MOL Group

MOL Group welcomes the European Commission's efforts to establish a harmonised EU framework for packaging producer registration and reporting, with the aim of reducing administrative burdens on producers. A common reporting structure can significantly improve consistency, transparency, and comparability across Member States.

MOL Group’s key comments on the rules on national registers of producers under Regulation (EU) 2025/40 MOL Group welcomes the European Commission's efforts to establish a harmonised EU framework for packaging producer registration and reporting, with the aim of reducing administrative burdens on producers.

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

MOL Group position on the Industrial Accelerator Act (IAA) MOL Group supports the European Commission’s intention to strengthen Europe’s industrial base through the Industrial Accelerator Act (IAA). Fostering innovation and investment, enhancing the resilience of European value chains, and supporting the competitiveness of strategic industries are probably more important than ever in the current economic and…

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

MOL Group welcomes the initiative and looks forward to the Commissions proposal on the Industrial Decarbonisation Accelerator Act (IDAA) as a potentially important policy to advance the green transition and help preserve the long-term competitiveness of European energy-intensive industries.

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The green transition can only take place if the required industrial and economic changes do not impose disproportionate burden on society.

MOL Group’s position on the Commission proposal for a regulation on packaging and packaging waste MOL Group is committed to helping the EU in reaching its circular economy objectives and is transforming to adapt to a circular and low-carbon world.

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

CONTRIBUTION OF MOL GROUP MOL Group welcomes the objective of the initiative to establish a well-functioning market for secondary raw materials through fully harmonised rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste.

The MOL Group submits this feedback to express some concerns regarding the current proposal for the European Competitiveness Fund (ECF). (1) Centralisation: The proposed consolidation of research and innovation funding into a single mega-fund, coupled with the unification of call conditions, risks aggravating the innovation gap between more advanced and less-developed regions.

MOL Plc. welcomes the opportunity to provide feedback on the European Commissions proposal for the Horizon FP10 Framework Programme and its envisioned implementation. As a leading energy company in the CEE region operating in a strategic and energy-intensive sector, we recognize the critical role that research and innovation will play in ensuring Europes industrial competitiveness, energy security, and climate…

MOL Group’s position on the Commission proposal for a revised Waste Framework Directive MOL Group is committed to helping the EU in reaching its circular economy objectives and is transforming to adapt to a circular and low-carbon world.

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

The EU ETS effectively reduced emissions in its early phases, particularly in the energy sector and in sectors not exposed to carbon leakage. However, MOL Group does not believe the ETS in its current design will be able to further reduce emissions in hard-to-decarbonize sectors in a way that allows these industries to remain competitive at the same time.

MOL Group’s feedback to call for evidence for an impact assessment Clean Corporate Vehicles MOL Group is committed to support the EU to reach its targets in the transport sector and welcomes the Commission’s objective to decrease emissions in the corporate fleet segment.

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

MOL Group has a strong ambition to make improvements in its operation that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. Hence, MOL Group welcomes the European Commission’s proposal for the introduction of a Carbon Border Adjustment Mechanism (CBAM).

MOL Group welcomes the Commissions proposed approach to the removal of exchangeability. By continuing to account for indirect emissions in the calculation of the average GHG emissions of the 10% most efficient installations, as was done in previous allocation periods, the approach avoids the need to extrapolate between datasets that are not comparable, thereby ensuring methodological consistency for the affected…

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030, for which energy efficiency policies and continuous energy efficiency improvements in operations are key.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

MOL Group’s feedback to call for evidence for an impact assessment Renewable energy – legal framework after 2030 MOL welcomes the opportunity to provide feedback on the Commission’s initiative on the renewable energy legal framework for the period after 2030 and to contribute to the reflections shaping the future architecture of transport decarbonisation in the EU.

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

We welcome the direction of the proposed changesespecially the effort to align evidence requirements more closely with existing guidelines, regulations, and permits in the DNSH and TSC criteria. Here are some comments for further consideration. For activity 3.10 (Manufacture of hydrogen): The current Substantial Contribution (SC) criteria do not cover hydrogen uses other than as a fuel.

MOL Group, being amongst the top ten polymer producers in Europe and the biggest in Central Europe, is committed to helping the EU in reaching its circular economy objectives and welcomes the initiative’s aim to modernise EU rules on food contact materials.

MOL GROUP’S POSITION ON THE COMMISSION PROPOSAL ON PLASTIC PELLET LOSSES General comment MOL Group is committed to protecting the environment and to preventing any pollution, as part of our transformation to adapt to a circular and low-carbon world. Plastic pellets are valuable raw materials needed in several end use segments, and pellet losses pose both ecological and economic risks.

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

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model. We welcome the Gas Package aiming to establish rules for the transport, supply and storage of natural gas system and its transition to the system based on renewable and low-carbon gases.

MOL Group welcomes the publication of the Commissions draft methodology for mass balance accounting rules for chemical recycling technologies, and calls for the swift adoption of the implementing act (IA) to secure legal certainty for the industry regarding new investments in chemical recycling.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

MOL Groups position on the harmonisation of rules for calculating and verifying recycled content in plastic packaging (Article 7(8)) MOL Group welcomes the Commissions efforts to establish a harmonised methodology for the calculation and verification of recycled content in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR).

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

MOL Group welcomes the European Commission’s proposal on a revised Waste Shipment Regulation to ensure the safe handling of wastes, to preserve the environment and human health, and to contribute to the transition to a competitive circular economy in the EU.

MOL Group welcomes the call for evidence launched by the European Commission with the aim to rationalise the administrative burden of reporting obligations. We fully recognise the purpose of reporting obligations to monitor compliance with the requirements prescribed by EU, international and national legislations, and to ensure comparability and disclosure of data of public interest.

MOL Group welcomes the European Commission's proposal for the regulation on methane emissions reduction in the energy sector. Monitoring and preventing methane leakage in the energy sector is an important step towards achieving climate neutrality, however, some of the Commission's proposals would place a disproportionate burden on operators and force companies to apply not cost-effective solutions.

MOL Group’s proposal for introducing flexibility to access negative emission credits generated from land use, land-use change, and forestry (LULUCF) project in the European Union’s Emission Trading Systems (industrial ETS and new road transport and building ETS) To stimulate additional, long-term actions in the land use sector to achieve a climate-neutral land sector in 2035 in the European Union, and to help…

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

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model. We welcome the Gas Package aiming to establish rules for the transport, supply and storage of natural gas system and its transition to the system based on renewable and low-carbon gases.

MOL Group’s key comments on the calculation and verification of recycled content in batteries MOL Group welcomes the European Commission's initiative to establish a harmonized methodology for the calculation and verification of recycled content in batteries under the EU Batteries Regulation.

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

MOL Group supports the initiative of strengthening the principle of equal pay between men and women. Gender being one of the four strategic pillars of MOL Group’s Diversity&Inclusion strategy together with age, wellbeing and changed working capacity.

MOL Group’s answers to the public consultation MOL Group welcomes the European Green Deal and its direction to tackle climate change and make Europe the first climate neutral continent and appreciates the possibility to contribute to the IIA of ETS revision concerning aviation.

MOL Group’s draft input to critical infrastructures roadmap consultation: Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach.

MOL Group’s input to critical infrastructures roadmap consultation Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach.

We support the circular economy concept aiming at the use of much more circular products, to identify those products which could be reused, repaired and recycled. It is especially important to extend EU regulation to these products, due to the increasing amount of waste produced in the EU, such as waste tyres. Reuse of tyre rubber as raw material could be a good method to reduce the amount of waste.