Grupa Azoty S.A.

Grupa Azoty is Poland's largest and Europe's leading chemical concern, employing above 14,000 people. It ranks second in the European Union in the production of nitrogenous and compound fertilisers, and has a strong position in markets for products such as melamine, polyamides, oxo alcohols, plasticisers and titanium white.

Thank you for the opportunity to comment. A detailed assessment of the functioning from the point of view of was presented by Grupa Azoty in the questionnaire provided. In this consultation process, we would like to draw your attention to several important elements.

Grupa Azoty supports the introduction of CBAM as it addresses the key gaps in EU ETS system: allowing EU consumption to contribute to increased global emissions, while burdening EU producers with ETS costs. At the same, by failing to incentivize foreign producers to lower their emissions, ETS fails to achieve the key EU objective of lowering global emissions.

As part of the public consultation process, we are submitting the position of Grupa Azoty S.A. regarding the revision of product benchmarks for the years 20262030. We would like to emphasize that the proposed regulation is not adapted to the current economic situation in which the EU industry operates.

Grupa Azoty is one of the leading producers on the European fertilizer and chemical markets. We welcome the opportunity to share our initial views on the planned Amendment of the EU Emissions Trading System - our comments can be found in the attached document.

Warsaw, 20.08.2025 Internal mark: NNR/21/2025 Applies: Response to the European Commission's call for comments: Carbon border adjustment mechanism – extension to downstream goods, additional anti-circumvention measures and legislation for the electricity sector The Grupa Azoty Group [Grupa Azoty] would like to thank you for the opportunity to refer to the important regulatory mechanism - CBAM.

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

We are grateful for the opportunity to submit our position on the proposed changes to the European Climate Law. We would like to emphasize that the greenhouse gas emission reduction targets for 2040 will play a key role in the competitiveness of the EU's energy-intensive industry.

Thanking you for the opportunity to submit comments, Grupa Azoty hereby submits its proposals. Our most important request is to maintain the allocation of free allowances until the effectiveness of the CBAM mechanism has been fully verified in practice.

Grupa Azoty, as a company operating in accordance with the principles of sustainable development and respecting environmental protection aspects, supports all measures aimed at preventing environmental pollution, including the unintentional emission of microplastics into the environment.

Grupa Azoty S.A. welcomes the European Commission's initiative to reduce reporting obligations. Despite representing a group of large entrepreneurs, we are of the opinion that the reporting burdens, in particular in the field of economy, finance and digital policy, on both SME and large entrepreneurs are significant, and it depends on public and private entities to what extent they will be reduced.

Grupa Azoty welcomes the Commission invitation to provide feedback on the proposed update of the Nitrates directive, aimed at allowing the use of RENURE fertilizers above the limit of 170kg N per hectare per year. Below you can find some comments: 1.

Thanking European Commission for the opportunity to contribute to the consultation on Renewable energy - guidance on designating renewables acceleration area, the Azoty Capital Group, which is a leader in the Polish fertiliser market and one of the key capital groups in the fertiliser and chemical industry in Europe, encloses its position on the consultation.

Warszawa, 25 May 2023 Feedback: Electricity market – reform of the EU’s electricity market design 1. Name of the entity submitting comments Grupa Azoty S.A. Editorial unit to which the comment is submitted General remark Current content of provision Proposal for amendment with justification One of the key elements of the European Commission's proposed reform of the internal electricity market is the widespread use…

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

Grupa Azoty is one of the leading producers on the European fertilizer and chemical markets. We welcome the opportunity to share our initial views on the evaluation of Fertilising Products Regulation. Grupa Azoty calls for efforts to improve the international competitiveness of the fertilizer sector, increase regulatory clarity and reduce administrative burdens, as well as increase the possibility of faster…

Grupa Kapitałowa Grupa Azoty as capital group supports the principles of sustainable development, including the idea of circular economy as a tool for building a strong, competitive and independent economy within the European Union.