness, next to enabling its green and digital transition.

EFCG, the European Fine Chemicals Group, represents European manufacturers of APIs, excipients and fine chemicals. As producers of the essential building blocks used to make medicines, we welcome the Commission’s initiative to ensure a future-proof and crisis-resistant medicines regulatory system that will allow all EU citizens full and equal access to safe, state-of-the-art therapies.

Cefic welcomes the Commissions efforts in addressing existing concerns in the EFRAG technical advice from December 2025. We reiterate that the goal of the Omnibus I Directive is to deliver a meaningful reduction in compliance costs without compromising decision-useful transparency.

The EFCTC (European Fluorocarbons Technical Committee) supports the ambition of net-zero greenhouse gas emissions in the European economy by 2050 whilst underlining the issues raised by CEFIC in its contribution to the consultation, in particular, the needs for a deep transformation within one or two investment cycles as well as a detailed impact and feasibility assessment regarding the milestones towards 2050.

As the Green Deal communication recognizes, Energy-intensive industries such as chemicals are indispensable to Europe’s economy, as they supply several key value chains. Breakthrough transformation of our sectors is essential to reach a climate neutral Europe.

Cefic supports the EU Green Deal and Europe’s ambition to become climate neutral by 2050. With this in mind, we welcome the EU initiative to revise the Waste Framework Directive to improve waste management and to reduce the environmental footprint of society. As a Responsible Care®-registered industry sector, we aim at investing in the best available technologies and adopting the best practices to reduce waste.

The European chemical industry is an industry of industries – providing building blocks on which modern societies are built, our materials are found in all industries, from agriculture to construction, food and beverages, energy, healthcare, machinery, textiles, hospitals and transportation.

Cefic welcomes the Commissions initiative to develop a regulatory framework for the certification of carbon removals. Cefic hopes this initiative will pave the way for recognizing the contribution of technological solutions to carbon removals: the Commissions long-term strategy which underpins the EU Climate Law clearly emphasizes the role of industrial removals solutions for the achievement of the…

Fertilisers Efficiency Enhancers appreciates the opportunity to contribute to the Call for Evidence on carbon removals. We recognise carbon storage plays a key role in climate change mitigation and believe that complementary measures aimed at further carbon emissions reduction should be supported and promoted as well.

Whilst with different cost-implications and impact across sectors, the ETS provided reasonable protection against carbon leakage. Thus, ensuring ETS liquidity and sustained carbon leakage mitigation, even after 2040, is crucial to improve the climate policy framework. Regarding the MSR's effectiveness, there is more mixed feedback, with the main suggestion being to eliminate the invalidation of allowances.

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…

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Cefic welcomes the European Commission proposal on the Ecodesign for Sustainable Products Regulation and supports the overall objectives of this ambitious initiative. Well implemented, the ESPR is an opportunity for industry to take an active role in the European market transition towards sustainable products.

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu supports the objective of the Sustainable Products Initiative (SPI) to move forward product sustainability, circularity and energy and materials efficiency, including addressing chemicals.

MCEC supports the policy goal to create a circular economy in Europe, focusing on enhanced reusability and recyclability of products. However, we would like to stress that references to hazardous chemicals should be better defined in the initiative. Many chemicals need to have hazardous properties to ensure action efficacy.

We welcome the opportunity to provide feedback to the Commission’s Roadmap on the Sustainable Products Initiative. The European chemical industry is highly committed to bringing products to the market that are safe and have a low environmental impact, while maximising value for the consumers and the society. Innovation continues in search of more resource efficient and circular products.

A. Context Cefic welcomes the Commission’s focus on ensuring industry competitiveness for a climate-friendly transition, namely to become climate-neutral by 2050 while ensuring that European companies can globally compete on a level-playing field. Cefic remains a strong supporter of free and fair trade.

A. Context Cefic welcomes the Commission’s focus on ensuring industry competitiveness for a climate-friendly transition, namely to become climate-neutral by 2050 while ensuring that European companies can globally compete on a level-playing field. Cefic remains a strong supporter of free and fair trade.

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.

POSITION PAPER OCTOBER 2021 Cefic views on the Commission proposal to recast the Energy Efficiency Directive Cefic supports Europe’s ambition to become climate neutral by 2050. To achieve this objective, large volumes of competitively priced renewable and low-carbon energy, breakthrough technologies and enabling frameworks for the very large investments will be required.

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

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries (EIIs) are indispensable for Europe’s transition. The chemical industry provides all other sectors including efficiency solutions to multiple value chains such as the construction sector.

The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.

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 Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association (pinfa) is in favour of Repairing CPR as described in policy options B & D and aligned with the position paper sent by Construction Products Europe (CPE), which we support. Pinfa welcomes the proposal to revise the CPR in coherence with the Green Deal.

March 2023 Cefic input to the EC Public Consultation on the Revision of EU Legislation on hazard classification, labelling and packaging of substances and mixtures (CLP) The EU chemical industry supports the goals of the Chemicals Strategy for Sustainability: ensure that the chemicals are produced and used in a way that maximises their contribution to society including achieving the green and digital transition…

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

The Microbial Control Executive Council (MCEC) welcomes the opportunity provided by the European Commission to submit views about the forthcoming revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP, (EC) No 1272/2008).

Cefic welcomes the opportunity to comment on European Commission inception impact assessment on CLP. The text below highlights the key points related to five proposed options but detailed comments on all can be found in the attached document. 1.

The European Melamine Producers Association (EMPA) welcomes the opportunity provided by the European Commission to comment on the revision of the CLP Regulation, expected for Q2 2022. The publication of the Chemicals Strategy for Sustainability marked a milestone in the European chemicals policy framework, including the proposal to revise the CLP Regulation.

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.

Cefic, the European Council of the Chemical Industry, welcomes the Commission Better Regulation Consultation on the 14th Adaptation to technical progress of the CLP Regulation. We believe this is an important measure to ensure transparency and look forward for future opportunities to participate in regulatory consultations.

The Titanium Dioxide Manufacturers Association (TDMA) has become aware that the adaption to technical progress (ATP) that is the subject of this public consultation has been updated and a new version with substantive changes has been made available on the Commission Comitology Register.

The European UP/VE Resin Association is a CEFIC sector group representing suppliers of the Un-saturated Polyester (UP) and Epoxy Vinyl Ester (VE) resins. The UP Resins market in the European Union includes approximately 8,000 companies. That is ap-proximately 100,000 direct employees and an added value of €60 billion that is expected to grow to €85 billion by 2020 (1) .

The proposed classification of titanium dioxide (TiO2) is disproportionate and does not meet the burdens of legal compliance or certainty. The proposal is at odds with the stated positions of several Member States due to concerns about its added value for protection of human health and its wide-ranging impacts.

Revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity (Energy Taxation Directive or ‘ETD’ or ‘Directive’) Cefic comments 1. Managing the different global speeds.

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.

BioChem Europe, representing the biochemical sector in Europe, acknowledges the Commission's initiative to address the legislation for plants produced by new genomic techniques. As a pivotal stakeholder in the biobased chemical sector, we emphasise the significance of biotechnologies as key enabling tools for our sector and for the chemical industry in general.

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…

POSITION PAPER September 2025 Cefic Position Paper on the European Commission’s 2040 Climate Target proposal The European chemical industry supports the objective to reach carbon neutrality by 2050 by stimulating investments into the European economy.

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

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 IED (2010/75/EU) regulates large industrial emissions since the end of 2010. An evaluation in 2019 carried out by DG ENV showed that the IED is efficient, fit for purpose and has achieved its goals to a large degree as emissions have been reduced significantly across Europe. However there was also room for improvement which together with the targets of the EU Green Deal has triggered a review of the IED in 2021.

Cefic, the voice of the European chemical industry is strongly committed to contribute its proposals to support the review of the IED-Sevilla process. Cefic already supported the evaluation of the IED in 2018/19 and endorsed its members to provide broad response to the public consultation (PC) and the Targeted Stakeholder Survey (TS).

CES – Silicones Europe, a sector group of the European Chemical Industry Council (Cefic) representing all major producers of silicones in Europe, welcomes the opportunity to provide comments on the Inception Impact Assessment (IIA) for the revision of EU rules on food contact materials (FCMs) and supports the objective of this initiative.

Food Contact Additives (FCA), a Sector Group of the European Chemical Industry Council (Cefic), welcomes the opportunity to provide input to the Inception Impact Assessment (IIA) on the revision of EU rules on food contact materials (FCMs).

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 representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

Cefic representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

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.

EFCTC representing fluorocarbons manufacturers fully supports the objectives of the F-gas Regulation to encourage transition to lower GWP refrigerants. Our industry remains committed to do its part to comply with the already ambitious phasedown schedule for HFCs.

Response from the European Fluorocarbons Technical Committee (EFCTC) to the Inception Impact Assessment on the revision of Regulation No. 517/2014 (Ref. Ares (2020) 3402178 - 29/06/2020) is detailed in the attached document. While contributing to this consultation we remain very aware we are all still experiencing unprecedented times. As Cefic, we aim to maintain a high standard in our responses.

With the publication of the proposed Corporate Sustainability Reporting Directive (CSRD), Cefic welcomes further development of the EU Sustainable Finance Agenda. Reliable, comparable and relevant information on companies’ exposure to sustainability risks will enable informed decision-making that fosters investment in economic activities contributing to the socially just and sustainable economic transition.

Cefic is supporting the European Commissions initiative for a roadmap towards voluntary nature credits and is willing to further exchange experiences and insights based on the sectors best practices. See a first set of elaborated recommendations in the attached paper.

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

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.

Cefic welcomes the opportunity to provide first insights and suggestions for the REACH Revision Inception Impact Assessment public consultation. REACH is the most comprehensive regulatory framework securing safe use of chemicals. Recent European Commission’s reviews concluded that the system is fit for purpose, delivering on its objectives, and serves as a global model for chemical legislation.

The Microbial Control Executive Council (MCEC) welcomes the opportunity provided by the European Commission to submit views about the forthcoming revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH).

The European Melamine Producers Association (EMPA) welcomes the opportunity provided by the European Commission to share views regarding the revision of the REACH Regulation, expected for Q4 2022. With the publication of the Chemicals Strategy for Sustainability in October 2020, the European Commission proposed many actions to review and update the current policy framework on chemicals.

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, supports the industry and stakeholder position (1) that housing simplification is synergistic with harmonised safety requirements.

Cefic welcomes the European Commissions efforts to reduce the microplastics pollution, in particular with the current proposal to address plastic pellet loss. Cefic suggests that some additional considerations in the current proposal are needed to achieve such aim. In particular, Cefic suggests the following: For better clarification, a definition of plastic should be included in the text.

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The chemical industry is already nowadays a major producer and consumer of hydrogen. On a local level, production and consumption are typically well-balanced today.

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)

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.

Our goal is a successful circular economy for plastics and chemicals. Europe needs to expand its recycling infrastructure and markets rapidly and create competitive conditions that enable companies to compete globally and Member States to meet their targets.

APAG welcomes the Commission’s proposal for the ReFuelEU Aviation Regulation. We are pleased by the horizontal alignment with the Renewable Energy Directive (RED II) on sustainable transport fuels and the choice of a Regulation over a Directive. We are delighted that the European Commission’s proposal aims at promoting truly sustainable biofuels for aviation.

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)

Cefic welcomes the European Commission proposal on Waste Shipment Regulation to ensure the safe handling of wastes, to preserve the environment and human health by fighting against illegal imports and exports of waste within, from and to the EU, and to contribute to the transition to a competitive circular economy in the EU.

Cefic views on the revision of Waste Shipments Regulation Cefic has recently presented its 8-point Mid Century Vision for the Future of Europe; a Vision where the European Economy has gone circular, recycling all sorts of molecules into new materials.

INCOPA, the Inorganic Coagulants Producers Association, a Cefic Sector Group, supports the European Commissions proposal on the revised Urban Waste Water Treatment Directive. In particular, INCOPA supports the proposed new phosphorus (P) limit of 0,5 mg P/litre in urban wastewaters. Phosphorus facilitates the eutrophication in natural waters such as lakes, rivers and seas.

INCOPA, the European association for inorganic coagulant producers, welcomes the outlined priorities of the revision of the Urban Waste Water Treatment Directive. Our members manufacture inorganic coagulants, aluminum and iron salts, which are used to purify drinking water, treat wastewater and create vital industrial products. INCOPA is a Cefic sector group.

The Commissions effort to reduce the reporting burden on companies should further facilitate undertakings to properly prepare and provide quality reporting. Minimising the undue reporting burden will not only reduce costs for companies, but will also ensure that only the information which is useful to investors is reported on.

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.

Cefic welcomes the European Commission’s ‘Fit for 55’ package and supports strong action on climate change in line with the scientific advice provided by the Intergovernmental Panel on Climate Change (IPCC). We welcome the European Commission’s ‘Fit for 55’ package as a crucial step towards the EU climate-neutrality objective by 2050.

Cefic supports Europe’s ambition to become climate-neutral by 2050. We acknowledge the EU’s desire to significantly accelerate the transition, in order to increase our chances to reach climate-neutrality by 2050. Increasing the 2030 level of ambition can secure a balanced reduction pathway towards 2050 and redistribute in time the transition effort towards climate-neutrality.

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.

The Packaging and Packaging Waste Regulation (PPWR)1 makes recycled-content requirements a condition for plastic packaging placed on the Union market. The rules adopted under Article 7(10) must therefore enable legitimate trade in recycled materials and packaging, while ensuring that imported recycled content is counted towards EU targets only if compliance with requirements equivalent to the applicable EU…

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.

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new legislative proposal on strengthening the role of consumers in the green transition in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value).

POSITION PAPER MAY 2023 Cefic position on the proposal of the European Commission amending the EU Electricity Market Design Access to competitive, abundant renewable and low-carbon energy is critical to the competitiveness of the EU’s manufacturing industry and to the transition to climate neutrality.

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

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.

•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.

The UP/VE and Epoxy Europe sector groups of Cefic, the European Chemical Industry Council (EU Transparency Register n° 64879142323-90), strongly welcome the European Commissions proposal to include non-hazardous fibre-reinforced polymer composite waste under the new Annex IIIB entry BEU06 of Regulation (EU) 2024/1157 on shipments of waste.

Cefic, the European Chemical Industry Council, founded in 1972, is the voice of large, medium and small chemical companies across Europe, which provide 1.2 million jobs and account for about 17% of world chemicals production.

Please see the attached document on behalf of the Titanium Dioxide Manufacturers Association (TDMA) on the proposal for a Regulation on a common data platform on chemicals where we highlight Titanium Dioxide, the main substance we follow.

Please see attached document for CEFIC's feedback on the proposal for a Regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals

Cefic supports re-use of chemical safety data by public authorities in charge of the implementation of EU chemicals legislation, as an enabler of “One Substance-One Assessment’. Applying the ‘originator’ principle as a mechanism to overcome legal barriers to re-use by authorities of data generated by industry would ensure legal foreseeability and consistency of decisions on data treatment.

August 2022 Cefic response to Call for Evidence - ‘better access to chemicals data for safety assessments’ We support the re-use of chemical safety data to enable ‘One Substance One Assessment’ and a balanced dissemination of chemical safety information which incentivizes companies to invest in safety data generation, in full trust that their data will be protected from unfair use by competing entities whilst…

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

Cefic welcomes the opportunity to submit comments on the General Product Safety Directive (GPSD, Directive 2001/95/EC). With 96% of goods manufactured in Europe relying on chemicals, the European chemical industry is committed to ensuring chemical safety for all users.

Cefic supports the Commission's proposal for a common methodology based on the ISO 14083 standard. However, it remains important to continuously monitor other valuable sources and references which are consolidated in the market and may offer more accurate guidance for GHG emissions calculation and reporting. The use of primary data should be encouraged as much as possible to ensure more precise calculations.

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

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.

The Association of Synthetic Amorphous Silica Producers (ASASP) recognises the European Commission’s efforts to further improve the protection of human health and the environment and to ensure that regulations become more efficient and predictable and supports the Chemical Strategy for Sustainability (CSS) objective of improving effectiveness, efficiency, and coherence of safety assessments across EU legislation.

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.

Increasing the efficiency of the Internal Combustion Engine (ICE) has been the core driver of emissions reduction of passenger transport to date. In fact, average tailpipe CO2 emissions from petrol cars dropped by more than 30% between 2000 and 2016, largely due to increased performance of engines. At the same time, the fuel used in the car, also played an important part in making today’s cars cleaner.

Euro Chlor would like to thank the European Commission for the opportunity to provide feedback to this important legislative proposal. Euro Chlor represents the interests of chlor-alkali producers in Europe, we are a sector group of Cefic. Please find attached our input.

The legislative proposal creates an unparalleled administrative review mechanism accessible only to a specific stakeholder category. To ensure consistency with the EU Treaty system of legal remedies, it is of crucial importance that applicants under the Aarhus Regulation should only be admitted to request reviews of acts not entailing implementing measures.

Cefic welcomes the opportunity to take part in this Commission Roadmap and to contribute to the discussions on access to justice in environmental matters. Further to the targeted changes to the EU Aarhus Regulation and other new initiatives on access to justice in environmental matters presented in the Roadmap at hand, Cefic would like to provide to the Commission the following feedback: Targeted changes to the EU…

Fertilisers Efficiency Enhancers (FEE), a sector group of the European Chemical Industry Council (Cefic), welcomes the opportunity to provide input to the proposal for a Regulation regarding the digital labelling of EU fertilising products.

Cefic, the European Chemical Industry Council (www.cefic.org) welcomes the possibility to comment on the EU Commission Inception Impact Assessment on “Simplification and digitalization of labels on chemicals (CLP, Detergents, Fertilising Products)”. This feedback focuses on the CLP regulation.

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.

Cefic takes note of the European Commission proposal to update the list of pollutants affecting surface and groundwaters and welcomes the changes to the watch lists mechanism and subsequent timeframe for implementation. Cefic does, however, call for better alignment with EU legislations, enhanced use of standard methodologies, and a better-framed role for ECHA.

Cefic supports the revision of lists of pollutants affecting surface and groundwaters based on new scientific developments and on a thorough data collection involving a proper consultation of relevant stakeholders. In this paper, Cefic would like to share its views on the above-mentioned initiative. Water Framework Directive and European legislative initiatives Cefic supports the EU Green Deal.

Cefic believes that the Commission proposal for a Regulation on the use of railway infrastructure capacity in the Single European Railway Area is a significant step forward towards improving rail capacity management and increasing national and international rail freight efficieny, reliability and flexibility.

Fertilisers Efficiency Enhancers, a Sector Group of Cefic, appreciates the opportunity to contribute to the consultation on a Nutrients' action plan for better management. Please refer to the documents attached for detailed information about urease and nitrification inhibitors and their contribution towards the achievement of the ambitions of the Action Plan and the green Deal in general.

The European Pollutant Release and Transfer Register E-PRTR (166/2006/EU) provides the framework for the reporting of large industrial emissions since 2006. An evaluation carried out by DG ENV showed that it is efficient, fit for purpose and has achieved its goals to a large degree. It has been reviewed and is intended for replacement via the new Industrial Emission Portal IEP by January 1, 2026.

Cefic supports the European Commission aim of a revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). Annex I of it lists 20 chemical sectors being in scope of this directive, and close to 3,000 chemical installations are reporting under E-PRTR, making the chemical industry one of most important stakeholders of this directive.

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 welcomes the opportunity to comment on the Commission’s proposal. Effective enforcement of EU environmental legislation is crucial to the EU chemical industry and this requires both adequate tools and resources to detect, investigate, prosecute criminal activity and effective coordination and cooperation mechanisms across Member States.

Comment provided by EFCTC: European Fluorocarbons Technical Committee. EFCTC considers the Environmental Crime Directive could further enhance these efforts through its horizontal approach across EU measures, including the F-Gas Regulation, to help develop a more coherent and effective framework that better achieves the EU’s climate action objectives.

The Phosphorus, Inorganic and Nitrogen (PIN) Flame Retardants Association, pinfa, www.pinfa.eu welcomes the European Commission’s initiative to assess the need for regulation to manage the environmental impact of photovoltaic (PV) modules, inverters, and systems.

The Hydrocarbon Solvents Producers Association would like to make the following comment: The cut-off concentrations for those substances listed in Annex III should be based on the REACH / CLP regulatory cut-off concentrations of 0.1 % w/w in the final mixture.

Cefic's Oxygenated Solvents Producers Association (OSPA), part of the European Solvents Industry Group (ESIG), and the BDO & Derivatives Sector Group welcome the opportunity to comment on the draft Commission Delegated Regulation amending Annexes I and V to Regulation (EU) No 649/2012.

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 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).

The Aromatics Producer Association (APA), a sector group of Cefic supports the commission efforts to beat cancer and in the light of this, agrees to the revision of the OEL of benzene from the current binding EU value of 1 ppm to a value of 0.2 ppm 4 years after publication of the 4th amendment to the CMD.

POSITION PAPER MARCH 2017 The European Chemical Industry Council (Cefic) views the Recast of the Persistent Organic Pollutants (POPs) Regulation as an opportunity for the EU to improve its approach to the nomination of new substances under the Stockholm Convention.

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

Cefic welcome the EU POP Recast proposal and the opportunity to provide comment. Those comments are presented in the attached files. The 2018 updated position paper based on the Recast proposal issued earlier this year, completes the position paper shared last year on the draft Recast proposal available at that time.

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.

This is a response from the European Fluorocarbons Technical Committee (EFCTC) to the Inception Impact Assessment on the revision of Regulation No. 1005/2009 (Ref. Ares (2020) 1782671 - 26/03/2020). EFCTC notes that the Commission evaluation of Regulation No.

Although most of the European chemical industry manufacturers use distributors to supply chemicals to end-users in consumer markets, they feel obliged to ensuring the security of chemicals across the entire supply chain.