We at DSM thank the European Commission for the chance to comment on the inception impact assessment of the Sustainable Products Initiative (SPI), which is an important next step to enhance Europe’s market for high-quality secondary raw materials and circular products. As the new Circular Economy Action Plan rightly points out, the performance of frontrunners must become the market benchmark and standard.
DSM
DSM
Company · Netherlands · EU Transparency Register 73926352722-07
6
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1210 companies & groups on this site, they rank #266 by legislative files engaged, a count of participation, not a measure of influence.
2
declared lobbying FTE
self-declared
€900K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2009
in the register since
Declares membership of
- AIJN (European Fruit Juice Association)
- AMFEP (Association of Manufacturers and Formulators of Enzyme Products) →
- Cefic (European Chemical Industry Council)
- Cosmetics Europe (European trade association for the cosmetics and personal care industry)
- EFCG (European Fine Chemicals Group)
- EFEO (European Federation of Essential Oils)
- EFF (European Food Forum)
- EFFA (European Flavour Association) →
- EFFCA (European Food and Feed Cultures Association)
- Europabio (European association for Bioindustries)
- EUSFI (European Specialty Food Ingredients)
- FEFANA (EU Association of feed additives and premixtures operators)
- and 7 more
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Companies & groups
- Registered as
- DSM-Firmenich (dsm-firmenich)
- Head office
- Kaiseraugst, Switzerland
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
DSM filed 6 positions between 16 Nov 2020 and 21 Aug 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2020 · 1 filed2021 · 3 filed2025 · 1 filed2026 · 1 filed
What they argued
Drawing on over 150 years of research and innovation, dsm-firmenich is a pioneer in the use of modern biotechnology to develop, manufacture and commercialize new and better food and beverage ingredients, essential nutrients, fragrances, personal care and health products.
The MD 2006/42/EC introduced textile ropes for lifting purposes as part of lifting machinery and lifting accessories. Since then, complexity, unclarities and ambiguities have made application of the MD very difficult. The revision of the MD is a singular chance for clarification of utmost importance under the current market circumstances and increasing need for safe and reliable products being put on the EU market.
DSM welcomes the effort to collect additional information for a fact-based analysis of the sustainability performance of European farming systems and to enable monitoring of progress to happen. To secure the possible use of the data collected for GHG emissions modelling, it would matter to capture, in the future FSDN, farming parameters which are known to influence GHG emissions.
Based on extensive user experience of Regulation (EC) No 1831/2003 DSM Nutritional Products Ltd supports the initiative to modernise the legislative framework in order to address new developments and needs that have emerged over the past 20 years.
We support the objectives of Regulation (EU) No 649/2012 and the Rotterdam Convention in promoting transparency in the international trade of hazardous chemicals. However, we would like to express concerns regarding the inclusion of fragrance ingredients such as Lilial within a regulatory framework primarily intended for pesticides and industrial chemicals. Lilial (Cas no.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 47.
Is this your organization?
Everything on this page comes from DSM’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.