Verband der Chemischen Industrie e.V.

The VCI supports harmonised, digital and interoperable producer registers. However, the draft should be revised to ensure that the reporting framework is proportionate and workable. The VCIs key requests are: - Reduce and cluster the detailed plastic reporting categories to the level demonstrably necessary for PPWR monitoring.

Anzahl Seiten: 10 | Stand: 06.11.2025 Position - VCI CIRCULAR ECONOMY ACT Die chemisch-pharmazeutische und biotechnische Industrie spielt eine zentrale Rolle bei der Transformation hin zu einer Kreislaufwirtschaft.

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

The Commissions proposal takes an important step by explicitly recognising the chemical industry as a strategic sector and by seeking to bridge gaps between existing frameworks such as the NZIA and CRMA. However, the overall proposal falls short of delivering the conditions needed for a competitive and resilient chemical industry and successful industrial transformation.

Renewables and RFNBOs need to become competitive The amending Directive focuses on increasing the renewable energy target to at least 40 % by 2030. For the industrial sector, an indicative annual increase in the share of renewables and a binding target of at least 50 % RFNBO share of hydrogen use by 2030 is set.

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VCI-Position: Inception impact assessment on the revision of Directive (EU) 2018/2001 (RED II) Competitiveness is a driver for sustainability VCI welcomes the consultation of the roadmap on the revision of RED II. Industry is ready to support the transition of a carbon neutral energy supply system with innovative processes and products.

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

The Verband der Chemische Industrie e.V. (VCI) brings together companies in the chemical and pharmaceutical industry that sell their products to business and private customers worldwide. We welcome the European Commission’s efforts to promote, through the Packaging and Packaging Waste Regulation (PPWR), as part of the new Circular Economy Action Plan under the Green Deal, a unified framework for the sustainable use…

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Comment on Inception Impact Assessment „Review of the requirements for packaging and other measures to prevent packaging waste“ When amending the essential requirements on packaging to improve design for reuse and promote high quality recycling, it should be considered that the functionality of the packaging (e.g.

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

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and welcomes the European Commissions draft of the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria (TSC). VCI considers the withdrawal of the activities PPC 1.1 and 1.2 from the Environmental Delegated Act as a constructive step.

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and welcomes the European Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria (TSC).

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and welcomes the European Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria (TSC).

The VCI supports the European Commissions proposal establishing a framework for ensuring a secure and sustainable supply of critical raw materials (Critical Raw Materials Act, CRM Act; COM(2023) 160). We highly appreciate inclusion of strategic raw materials into a regulatory framework. Quantifiable objectives on Union extraction, processing, and recycling capacities offer planning and investment security.

VCI and its associated professional associations represent the interests of approximately 1,900 companies in the chemical and pharmaceutical industry and related sectors vis-à-vis politics, authorities, other areas of the economy, science, and the media. In 2022, the member companies of the VCI generated sales of around 260 billion euros and employed nearly 550,000 employees.

VCI and its associated professional associations represent the interests of approximately 1,900 companies in the chemical and pharmaceutical industry and related sectors vis-à-vis politics, authorities, other areas of the economy, science, and the media. In 2022, the member companies of the VCI generated sales of around 260 billion euros and employed nearly 550,000 employees.

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and acknowledges the European Commissions draft Delegated Acts published on 8 May 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain European Sustainability Reporting Standards (ESRS).

The German chemical industry supports the objective of net-zero GHG emissions by 2050 set out in the draft. In addition to the reduction through the EU ETS, the sector also contributes to climate protection through its products. The VCI study ‘Roadmap Chemie 2050’* shows that a net-zero GHG production is technologically feasible by 2050.

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The German chemical industry supports the achievement of the global 2 °C objective 2050. In order to achieve the objective of net-zero GHG emissions, the sector will face a huge transformation process and major challenges in the coming years. According to a recent study by the VCI, it is technologically possible to produce net-zero GHG by 2050.

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VCI-POSITION Comments on the Proposal (COM(2023)420) for a Directive of the European Parliament and oft the Council amending the EU Waste Framework Directive (2008/98/EC) of 5.7.2023 With this draft, the EU Commission intends to revise the EU Waste Framework Directive.

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

With this initiative, the EU Commission intends to revise the EU Waste Framework Directive. One of the main objectives is to better implement and strengthen the EU waste hierarchy in order to optimise waste prevention, preparation for re-use and recycling. In principle, this goal of the EU Commission is supported by VCI. The chemical industry is making a variety of contributions to this.

Kommissionsvorschlag „Sorgfaltspflichten von Unternehmen im Hinblick auf Nachhaltigkeit“ darf Unternehmen nicht überfordern Menschenrechtliche Sorgfalt gehört zum Selbstverständnis unserer Mitgliedsunternehmen. Deswegen unterstützen wir eine praktikable europäische Lieferkettenrichtlinie, die ein Level-PlayingField schafft.

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

The German Chemical Industry Association (VCI) welcomes the efforts of the European Commission to create a market for certificates for carbon removal. German chemical industry supports the European target to become climate neutral in 2050.

The VCI welcomes the efforts of the EU Commission to create a single market for certificates for carbon removal. The German chemical and pharmaceutical industry also support the target announced in the Commission's Communication "Sustainable Carbon Cycles" that at least 20% of the carbon used in chemical and plastic products should come from sustainable non-fossil sources by 2030.

The German chemical and pharmaceutical industry welcomes the proposal of the European Commission on certifying carbon removals that can accelerate implementation of the Green Deal and European Climate Law. With such measures as carbon farming, the agrochemical industry could provide additional contribution based on its long-standing experience and know-how towards achieving climate neutrality, building a sustainable…

The German Chemical Industry Association (VCI) is committed to bringing products to market that are both safe and have lower burdens on the environment. Therefore, the VCI welcomes as a matter of principle the EU Commissions approach to create more transparency in the business-to-consumer sector. However, we still see a need for improvement to the draft directive in its current form.

The chemical industry contributes to the sustainability and climate goals of the EU with innovative products and processes and has been working successfully for years to avoid possible impacts on the environment and health. We therefore welcome the extension of the ecodesign criteria to include all aspects of the circular economy.

The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the European chemical industry) and employed around 464,000 staff.

Carbon border adjustments (CBA) are the wrong way to support transformation of industry The CBA proposed by the Commission do not help to support the transformation of the industry towards achieving the EU climate goals. The risks and burdens that come with CBAs outweigh by far the opportunities. Moreover, the effectiveness of CBA is questionable.

Genetically modified microorganisms (GMMs) are a key component of modern biotechnology. They can be used both as production organisms in contained systems or as products in their own right. Examples include industrial processes, in agriculture, in the food industry, in environmental biotechnology and the recovery of raw materials.

DIB welcomes the European Commissions proposal for the European Biotech Act I as an important step towards strengthening biotechnology and biomanufacturing as strategic capabilities for Europe. Biotechnology contributes to innovations in healthcare, food and feed innovation, agricultural production, the bioeconomy, industrial manufacturing, resilience and security.

The European Biotech Act represents a vital opportunity to reassert Europes leadership in biotechnology. Its success depends on achieving concrete structural improvements in the EU's regulatory and investment environment, while recognizing and taking into account the transformative shift in biotechnology from a series of specialized, sector-specific applications to a fundamental, cross-sectoral, general-purpose…

Generally The VCI supports the objective of net-zero greenhouse gas emissions. The need to move away from fossil fuels in the electricity sector to a large extent and to compensate for it through the development of renewable energies is a challenge. This can be better addressed by increasing energy efficiency.

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VCI Beitrag zum Inception Impact Assessment der Europäischen Kommission zur Energy Efficiency Directive Allgemein Im Rahmen des Green Deals hat die Europäische Kommission eine Roadmap zur Evaluierung der Energy Efficiency Directive kombiniert mit einem Inception Impact Assessment vorgelegt. Der VCI bedankt sich für die Möglichkeit der Stellungnahme und nimmt im Folgenden Stellung zu der Roadmap.

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

The German chemical industry supports the 2050 target. In addition to reducing greenhouse gas emissions through the EU emissions trading scheme, the sector also actively contributes with its products to climate protection in other sectors. The “Roadmap Chemie 2050” study (https://bit.ly/32Cizl8) shows that greenhouse gas neutral production is possible by 2050.

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VCI consultation contribution to the prospection of a CBAM down-stream extension NOT CBAM REPORT FOR CHEMIE: The Chemical Industry Association (VCI) continues to be critical of the Carbon Border Adjustment Mechanism (CBAM).

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This is a short summary of the key points of the VCI position on the CLP revision. Additional information and detailed assessments of the EU Commission's drafts is available in the attached document. General comments -Amendments in CLP Regulation concern several regulations: The legal consequences of the proposed changes for other chemical regulations, like REACH, biocides or cosmetics regulation, must be considered…

On 4 May 2021, the EU Commission published its Inception Impact Assessment regarding the proposed CLP Revision. This roadmap to be commented on in this context is part of the Chemicals Strategy for Sustainability. The CLP Regulation regulates the classification, labelling and packaging of chemicals and implements the internationally valid Globally Harmonised System (GHS) of the United Nations (UN) in the EU.

On 4 May 2021, the EU Commission published its Inception Impact Assessment regarding the proposed CLP Revision. This roadmap to be commented on in this context is part of the Chemicals Strategy for Sustainability. The CLP Regulation regulates the classification, labelling and packaging of chemicals and implements the internationally valid Globally Harmonised System (GHS) of the United Nations (UN) in the EU.

The European Commission has a unique opportunity to position biotechnology as a strategic enabling technology for Europes future competitiveness, sustainability, and technological sovereignty. While the recently presented Biotech Act I addresses important sector-specific challenges, it does not sufficiently tackle the underlying governance barriers that affect biotechnology across all application domains.

The German Chemical Industry Association (VCI) welcomes this public consultation under the Better Regulation initiative. The proposal for classification and labelling of titanium dioxide is inappropriate from the toxicological and epidemiological perspective. The criteria for classification are not met. Consequently titanium dioxide should not be included in the 14.

VCI opinion on the consultation on the revision of the European Energy Tax Directive (ETD) Basic principles of energy taxation With regard to the changeover of the tax base, the VCI considers it necessary to find a solution for alternative fuels. The analysis of the energy content, in particular for substitute fuels, involves a disproportionate effort and is technically impossible in many cases.

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Basis for EU intervention (legal basis and subsidiarity check): VCI doubts that the proposed change of legal basis will be implemented easily. It seems probable that many lawsuits will follow resulting in a reduction of legal certainty for companies.

The German Association of Biotechnology Industries (DIB) is the biotechnology branch of the Association of the German Chemical Industry (VCI). DIB represents the political-economic interests from small and medium-sized enterprises up to multinationals active in all application fields of biotechnology - from agriculture to industrial and all the way to medical biotechnology.

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and welcomes the European Commissions draft of the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria (TSC).

DIB welcomes the adoption of the EU Regulation on plants obtained by certain New Genomic Techniques (NGTs). The regulation is an important step towards a more differentiated and proportionate European framework for plant breeding and plant innovation. The new framework recognises that NGT plants are not a uniform regulatory category.

DIB welcomes the adoption of the EU Regulation on plants obtained by certain New Genomic Techniques (NGTs). The regulation is an important step towards a more differentiated and proportionate European framework for plant breeding and plant innovation. The new framework recognises that NGT plants are not a uniform regulatory category.

VCI supports the European Commission's initiative to strengthen Europe's innovative capacity. Innovation requires a holistic ecosystem that integrates research, industry, SMEs/Mid-caps, and start-ups. The Innovation Act must remove regulatory barriers, provide planning security, and facilitate investments for all actors.

Stellungnahme des VCI zum Legislativvorschlag des EU Data Act                        Der Verband der Chemischen Industrie (VCI) vertritt die Interessen von rund 1.900 Unternehmen aus der chemisch-pharmazeutischen Industrie und chemienaher Wirtschaftszweige gegenüber Politik, Behörden, anderen Bereichen der Wirtschaft, der Wissenschaft und den Medien.

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

Stand: 01.08.2025 VCI-Stellungnahme Vorschlag der EU-Kommission für ein EU-Klimaziel 2040 Es ist zielführend, dass die Erreichung des EU-Klimaziels 2040 grundsätzlich mit Flexibilitäten ausgestattet werden soll.

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

The proposal for a European Health Data Space (EHDS) promotes the EU-wide exchange of health data, removes access barriers and supports health research, in particular on new prevention strategies, but also for scientific research, on treatments, medicines, medical devices, as well as removing barriers to the cross-border use of digital health services and products to allow building more resilient and sustainable…

VCI welcomes the opportunity to provide feedback on the roadmap published by the Commission on the European Health Data Space (EHDS). The current Covid-19 pandemic particularly highlights the need for such an initiative to efficiently develop vaccines and treatments while monitoring the spread of the virus. The baseline scenario describes adequately the current situation in the EU.

VCI-Stellungnahme Entwurf der Industrieemissionsrichtlinie vom 6. April 2022 VORBEMERKUNG Die Richtlinie 2010/75/EU über Industrieemissionen (IED) ist seit Ende 2010 in Kraft. Die Industrieemissionsrichtlinie definiert den aktuellen Stand der Technik und enthält Anforderungen an Industrieanlagen und deren Genehmigung.

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

The IED and within the BREF process is a commonly accepted and effective instrument to reduce the emissions from major industrial installations. Changes of this system should always be assessed in terms of feasibility, cost effectiveness and manageability. The IED cannot and must not solve all issues raised during the IED Evaluation Workshop in May 2019.

Protection of human rights and sustainable sourcing of raw materials are a high priority for the chemical-pharmaceutical industry in Germany. The EU Regulation 2023/1115 (EU Deforestation Regulation, EUDR) for deforestation-free supply chains could be one possible instrument supporting implementation of high environmental and social standards along the value chain of soy, oil palms, cattle, coffee, cocoa, rubber…

The authorised dimensions and weights of heavy goods vehicles continue to be regulated in very different ways in the Member States of the European Union. These sometimes serious differences create unnecessary restrictions on cross-border transport; this creates distortions of competition between Member States.

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VCI welcomes the opportunity to provide feedback on the Environmental Omnibus initiative. While the EUs Green Deal has reinforced Europes commitment to high environmental and health protection standards, it has also led to a significant expansion of regulatory complexity and administrative burden for industry.

We welcome the further development of the EU Sustainable Finance Agenda and the opportunity to provide feedback on the draft legislative act as proposed by the European Commission. Reliable, comparable and relevant information on companies’ exposure to sustainability risks will enable informed decision-making that fosters investment in economic activities contributing to the socially just and sustainable economic…

We recognise the need to mobilise funding to protect and restore biodiversity. The chemical, pharmaceutical and biotech industries have the greatest interest in having an intact nature as a basis for many economic activities and innovations. This is why we are committed to the protection of biodiversity and the sustainable use of nature.

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In the context of the European Commission’s stakeholder consultation on the Carbon Border Adjustment Mechanism (CBAM) methodology for the final period starting on 1 January 2026, the VCI would like to comment as follows: (1) In order to reduce the red tape for the CBAM declaration, it should be clarified that empty refill containers (e.g.

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The Net Zero Industry Act (NZIA) has good intentions, but it is not a gamechanger for the EU in the competition of locations. Faster, more innovation-friendly this sounds good. But not enough attention is given to industry as such. Regarding net-zero technologies (NZT) only, chemicals are essential to green technologies, e.g. for wind farms, photovoltaics, electric drives or future-oriented bio-based products.

The EU Chemicals Strategy intends large numbers of amendments and extensions of the existing chemicals legislation. These will have major impacts on both the chemical industry and users of chemicals (substances, mixtures and articles).

The current draft illustrates how the EU risks undermining its own industrial competitiveness through increasingly complex and granular regulatory requirements. The Digital Product Passport will become mandatory for a vast majority of products many of which are manufactured largely outside Europe.

The German Chemical Industry Association (VCI) welcomes the Commission's initiative and supports the goal of strengthening EUs research and technology infrastructure (RTI) ecosystem. The challenges identified - fragmented funding landscape, insufficient coordination and limited access - reflect central problems regularly encountered in industrial practice.

VCI Position to the Call for evidence for an impact assessment — Ares(2021)7346796 Below you will find a short summary of the most important key points of the VCI position on the “Call for evidence for an impact assessment” to comply with the required number of characters. Please take note of the detailed VCI position paper, which we have uploaded.

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The VCI advocates a non-disruptive and cost-effective transition of energy markets towards net-zero greenhouse gas emissions in planned stages of development. This requires cost efficiency and sufficient availability of greenhouse gas neutral energy sources at competitive prices. Otherwise, transition in industry cannot succeed; As a result, there is a risk of carbon leakage.

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Überarbeitung des Zollkodex der Union                       www.vci.de www.ihre-chemie.de www.chemiehoch3.de LinkedIn Twitter YouTube Facebook Datenschutzhinweis Compliance-Leitfaden Transparenz   Der VCI und seine Fachverbände vertreten die Interessen von rund 1.900 Unternehmen aus der chemischpharmazeutischen Industrie und chemienaher Wirtschaftszweige gegenüber Politik, Behörden, anderen…

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

- Sustainability criteria should assess recycling technologies on the basis of objectively measurable outcomes, science-based criteria and environmental performance rather than favouring specific recycling pathways. - Mechanical recycling, chemical recycling, solvent-based recycling, biotechnological recycling and other recycling solutions should be regarded as complementary approaches.

VCI - Position PPWR Article 7 (8) Shared Objectives Amid Different Technical Approaches The implementation of Article 7(8) PPWR involves a number of complex technical questions, including chain-of-custody approaches, attribution methodologies, aggregation levels and verification requirements.

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

For the chemical industry, the next steps in implementing the EU Commission's support efforts are crucial, in particular the strengthening of short- to long-term support measures in the pilot and demonstration phases; it is crucial to coordinate policy support measures across DGs of EU COM in order to accelerate approval procedures, remove regulatory barriers to scale-up, and simplify the administration of…

Die Entwicklung und vollständige Umsetzung neuer treibhausgasneutraler Technologien wird noch bis in die 2040er Jahre dauern. Neben der noch unzureichenden Technologiereife und dem hohen Investitionsbedarf in wirtschaftlich herausfordernden Zeiten limitiert vor allem die auf absehbare Zeit unzureichende Verfügbarkeit einer CO2-Infrastruktur sowie erneuerbarer Energie und CO2-neutralen Wasserstoffs zu…

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

In its proposal for new rules on the shipment of waste, published on November 17th, the EU-Commission pursues three main goals, which, in principle, are supported by VCI: - Shipments of waste for preparation for reuse and recycling in the EU are facilitated - The EU does not export its waste challenges to third countries - Illegal shipments of waste are more effectively addressed Especially the measures to…

The Urban Wastewater Treatment Directive (UWWTD) introduces the issue of Extended Producer Responsibility (EPR) into the water policy. The chemical industry in Germany and the VCI have been intensely accompanying this issue for many years under the Trace Substance Strategy of the German federal administration.

In view of the many new reporting requirements resulting from the transformation, streamlining is essential. The chemical and pharmaceutical industry’s proposals are set out in the Annex. The following should also be discussed in advance with stakeholders (e.g.

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Placing on the market and use of biocidal products in the EU are regulated by the Biocidal Products Regulation (EU)No. 528/2012(BPR). Its aim is to improve the functioning of the internal market. At the same time, it aims to ensure a high level of protection for human and animal health and the environment. In accordance with the precautionary principle, particular attention is paid to protecting vulnerable groups.

VCI welcomes the opportunity to contribute to the public consultation on the draft Commission Implementing Regulation establishing EU-wide end-of-waste (EoW) criteria for plastics derived from mechanical and solvent-based recycling.

- The methodology should provide a robust and credible framework for assessing equivalence while remaining practical, internationally operable and supportive of investments in European circular economy solutions.

The German Chemical Industry Association (VCI), in line with BDI, acknowledges the initiative of the European Commission for a more effective promotion of dual-use technologies. VCI appreciates the term research and development involving technologies with dual-use potential. This ensures a clear distinction from the very important term "dual-use research of concern" and the measures associated with it.

Entwurf einer neuen Luftqualitätsrichtlinie      Dipl.-Ing. [name removed] Wissenschaft, Technik und Umwelt Abteilung Umweltschutz, Anlagensicherheit, Verkehr T [phone removed] | E [email removed] Verband der Chemischen Industrie e.V.

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

The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the Europe-an chemical industry) and employed around 464,000 staff. We welcome the consultation of stakeholders about the roadmap for updating the Air Quality Directives.

Basically, VCI and its member companies welcome the establishment of a common data platform to support sound scientific hazard and risk assessments as well as best informed regulatory decisions while respecting efforts, ownership rights and confidential business information of companies.

The VCI supports an independent mandate for the work of the ECHA, its continuation, the planned strengthening of the RAC and SEAC committees, and sustainable financing for the agency. The opportunity should be taken to improve provisions with regard to communication between the Agency and duty holders as well as transparency. Both are key for efficient and effective implementation of sectoral legislation by ECHA.

•VIK and VCI welcome the steps taken by the legislative initiative for the integration of low greenhouse gas pipeline gases into the internal market. •The technology-open approach to taking into account low carbon hydrogen and low carbon fuels favours a rapid market uptake for climate-friendly gaseous fuels and feed stock.

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Concerning substances and mixtures to be used by consumers, the GHS is only used in the European Economic Area (EEA) and very few countries outside the EEA. The Fitness Check of the most relevant chemicals legislation (excluding REACH) found that labels are overloaded with information, especially for consumers.

ESG ratings have become established on the capital market, which make it their business to evaluate the sustainability performance of companies. The ratings often form the basis for investment decisions by sustainability-oriented investors to select suitable securities. In addition, the ESG ratings are used as a basis for compiling company values for sustainability indices.

The VCI expressed its gratitude for the possibility of issuing an opinion on an impact assessment on: “Medicinal products and plant protection products — uniform procedure for the granting of supplementary protection certificates” of 8 March 2022 and comments in the attached document.

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The VCI welcomes the opportunity to take position on the Commission proposal amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy.

The goal of reducing the content of certain POPs in new products, especially those made from recycled materials, can only be supported. In our view, the following points should be taken into account when deriving the limit values for POPs: 1) Not only because of the waste hierarchy, waste incineration should be the preference option compared to landfilling for the disposal of POP containing wastes.

The German Chemical Industry Association (VCI) welcomes an early adoption of clear monitoring and reporting rules for the emissions trading system for buildings, road transport and additional sectors (Chapter IVa / ETS II) to facilitate an orderly implementation and reducing administrative burden by ensuring the maximum possible consistency between monitoring methodologies.

We support the initiative’s objective to improve transparency in rail freight transport. Making the processes in the complex rail system more manageable and optimised by sharing data is an important prerequisite for strengthening rail freight transport. However, sharing of data must not have the effect of influencing competition or endangering security.

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Association of the Chemical Industry (VCI) – Opinion (24 July 2020) Ö 1. Mixing of Critical Infrastructure Protection (CIP) and Essential Services is rejected The CIP Directive 2008/114/EC prioritises terrorist risks. The measures are primarily designed to counter external attacks targeting individual institutions. Essential Services focus on the availability of complex supply chains and services.

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

The VCI represents the politico-economic interests of around 1,700 German chemi-cal companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros and employed around 464,000 staff. Therefore, we welcome the impact assessment.

Opinion on the European Commission’s intended proposal to amend the Directive on asbestos at work (2009/148/EC) We welcome the European Commission’s intended proposal to improve the protection of workers from the risks related to asbestos in the EU and support the proposal of the Employers and Government Interest Group of Working Party Chemicals to set the BOELV at 0.01 F/cm³ (= 10 000 F/m³).

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The VCI represents the politico-economic interests of around 1,700 German chemical companies. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the Europe-an chemical industry) and employed around 464,000 staff. The goals and requirements described in the 8th EAP cannot be realised in isolation from the international community.

The VCI supports the UN Sustainable Development Goal 3, in particular sub-objective 3.5, in the context of this evaluation, as well as the European Commission’s Beating Cancer Plan, which aim to reduce harmful alcohol consumption. Therefore, we are in principle in favour of measures that are suitable for achieving this objective, including by using alcohol taxation as a starting point.

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The German Chemical Industry Association (VCI) rejects the regulatory proposal submitted for consultation on the introduction and application of Average Loss Rates (ALRs) in its current form. From the perspective of industry, the additional insight expected from the regulation is not proportionate to the significant additional administrative burden it would create.

The VCI would like to express its gratitude for the opportunity to comment on the draft revised version of the ALC Regulation as part of the stakeholder consultation. — Article 6(1) has been deleted from the draft regulation.

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VCI strongly supports the implementation of this partnership. However, the Commission should have a differentiated view to innovative SMEs and how to support them. Between fast-growing start-ups and the so-called lagging companies, the majority of innovative SME’s perform with normal growth rates and are at the same time economically successful and create new jobs.

The VCI strongly supports the European Commission’s objective of preventing the use of drug precursors for the illicit manufacture of drugs, while facilitating rules and procedures for legitimate trade. The German chemical-pharmaceutical industry supports the EU’s basic substance legislation and its implementation.

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The German chemical-pharmaceutical industry supports EU legislation on raw materials and its implementation and considers the current legal framework overall appropriate, although there is a need for improvement in detail. Our member companies have been proactively and conscientiously fulfilling their responsibilities since 1991 through a national agreement on voluntary measures.

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VCI, the German Chemical Industry Association, has discussed the White Paper on Export Controls with its members, as the sector we are representing is a global actor with sites all over the world. In brief: VCI welcomes the analysis of the most recent developments and challenges in todays regulatory framework of the European Union.

VCI contribution to the stakeholder consultation on the Commission proposal on the revision of the market stability reserve of 14.07.2021 (COM (2021) 571 final): — The proposal is to extend the tightening of the market stability reserve until the end of 2030, which was actually limited in time until 2023.

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The objective of Regulation (EU) 2019/1148 is to limit the access of members of the general public to explosives precursors. The aim is to prevent criminal actors from acquiring these substances in order to produce explosives and to use them for attacks. The VCI supports the Commission’s objective of countering and minimising the threat of terrorist attacks involving chemicals.

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The VCI supports the Commission’s objective of countering the threat and risk of terrorist attacks involving chemicals. The chemical industry has long been engaged in the peaceful, legal use of chemicals, which are essential for the processes of the industry and its customers. We are firmly opposed to the illegal misuse of chemical substances.

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