Verband der Mineralfarbenindustrie e.V.

The Verband der Mineralfarbenindustrie e.V. (VdMi) welcomes the EU Commission's efforts to strengthen the circular economy through the Ecodesign Regulation for Sustainable Products (ESPR), which is part of the 2020 Circular Economy Action Plan, as part of the Green Deal.

Please see our position in the attached document. Our key points: The proposed approach to the classification of multi-constituent substances contradicts the UN GHS and will lead to serious implementation problems. We call for the withdrawal of the introduction of the definition of multi-constituent substances.

Filed in German · English published by the European Commission

VdMi’s input to the inception impact assessment of the Revision of EU legislation on hazard classification, labelling and packaging of chemicals The EU’s CLP Regulation in combination with the REACH Regulation are unique in such a form and extent worldwide.

Verband der Mineralfarbenindustrie e.V. (VdMi) represents the German manufacturers of inorganic and organic pigments, fillers, carbon black, ceramic colours, food colourants, artists’ and school colours, masterbatches, and products for applied photocatalysis. VdMi represents in total 75 companies, about 75 % of the companies are SME’s. The combined annual turnover of the sectors is about 4 billion Euro.

The Industrial Emissions Directive (IED) 2010/75/EU has been in force since the end of 2010, regulating large industrial installations and defining requirements for their permits. It also provides the basis for the "BREF process" in Seville, which resulted in a large number of binding conclusions corresponding to the best available techniques (BAT).

Stand: 06.Mai 2026 Vereinfachung der Umweltregulierung mit Fokus auf der IED Wir begrüßen das Umwelt-Omnibuspaket als einen entscheidenden Schritt, um unnötige und übermäßige Verwaltungslasten wirksam zu reduzieren und entlasten, die Wettbewerbsfähigkeit zu stärken, unnötige Kosten zu begrenzen und einen ausgewogenen umweltrechtlichen Rahmen sicherzustellen.

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)

Please note our detailed opinion, which we have uploaded with this submission. Our key messages are: Measures to avoid accidental releases are well known by producers of plastic granules and have been implemented voluntarily and effectively in recent years. The unintended loss of plastic pellets is not to be equated with the actual release of plastic pellets into the environment.

Filed in German · English published by the European Commission

This initiative is closely linked to the concept of ‘one substance, one assessment’, strived for under the EU Green Deal and its Chemicals Strategy for Sustainability. This concept promises some improvements in substance evaluation but at the same time it also harbours many pitfalls that might cause serious damage to EU’s industry.

VdMi welcomes the opportunity to comment on the initiative to steamline scientific assessment in the EU. As representer of German manufacturers of inorganic (e. g. titanium dioxide, iron oxides), organic and metallic pigments, fillers (e. g.

VdMi basically supports the use of digital labels, as they offer many options for providing the user with important information in a targeted and uncomplicated manner (see also our position paper file). However, some aspects must be taken into account, especially in the area of very small packagings, in order to really achieve a simplification and not just produce additional effort for the manufacturers.

As association, Verband der Mineralfarbenindustrie e. V. represents the German manufacturers of lead-containing ceramic colours and frits, amongst others. Our members are predominantly medium-sized companies and employ many long-serving employees. We can understand the appropriateness to lower the established biological limit of 700 µg lead/L blood, which has been in place for 20 years.