Svaz chemického průmyslu ČR

The proposal builds on the EU’s efforts to develop the circular economy and digitalisation. In reality, its adoption will mean that large firms will have to invest in IT systems linked to state registries, which is likely to simplify their administrative processes in the long run.

Filed in Czech · English published by the European Commission

The Association of the Chemical Industry of the Czech Republic strongly disagrees with the lowering of benchmark values proposed by the European Commission. Limiting the volume of free allocation at a time when European industry is facing extremely difficult economic conditions will not primarily lead to technological transformation and emission reductions while maintaining production in Europe, but rather to the…

Filed in Czech · English published by the European Commission

Call for evidence: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions In general, we do not support the reduction of free allowances allocation, particularly due to the CBAM factor in strategic sectors, such as chemical production, including fertilizers.

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

We are quite skeptical about recognizing carbon costs outside the EU due to the absolute disparity between the functioning of carbon charging in the EU and outside the EU. Even if a system outside the EU exists, we are unable to assess its relevance in a wider perspective.

We reject additional administrative and financial burdens for companies. DPP services must be legislatively dedicated to the EU and the national authorities. It is unacceptable to create requirements for the purchase of any services in connection with DPP by legislation, or to create a completely new market for DPP services ( Recital 3, 4, 14, hereinafter Art. 3). Art.

SCHP ČR has consistently advocated for the material recovery of plastic waste through chemical recycling methods, which we consider essential for achieving a circular economy. Without chemical recycling, it is impossible to ensure sufficient substitution of fossil raw materials and to promote the responsible use of plastics within the packaging, automotive, and other sectors.

The draft implementing regulation establishing the criteria under which plastic waste ceases to be waste and becomes a secondary raw material defines End of Waste (EoW) criteria (input material, processes, product quality), thereby supporting a unified market for recyclates.

The subject of the proposal is to reduce the PCB content in substances, mixtures and articles from 5 mg/kg to 0.2 mg/kg - we cannot agree with this in principle and the proposed reduction in the limit should be deleted. We request that the current limit be maintained. Justification: The proposed limit is not realistic.