Association of Chemical Industry of the Czech Republic

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

Czech Chemical Industry Association (SCHP ČR) In our opinion, the actual (negative) impact of carbon pricing on industry in the EU, in combination with other “fit for 55” regulations, has not manifested yet. It will show in the next five years, as a result of the impact of the linear reduction factor, the end of free allowances, the CBAM factor and the tightening of emission limits, which are contrary to the idea of…

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

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)

The Czech Chemical Industry Association supports the revision of the CLP Regulation, which will clarify some of the contested provisions, supplement them or adapt them to scientific progress. This concerns, for example, notification of information on mixtures under Annex VIII, online sales or new forms of labelling (digital labelling).

Filed in Czech · English published by the European Commission

In the framework of revision of the CLP Regulation the introduction of new hazard classes (such as endocrine disruptors) and corresponding criteria is proposed. The criteria for identification of endocrine disruptors (EDs) for the purposes of the Biocidal Products Regulation and the Plant Protection Products Regulation are in place.

Association of Chemical Industry of the Czech Republic disagrees with the TiO2 entry to Annex VI (CLP Regulation) for the following reasons: 1. Particle effect is not intrinsic property The intrinsic property is the one that can be allocated to a specific substance. RAC’s recommendation operates with a general particle effect assigned for the group of Poorly Soluble Low Toxicity (PSLT) particles.

SCHP CR position on climate targets for 2040 On 2 July 2025, the European Commission proposed, in accordance with Article 4(3) of Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing a framework for achieving climate neutrality and amending Regulation (EC) No 401/2009 and Regulation (EU) 2018/1999 ("European climate legal framework"), the Union's climate target for…

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.

The EU has a robust framework for regulation of chemicals, which is the most comprehensive in the world. There are REACH and CLP Regulations and 40+ pieces of EU chemicals legislation, that strictly regulate management of chemicals. The result of implementation of the REACH Regulation is the largest database of information on chemical substances in the world.

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.

SCHP ČR supports the establishment of technology-neutral, harmonised and scientifically robust criteria based on the demonstrable environmental impact of the specific facility concerned, rather than solely on the type of technology employed.

The Association of the Chemical Industry of the Czech Republic (SCHP ČR) supports the establishment of a harmonised methodology for calculating and verifying the recycled content of plastics in packaging throughout the EU, in order to ensure the consistent application of the PPWR requirements and to support the objectives of the circular economy.

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.

In the view of the SCHP ČR, the implementing act should establish a legally predictable, non-discriminatory and practically enforceable system for recognising recycled content originating in third countries. The assessment must be based on the level of protection and quality actually achieved, rather than on the formal identity of legal provisions, while maintaining independent verification and effective safeguards…

Association of Chemical Industry of the Czech Republic agrees, that chemicals´labels are overloaded with information, making them difficult to read and understand, especially for consumers (eg. new introduction of UFI code on the labels of some chemical mixtures). We support therefore simplification and streamlining of labels under CLP and Detergent Regulation.

Comments of Association of Chemical Industry of the Czech Republic on the proposal to amend the Directive 2004/37/EC of the EP and of the Council on the protection of workers from risks related to exposure to carcinogens, mutagens or reprotoxic substances at working environment.

Lead substances in explosives/detonators – comments We support the comments submitted by International Lead Association and we would like to add following: • Lead compounds are used for the production of detonators and explosives since 1900s.

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.