German Association of Biotechnology Industries (DIB) within the German Chemical Industry Association - VCI

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.

Filed in German · English published by the European Commission

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.

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 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.

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…

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).

Filed in German · English published by the European Commission

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.

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 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.

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.

Filed in German · English published by the European Commission

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.

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.

Filed in German · English published by the European Commission

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.

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)

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 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.

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.

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.

Filed in German · English published by the European Commission

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.

Filed in German · English published by the European Commission

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.

Filed in German · English published by the European Commission

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.

Filed in German · English published by the European Commission

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.

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.

Filed in German · English published by the European Commission