FECC

Fecc welcomes the European Commissions initiative to establish a more harmonised framework for national registers of producers under the Packaging and Packaging Waste Regulation (PPWR). In the attached feedback, Fecc provides practical considerations from the perspective of the chemical value chain, with a particular focus on consistent implementation across Member States, proportionate data requirements…

The European Association of Chemical Distributors (Fecc) welcomes the objectives of the forthcoming Circular Economy Act (CEA) but stresses that its success will depend on rules being practical, proportionate, and workable for SMEs.

The European Association of Chemical Distributors (Fecc) supports the objectives of the Industrial Accelerator Act (IAA) to advance decarbonisation while strengthening Europes industrial competitiveness and preventing relocation of value creation outside the EU.

Fecc welcomes the opportunity to provide feedback on the Commissions proposal for Voluntary Sustainability Reporting Standards for SMEs (VSME), supporting the objective of a proportionate tool that facilitates sustainability data sharing across value chains.

Fecc acknowledges the consultation on Sustainable Corporate Governance and welcomes the opportunity to provide input. In this context, we would like to raise the following points in this consultation: 1. The synergy between the Sustainable Governance and the proposed Due Diligence Directive should be put into perspective.

The European Association of Chemical Distributors (Fecc) supports the principle of environmental impact information on products being clear, transparent, and comparable, and that such information can help consumers to make more sustainable choices.

Fecc supports Sustainable Products Initiative roadmap and the measures proposed to assess the presence of certain chemicals in products present in the EU market. In this context we would like to raise the following points on behalf of the European chemical distribution sector and in particular the many SMEs we represent: - The synergy between the Sustainable Products Initiative and the Chemical Strategy for…

The European Association of Chemical Distributors (Fecc) welcomes the opportunity to contribute to the Commissions consultation on the potential extension of the Carbon Border Adjustment Mechanism (CBAM). We support the EUs climate ambition and recognise CBAM as an important tool to ensure a level playing field.

With regard to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022, the European Association of Chemical Distributors (Fecc) would like to comment on various points that are critical from our point of view. Please find our comments in the attached document.

Fecc acknowledges the inception impact assessment on CLP under the objectives of the Chemical Strategy for Sustainability (CSS). In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent: 1.

Feccs feedback on the Biotech Act II urges the EU to bridge the scale-up gap for industrial biotechnologies and harmonise fragmented regulations to support SMEs. It calls for prioritising biomass for high-value industrial use, ensuring a global level playing field against lower-cost regions like Asia, and formally recognising distributors as essential market enablers.

Fecc welcomes the Commissions draft Implementing Regulation on recognising carbon prices paid in third countries under CBAM and supports its objective of avoiding double carbon costs while maintaining a level playing field.

Fecc acknowledges the consultation on the Revision of EU rules on food contact materials. Fecc would like to raise the following points in this consultation: 1. The harmonisation on EU rules pertaining to food contact materials (FCMs) should be taken into perspective. Although rules at a Member State level exist, the fragmented implementation of these rules results to the reduced production and distribution of FCMs.

Fecc welcomes the European Commissions initiative to simplify environmental legislation, stressing that simplification must ensure rules remain workable for complex supply chains while maintaining high levels of environmental and health protection.

Fecc acknowledges the inception impact assessment on REACH under the objectives of the Chemical Strategy for Sustainability (CSS). In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent: 1. Environmental footprint information should consider an enforceable safety scheme.

Fecc acknowledges the consultation on the Cyber Resilience Act and welcomes the opportunity to provide input. In this context, we would like to raise the following points in this consultation: 1. The synergy between the Cyber Resilience Act and current national initiatives should be put into perspective.

Fecc welcomes the opportunity to comment on the Digital Product Passport (DPP) Registry and supports its objectives under the ESPR. It highlights the importance of clear terminology and a strict separation of roles and responsibilitiesparticularly between data originators and data handlersto avoid unintended liability shifts to distributors.

Fecc acknowledges the consultation on Single-use plastic beverage bottles EU rules for calculating, verifying and reporting on recycled plastic content and welcomes the opportunity to provide input. As the leading voice for the European chemical distribution sector, we represent companies that play a vital role in the supply chain of plastics, ensuring compliance with regulatory requirements and maintaining high…

Fecc the European Association of Chemical Distributors welcomes the opportunity to contribute to the Commissions Call for Evidence on sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).

Fecc welcomes the European Commissions initiative to harmonise the rules for calculating and verifying recycled content in plastic packaging. As representatives of the European chemical distribution sector, we support a clear, reliable and proportionate framework that can work across complex chemical value chains and facilitate the uptake of recycled materials.

Fecc welcomes the opportunity to provide feedback on the proposed conditions for importing recycled materials into the EU for use in packaging. Representing the European chemical distribution sector, Fecc supports the objective of ensuring that imported recycled materials meet conditions equivalent to those applicable in the EU.

Fecc acknowledges the consultation on the evaluation of the Cosmetic Products Regulation (CPR) and welcomes the opportunity to provide input. As the leading voice for the European chemical distribution sector, we represent companies that play a vital role in the supply chain of cosmetic ingredients, ensuring compliance with regulatory requirements and maintaining high standards of safety and sustainability.

Fecc welcomes the opportunity to provide feedback on the Commissions initiative on green-listing certain waste for shipments to recovery between Member States. Fecc supports facilitating cross-border shipments of waste destined for recovery and strengthening the EU internal market for secondary raw materials.

Fecc welcomes the Commissions Call for Evidence on establishing a European Critical Raw Materials (CRM) Centre and supports its objective of strengthening the EUs strategic autonomy and securing sustainable CRM supply.

Fecc acknowledges the consultation for the upcoming initiative on streamlining scientific assessments (link). At the same time, we would like to raise the following points in this consultation: 1. Risk assessment should be maintained at the corresponding level of expertise for each agency.

Fecc acknowledges the consultation for the upcoming initiative on revising the Cosmetics Products Regulation under the Chemical Strategy for Sustainability. At the same time we would like to raise the following points in this consultation: 1.

Introduction: The European Association of Chemical Distributors (Fecc) supports the EU's climate goals but urges the Commission to align CBAM certificate rules with business realities. Our key recommendations, detailed in our attached paper, are: - Coherent Rollout: All Member States must implement the rules simultaneously to avoid administrative friction and market fragmentation.

While acknowledging the consultation for a fair and competitive digital economy Fecc would like to raise the following points: 1. On the scope and definition of digital activities/transactions or companies subject to the initiative - Fecc welcomes the initiative of the Commission and the national Competent Authorities to further promote digitalisation within the EU, provided that it is in accordance with the…

Fecc acknowledges the roadmap proposed on ‘Trade disputes – mechanism to deter & counteract coercive action by non-EU countries’ and the measures proposed to allow the EU to address practices by non-EU countries that seek to pressure on Member States. In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent.

Fecc welcomes the opportunity to provide feedback on the Commissions initiative on financial compensation under the EU Emissions Trading System for buildings and road transport (ETS2). While supporting the EUs climate objectives and the role of carbon pricing in the green transition, Fecc highlights the need for the financial compensation framework to adequately consider the indirect cost impacts on downstream…

Fecc welcomes the opportunity to provide feedback on the European Commissions initiative to amend Annexes I and V to Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals. Fecc supports the objectives of the PIC Regulation and the EUs commitment to the safe management of chemicals globally, while stressing the need for updates to remain practical, predictable and proportionate for…

Fecc Feedback to Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on monitoring and controlling drug precursors and repealing Regulations (EC) No 273/2004 and (EC) No 111/2005. Fecc notes the above-mentioned proposal from the European Commission and welcomes the opportunity to provide feedback (see document attached).

Fecc acknowledges the consultation on EU-Japan trade agreement evaluation and welcomes the opportunity to provide input. In this consultation we would like to raise the following points: 1. Strengthened Bilateral Cooperation: Fecc endorses the initiative to enhance relations between the EU and Japan, particularly in the areas of trade, investment, and sustainable development.

Fecc notes the European Commission initiative that would include additional drug precursors in the list of controlled substances used in the production of illicit drugs - specifically targeting substances that can only be used for drug production, known as designer precursors - and welcomes the opportunity to provide feedback (see file attached).

Fecc notes that the Commission strives to improve the security situation in the European Union and proposes further initiatives and options to minimise the misuse of ‘high-risk chemicals’ for terrorist or criminal purposes and welcomes the opportunity to provide feedback. However, as the names of the proposed substances have not been revealed yet, detailed comments are not possible at this stage.