European Advanced Carbon and Graphite Materials Association

We thank the Commission for the opportunity to contribute to this major new policy initiative. In the attached paper, we detail our recommendations. In a nutshell, we propose the following: Add graphite to the EU Batteries Regulation mandatory recycled content targets by 2030 and set clear penalties for non-compliance.

The European Advanced Carbon and Graphite Association welcomes the publication of the Industrial Accelerator Act, which aims to scale up European manufacturing in key sectors and technologies, strengthen demand for EU-made low-carbon industrial products, and support high-quality jobs and economic growth. However, for the proposal to be truly effective, we believe it should be strengthened in three key areas: 1.

Ensuring Europe’s economic resilience with regard to carbon and graphite Page | 1 Part I Executive summary and general comments Part II Upstream securing raw materials (natural graphite, coke, pitch, other carbon sources) Part III Synthetic graphite processing Part IV Markets, Trade and Competitiveness Part V Circularity European Advanced Carbon and Graphite Materials Association asbl Avenue de Tervueren, 168, box…

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

Our main asks are the following: (1) Clarify the Scope: Explicitly state that manufacturers of intermediate components and industrial consumables are not covered by the Taxonomy, and ensure that sharing a NACE code with an eligible activity does not create a presumption of eligibility.

The EU’s CRM Act Comments and suggestions • An overall framework for 2030 EU strategic autonomy Introduction Europe’s accelerated REPowerEU clean energy goals but also some its other policies (such as agraculture, construction and renovation, health care) require a considerable increase of strategic metals and minerals for new technologies, and a number of raw materials are central in several strategic areas.

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

The European Advanced Carbon and Graphite Materials Association (ECGA), representing 37 companies producing 100% of the EUs graphite electrodes and natural graphite, welcomes the opportunity to contribute to the review of the EU ETS1 framework post-2030.

ECGA, the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology acknowledges the publication of the…

The Emissions Trading System (2021 – 2030) should remain the main market instrument for Europe’s industries to cost-effectively reduce their emissions. Carbon and graphite products are commodities that are traded worldwide. This leads to high trade intensity and a globally competitive market.

The European Carbon and Graphite Advanced Materials Association (ECGA) welcomes the European Commission's initiative to develop a Circular, Regenerative, and Competitive Bioeconomy. We strongly support efforts to integrate bio-based feedstocks into industrial processes, which align with our commitment to reducing costs and the environmental footprint of our products.

The European Carbon and Graphite Association (ECGA) acknowledges the publication of the Fit for 55 Package as the largest and probably the most significant cluster of measures the EU has ever published at the same time, towards the same goal, namely, the EU carbon neutrality by 2050.

Response to the European Commission Call for Evidence on the carbon price paid in a third country. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern…

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology.

Response to the European Commission Call for Evidence on the methodology for the definitive period starting on 1 January 2026. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

ECGA and its members support several key measures for the EU steel industry. Regarding tighter caps for quotas, we advocate setting Tariff Rate Quota (TRQ) volumes at approximately 50% of 2024 import levels, equating to roughly 16-18 million tonnes. These TRQs should be applied universally to all third countries without any exemptions. A strict "melted and poured" origin requirement must be enforced.

The attached ECGA Position Paper responds to the European Commissions European Grids Package, highlighting the urgent need to ensure competitive, predictable, and reliable electricity access for Europes energy-intensive industries.

ECGA welcomes the European Commissions initiative to develop an Electrification Action Plan. As one of Europes most electricity-intensive sectors, carbon and graphite production depends on stable, affordable and predictable access to low-carbon power. Without this, investment in decarbonisation and competitiveness in Europe is at risk.

Service providers will be subjected to intense competition and will have to answer the requests of demanding customers. They will have to ensure a very high level of security for confidential business data. They will need to guarantee swift and transparent interoperability with their competitors. And finally they will not be able to monetise the wealth of high-value data that they will be handling.

We believe the Advanced Materials Act must deploy a comprehensive suite of demand-side policies to create a predictable market, as existing instruments for research and scale-up cannot alone bridge the "valley of death" to profitable production.

The European Advanced Carbon and Graphite Materials Association (ECGA) recognises the Commissions intention to implement the CO transport infrastructure as part of the EUs efforts to achieve climate neutrality. While the objective is understood, there are reasons for concern that warrant careful consideration.

Page | 1 Ref. Ares(2025)8329674 - 02/10/2025 SUPPORTING THE EUROPEAN GRAPHITE INDUSTRY THROUGH COMPREHENSIVE LIFECYCLE ASSESSMENTS The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's review of CO₂ emission standards for light-duty vehicles. This revision represents an opportunity to strengthen European industrial competitiveness without compromising climate ambition.

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

Executive Summary The graphite and carbon materials sector is a key enabler of EU decarbonisation and supports strategic value chains, including batteries, steel, semiconductors and advanced manufacturing. The current framework under the Energy Efficiency Directive (EU) 2023/1791 has improved energy performance and remains a central pillar of EU energy policy.

Response to the European Commission Call for Evidence on CBAM certificates - adjustment of obligation to surrender them to take account of free ETS allowances. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

The European Advanced Carbon & Graphite Materials Association (ECGA), representing Europes carbon and graphite producers, welcomes the revision of the EU Energy Security Framework and supports measures that strengthen resilience, ensure affordability, and secure stable access to clean energy for industrial consumers.

Founded in 1995 and based in Brussels, ECGA is the voice of the European advanced carbon and graphite industry. Its members manufacture graphite electrodes for steelmaking and foundries, electrodes and cathodes for aluminium and ferroalloy production, battery-grade graphite materials, and specialty carbon and graphite products serving applications ranging from industrial processes and advanced manufacturing to…

The European graphite association welcomes the introduction by the Commission of a new carbon footprint methodology for battery-grade graphite. The current proposal is fully in line with the Batteries regulation and will help further a greater decarbonisation of the automotive and energy storage sectors.

European battery-grade graphite offers demonstrably superior sustainability performance compared to imports: lower carbon emissions from more efficient processes and cleaner energy grids, full regulatory compliance, transparent supply chains, and respect for labour rights.

Thanks for the opportunity to contribute. You will find here attached our position paper. Our main requests are the following: For battery-grade graphite: Domestic content rules for recycled graphite in EU batteries Funding for certification of recycled anode materials Standardisation of graphite concentrate composition Battery passport data to drive sustainable demand For carbon fibres, we ask the Commission to add…

We thank the Commission for the opportunity to contribute. You will find our detailed position paper in attachment. Essentially, we, European manufacturers of carbon fibres, support the 70% recyclability thresholds for the blades of wind turbines.

The European carbon and graphite industry calls for a defence procurement framework that ensures European strategic autonomy by: (1) Setting mandatory European content requirements (5070% for materials, 60% for components) and prioritizing ITAR-free supply chains for sensitive defence technologies.

Occupational Exposure Limits for PAHs that support workers’ safety Legal justification • There is no evidence that there is a need for EU wide harmonised legislation. National limit values are in place and exposure is closely monitored. The need and benefits of a harmonised specific OEL on PAHs has not been assessed. • No economic assessment of the transition values to the final target value has been carried out.

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

Occupational Exposure Limits for PAHs that support workers’ safety Legal justification • There is no evidence that there is a need for EU wide harmonised legislation. National limit values are in place and exposure is closely monitored. The need and benefits of a harmonised specific OEL on PAHs has not been assessed. • No economic assessment of the transition values to the final target value has been carried out.

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

ECGA's main policy asks for a single market for defence focus on three key measures: (1) Implement European content requirements using physical origin criteria (e.g., graphitised in Europe) to ensure strategic carbon and graphite materials are genuinely produced in the EU, with ITAR-free mandates for the most sensitive defence applications.

ECGA welcomes the European Commissions proposed AGILE programme and underscores the critical role of advanced carbon and graphite materials in modern defence. These materials are indispensable for applications ranging from missile propulsion and satellite optics to lightweight stealth structures and military batteries, yet European suppliers face significant barriers to market entry.