Position papers


Search and download the European Chemical Industry position papers.

Cefic position on the treatment of GHG emissions under the IED

Cefic views on the EU Taxonomy and transition financing

Cefic welcomes European Commission efforts to bring clarity and transparency on environmental sustainability to investors, companies and issuers. The chemical industry strives to continuously improve its production processes, to lower its carbon footprint and to enable further emissions reductions along the various value chains, while pioneering breakthrough and disruptive technologies. The EU Taxonomy must be…

Cefic position paper: Cefic ideas for an updated EU Industrial Strategy

Cefic welcomed the publication, in March 2020, of the EU Industrial Strategy. One year later, we support an update of the strategy to bring it more in line with the objectives of the EU Green Deal and the aftermath of the Covid crisis.

Cefic Position Paper – Methane emissions in the chemical industry

EC request to Cefic: the European Commission’s (EC) energy department (DG ENER) reached out to Cefic in January to get more information on methane emissions in the value chains of the chemical industry. The main idea of Cefic response is to show the EC that methane emissions from refineries and chemical plants represent only a…

Cefic position paper on Chemical Strategy for Sustainability

Cefic supports the public health and environmental goals of the strategy and shares the vision outlined by the European Commission in the Chemicals Strategy for Sustainability.

Cefic Response to the Consultation on the First Taxonomy Delegated Act

Cefic’s views on the interplay between REACH & OSH legislation

Cefic sees OSH and REACH legislations as complementary to each other in the context of workers protection that must be risk-based and supported by a strong engagement of Social Partners in enhanced Social Dialogs. Cefic also recognises the need for clarification on the interface between these two legislative frameworks to avoid overlapping conclusions to help micro and SMEs assessing their risks and taking the appropriate level of protection for their Workers.

Cefic position on 2030 target plans

Cefic position on the Commission proposal to step up Europe’s 2030 climate ambition

Cefic views on EU Strategic Framework on Health and Safety at Work 2021-2027

Cefic supports the revision of the EU Strategic Framework on Health and Safety at Work for 2021-2027 to promote the higher Occupational Safety and Health (OSH) standards in Europe and elsewhere, to focus on better implementation of OSH acquis, and to ensure a science, data and risk-based policy involving Social Partners.

Cefic views on the Commission’s legislative proposal to amend the Aarhus Regulation

Cefic acknowledges the efforts made by the Commission to address concerns raised by the Aarhus Convention Compliance Committee while preserving consistency with the EU Treaty system of legal remedies to ensure judicial review of EU acts – but remains concerned as to the consequences of the proposed legislative changes.

Cefic views on the Revision of lists of pollutants affecting surface and groundwaters

Cefic supports the revision of lists of pollutants affecting surface and groundwaters based on new scientific developments and on a thorough data collection involving a proper consultation of relevant stakeholders.

Cefic views on the EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

Cefic’s contribution to the consultation on a renewed trade policy for a stronger Europe

Implementation of the harmonised Risk Management Framework (RMF) | Cefic position

Safety in handling and transport of all chemicals is at the heart of the Transport and Logistics activities of Cefic’s members. Through the long-lasting Responsible Care programme, the European chemical industry has adopted a sustainable strategy aiming for “zero accidents” in chemicals logistics based on a coordinated continuous improvement approach.

Cefic position on human biomonitoring (HBM)

Cefic response to the Inception Impact Assessment on Taxonomy-related disclosures

Cefic supports the objectives of the European Green Deal and EU ambition to become climate neutral by 2050.1 As a sector “indispensable to Europe’s economy”2 and supplier of many key value chains, climate neutrality requires a deep transformation within limited investment cycles.

Cefic’ s views on the potential Aarhus Regulation revision foreseen to broaden rules on Access to Justice

Following the legislative initiative announced in the Commission Roadmap on ‘better access to justice in environmental matters’, Cefic shares its views on the upcoming proposal to revise the Aarhus regulation which may lead to a privileged access to justice by environmental NGOs.

Circular economy action plan | Cefic answer to the Public consultation for Inception impact assessment regarding the upcoming initiative in the area of Consumer policy – strengthening the role of consumers in the green transition

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new legislative proposal on strengthening the role of consumers in the green transition in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value).

Chemical Strategy for Sustainability | Input Paper on the Chemicals Strategy for Sustainability (CSS)

This paper outlines the preliminary views and proposals of the European chemical industry, as represented by Cefic, on the future Chemicals Strategy for Sustainability proposed by the European Commission under the EU Green Deal. Its content may evolve at the light of future developments. It is organised in two part: 1. an overview outlining the…

Circular economy action plan | Cefic answer to the Public consultation for Inception impact assessment regarding the upcoming initiative in the area of environmental performance of products & businesses – substantiating claims

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new regulatory initiative on substantiating green claims regarding Environmental performance of products & businesses in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value)

Waste Shipments Regulation WSR | Cefic Contribution to Publication Consultation on Waste Shipment Regulation

Waste Shipments Regulation WSR | Explanatory note based on Cefic position paper on Waste Shipment Regulation to support our reply to the public consultation

EU Commission “Strategy for Sustainable and Smart Mobility” roadmap | Cefic feedback

Cefic supports the Green Deal and Europe’s ambition to become climate neutral by 2050. The Green Deal also recognizes the crucial role that the chemical industry plays in Europe’s transition, as a key solution provider to multiple value chains and as a contributor to low emission mobility. The EU chemical industry intends to grasp the opportunities arising from the transition to a climate neutral and circular economy and from low emission distribution solutions.

Cefic statement on the EU Economic Recovery Plan

Ahead of the European Council meeting on 17 July the EU chemical industry calls on the EU member states to urgently agree an EU Recovery Plan to restart Europe’s economy and kick off investments towards a green and digital transition. 

Cefic feedback on EU Commission’s “Stragegy for a Sustainable and Smart Mobility” Roadmap

Cefic supports the Green Deal and Europe’s ambition to become climate neutral by 2050. The Green Deal also recognizes the crucial role that the chemical industry plays in Europe’s transition, as a key solution provider to multiple value chains and as a contributor to low emission mobility. The EU chemical industry intends to grasp the…

Cefic position on Hydrogen

Cefic expects hydrogen to play a pivotal role in reducing the GHG footprint of Europe’s energy and feedstock supply within the transition to climate neutrality.
The future of the European chemical industry will be closely intertwined with the development of a hydrogen economy, as it is both a major producer and consumer of hydrogen.

Cefic position paper on climate policy and carbon leakage

The chemical industry’s initial thoughts on possible EU Border Adjustment Measures –

Cefic position paper on Carbon Border Adjustment Mechanism (CBAM)

Cefic welcomes the Commission’s focus on ensuring industry competitiveness for a climate-friendly transition, namely to become climate-neutral by 2050 while ensuring that European companies can globally compete on a level-playing field.

Cefic-CIA position on the future relationship negotiations between the EU and the UK (Brexit)

Cefic – CIA position on REACH related issues in the future relationship between the EU-27 and the UK (Brexit)

Cefic position on the European Climate Law

Best Available Techniques (BREF) | Cefic position paper Cefic additional remarks and comments to the Art. 13 Forum Workshop on the next BREF review cycle

As suggested by DG ENV in the Art 13 Forum workshop on June 12, 2020, Cefic would like to use the opportunity for a submission of more detailed comments and arguments.

Cefic position paper on Single Wagonload Transport (SWT)

Cefic response to Inception Impact Assessment on the first two Taxonomy Delegated Acts

Waste Shipments Regulation WSR | Cefic view on the revision of Waste Shipments Regulation WSR

Cefic Position Paper on Chemical Recycling

The Green Deal is at the heart of the EU’s ambitions of becoming climate neutral. To meet the ambitious European objectives, much more waste plastic needs to be recycled and a broader range of markets need to be served with plastic products containing recycled content. In this respect Cefic highlights the potential of chemical recycling…

Cefic Position Paper on Circular Economy 2.0

In Cefic’s Mid-Century Vision, the European chemical industry sees itself at the centre of Europe’s circular economy. From the design phase of products to their end-of-life, the chemical industry can offer innovative solutions to the benefit of the sector itself and throughout the value chain, enabling downstream industries to become more circular. By transforming waste…

Circular Economy action plan | Updated submission to the Roadmap for the new Circular Economy

In order to unleash the full potential of innovations the chemical industry can provide to a circular economy, Europe needs a progressive policy environment and smart regulations stimulating innovations.

Cefic Position Paper on Chemical valorisation of CO2

Carbon is an essential element of most products needed by society, and carbon is part of the structure of most chemicals. Recycling carbon from CO2 (and CO from ‘industrial waste gases’) is one of the options that can be considered by the chemical industry to reduce the environmental footprint of chemicals and polymers, develop the…

A Long-Term strategy for Europe’s industrial future – from words to action

This Joint Paper is the outcome of months of discussions and consensus-building between a wide range of industrial sectors, all willing to contribute to the preparation of this much-awaited “comprehensive long-term strategy for Europe’s industrial future”. At a key time where the EU is discussing the next Multiannual Financial Framework, we are ready, more than…

Cefic Position on European Rail Freight and Rail Freight Corridors

Cefic views on WTO modernisation.

The need to provide the list of importers in the IUCLID5 registration dossier of an only representative

Cefic views on the Commission’s proposal establishing a Framework to Facilitate Sustainable Investment

Cefic considers that the “Taxonomy Proposal” may help mobilizing finance towards environmentally beneficial projects and foster cross-border investments by defining a common language for environmentally beneficial investments. This may promote retail and institutional investors’ interest for such investments.

Joint call for an ambitious and comprehensive EU Industrial Strategy to enable industry’s contribution to the EU long-term GHG goals

Cefic position paper on the interface between chemical, product and waste legislation and identification of policy options

Cefic views on the EU Single Market

The Single Market is a major asset for a competitive chemical industry. Cefic encourages EU and Member State authorities to uphold and consolidate the Single Market.

Cefic views on the Stocktaking of the Commission’s Better Regulation approach

Cefic welcomes progress under President Juncker’s Better Regulation Agenda and invites the incoming Commission to follow up on and deepen existing rules and practices.

Cefic Manifesto for a competitive Europe

Why the EU needs an ambitious Industrial Strategy, and what it should contain

Cefic position paper on Combination effects of chemicals

Today, EU chemicals policy and risk management schemes predominantly focus on the safety of individual chemical substances. They protect public health and the environment by ensuring that no chemical substance is intentionally present in the environment at levels that might cause harm.

EU Research & Innovation Framework Programme: The Chemical Industry’s role in EU growth and competitiveness

Cefic welcomes the EC Horizon Europe proposal’s ambition to make Europe an unparalleled global innovation hub and recognition given to the innovative and enabling role of industry, by placing the pillar of the ‘Global Challenges & Industrial Competitiveness’ at the heart of the programme. In this role, industry provides productivity, progress, jobs and prosperity, and…

Joint statement ECHA Cefic to Work on an Effective Implementation of REACH (MOU)

With the completion of the third registration deadline, REACH now regulates all chemicals on the EU market. Recognising that the 2018 Commission General Report on REACH calls on all actors to further improve REACH implementation and, in particular, on industry and ECHA to further improve the safety information and its communication in the supply chain,…

Cefic position paper on Transparency and sustainability of the EU risk assessment model in the food chaine EFSA

REACH Annexes amendments to address nanoforms of substances: Cefic’s perspective

Cefic welcomes the vote of the REACH Committee on REACH Annexes amendments for nanomaterials. The adaptation of the Annexes is a meaningful step to reduce existing legal uncertainties and provide more clarity for the registration of nanomaterials under REACH. The issue remains, however, complex and some of the amendments can even create further confusion.

European Commission Mobility package

Cefic welcomes the European Mobility Package which contains important proposals to improve the social aspects of road transport and to harmonize road charging. The European Commission should continue to challenge internal market fragmentation and counter national measures that unduly hamper free movement of goods. In the past years, industry was confronted with several national regulations…

Cefic, ECEG and industriAll European Trade Union statement on Brexit

The UK’s decision to leave the EU presents a political and economic challenge that creates significant uncertainty for companies and their employees. Cefic, ECEG and industriAll Europe are united in their concern about the adverse impact that Brexit could have on the viability, international competitiveness and employment within Europe’s chemical industry on either side of…

EU Research & Innovation Framework Programme: mission statement

Cefic and CIA joint statement on Brexit and the future

Industry views on Aarhus Compliance Committee Findings on Access to Justice in the EU

Clean energy for all Europeans Package

Europe’s chemical industry welcomes the Clean Energy Package proposal from the European Commission in its ambitions to reform and harmonise energy markets in Europe and to pioneer the low-carbon economy for the benefit of all its citizens.

Clean energy for all Europeans Package – Executive summary

Europe’s chemical industry welcomes the Clean Energy Package proposal from the European Commission in its ambitions to reform and harmonise energy markets in Europe and to pioneer the low-carbon economy for the benefit of all its citizens.

Cefic – EBPF Comments on CA Document CA-April17-Doc.3.1.a & b: Draft criteria for the determination of endocrine-disrupting properties under the BPR

Cefic-EBPF is disappointed that the Commission has retained the term ‘substance’ instead of the term ‘active substance’, despite the legal and procedural arguments made by Industry in December1 2016 and February 20172.

Extension of the scope of the proposed endocrine disruptors criteria from ‘active substances’ to ‘substances’ in the biocidal products regulation (528/2012)

Circular economy

The European chemical industry supports the transition towards a circular economy as part of a strategy to make Europe more resource efficient. This can be achieved both by avoiding unnecessary material and energy losses throughout the life-cycle of products and maximising value by keeping resources circulating in loops.

Cefic views on respiratory sensitisation

Cefic is committed to ensuring that the health of workers and the safety of products are top priorities for the chemical industry. This paper focuses on the management of substances with respiratory sensitising potential.

Cefic views on skin sensitisation

Solutions for a well-functioning, fair and effective EU Emissions Trading System

The European Council Conclusions of October 2014 provided detailed guidance to prevent the risk of carbon leakage after 2020.

Rules of Origin for Chemical Chapters 28 to 40 under Transatlantic Trade and Investment Partnership (TTIP)

Following the UK’s departure from the European Union on 31st January 2020 and the transition period, both sides are now negotiating a future trade relationship. A priority in these negotiations is the conclusion of a trade agreement that will be the core of the future economic relationship.

Rules of Origin for Chemical Chapters 28 to 40 in context of the EU-UK negotiations

The Energy Union: drivers for success

Cefic supports the launch of the Energy Union and welcomes the Commission’s aim to alleviate constraints and enable growth and job creation. Delivering uninterrupted, competitively priced, stable and secure energy to fuel the European economy is a cornerstone to industrial competitiveness. An Energy Union achieving this goal would convince industries to invest in Europe, enabling…

Intermodal transport network development position paper

The European Commission’s transport white paper

European Policy for more sustainable transport and logistics across Europe

Cefic – ECTA joint position

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