Dow Chemical

You will find in the enclosed file the detailed feedback from Dow. Dow is an American multinational chemical company, among the three largest chemical producers in the world. Dow manufactures plastics, industrial intermediates, coatings and silicones to deliver products and solutions for its customers in various market segments, such as packaging, infrastructure, mobility and consumer care.

Dow’s priorities for industry decarbonization in the European Union Open public consultation concerning the 2040 European Climate law amendment 15 September 2025 Dow is one of the world's leading materials science companies, serving customers in high-growth markets such as packaging, infrastructure, mobility and consumer applications.

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

We are asking to include cotton linters in the European Union Deforestation regulation. Not including them is giving an unfair competitive disadvantage to wood pulp suppliers, both raw materials of cellulose ethers production. At the same time is also creating a regional disadvantage to Europe, since the majority of the cotton linters are coming in products from Asia.

Dow has adopted a Decarbonize and Grow strategy. We are committed to the Paris Climate Agreement and the EU Green Deal. We intend to be carbon neutral by 2050 and will reduce our CO2 emissions by 15% by 2030 (from the 2019 baseline), bringing the overall reduction to -30% compared to 2005.

About Dow Dow (NYSE: DOW) is one of the world’s leading materials science companies, serving customers in high-growth markets such as packaging, infrastructure, mobility and consumer applications. Our global breadth, asset integration and scale, customer-focused innovation and leading business positions enable us to achieve profitable growth and help deliver a sustainable future.

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

We support the proposal as it establishes a more rigorous and environmentally responsible framework for exporting non-hazardous waste from the EU. I particularly agree with the Commission's risk-based approach and its decision to apply stricter scrutiny to ferrous and non-ferrous metal waste due to the associated risks from heavy metals, emissions, contaminated residues, and resource-intensive treatment processes.

Dow appreciates the opportunity to comment on the proposed new rules extending restrictions for CMR substances under the REACH regulation. Dow is committed, as part of our Safer Materials approach, to ensuring that the materials we bring to marketand the way we manage them along the wayare designed for safety (https://corporate.dow.com/en-us/purpose-in-action/safer-materials.html).

We agree with all three changes as they are consistent with the EU's hazard-based approach for protecting vulnerable populations and are supported by updated scientific and regulatory developments. The prohibition of Lilial is particularly justified given its classification as a reproductive toxicant (Repr. 1B), making its continued use in children's toys difficult to defend from a risk-management standpoint.