Meeting with CEFIC CEO delegation
Brussels, 13 January 2021
Chemical strategy for sustainability: enforcement and trade
The Chemicals strategy for sustainability was adopted on 14 October 2020 . The str ategy
presents an ambitious vision and objectives to move towards safe and sustainable
chemicals and a toxic-free environment. It is built on two key pillars:
boosting innovation and competitiveness to make safe and sustainable chemicals the
EU norm and global standard;
moving towards a more preventive legal framework to reduce the impact of hazardous
chemicals on people and the environment.
CEFIC supports the vision and objectives of the chemicals strategy for sustainability, in
particular the intention to strengthen enforcement of EU chemicals legislation, ensure a
level playing field for the industry and support innovation for safe and sustainable
chemicals. However, CEFIC has been critical on the number of legislative proposals
announced in the strategy to strengthen the protection of health and the environment from
the most harmful chemicals. They consider that a better balance should be struck
between simply banning chemicals based on their hazardous properties and enabling the
technology solutions for the future, and that the strategy is not specific enough on how
innovation and the industrial transition will be supported.
CEFIC considers that the strategy lacks connection to the real-world geopolitical context
and that it is a missed opportunity for delivering on the European Green Deal as a gr owth
strategy. Its ultimate fear is that an uncoordinated policy combined with weak enforcement
risks outsourcing the Green Deal technology solutions to other parts of the world.
Main messages
The chemicals strategy sets out an ambitious regulatory agenda. The Commission
wants to reinforce the regulatory framework on chemicals but also to support the EU
chemicals industry and its value chain in this important transition.
A stronger enforcement of EU rules by national inspectors (
‘market surveillance’) is a
key concern for the Commission. The new market surveillance regulation 2019/1020 1 is
expected to be a game-changer. National authorities will have stronger powers to
ensure effective market surveillance of products subject to EU harmonisation
legislation sold offline and online, within their territory. It will enter into force on 16 July
2021.
In addition, we need to step up implementation and enforcement of European
chemicals legislation to ensure compliance as well as a level playing field for the EU
chemicals industry. Currently, almost 30 % of the alerts on dangerous products on the
market involve risks due to chemicals with almost 90 % of those products coming fr om
outside the EU. Imports and online sales are particularly problematic.
The chemicals strategy proposes a number of measures to ensure better controls by
authorities, including by using digital tools. The Commission will, among other things,
propose a new system to audit the enforcement systems of the Member States, tar get
known areas where non-compliance causes high-risk, and make proposals to fur ther
strengthen the principle of
‘no data, no market’.
Commission services are currently discussing how to implement the different actions
on enforcement.
1 Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on
market surveillance and compliance of products and amending Directive 2004/42/EC and
Regulations (EC) No 765/2008 and (EU) No 305/2011
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Meeting with CEFIC CEO delegation
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Defensives
How does the Commission intend to ensure a level playing field for the European
chemicals industry?
First, by better enforcement at our borders to make sure that EU businesses compliant
with EU rules do not suffer disadvantages compared to imports.
Second, by applying the same high environmental and health standards for all articles,
whether they are imported, exported or produced for domestic use. To achieve this, the
Commission intends to, among other things, reform the REACH (Regulation on
Registration, Evaluation, Authorisation and Restriction of Chemicals ) authorisation
system for chemicals. It has proven effective in achieving progressive substitution of
substances of very high concern but at a high cost to EU businesses as it only applies
to uses in the EU.
Third, by providing financial support measures to businesses for example via the Single
Market programme, Member State investments in projects facilitating the green and
digital transition, and the Commission’s financial instruments for research and
development programmes.
How does the Commission reconcile moving towards a more hazard-based system
to regulate chemicals with World Trade Organization-principles, which are risk-
based?
The strategy foresees an increased protection of consumers and vulnerable groups by
not allowing the most hazardous chemicals in consumer products or childcare articles.
This is a generic approach to risk, which recognises that exposure to chemicals in
consumer products cannot be easily controlled and better avoided altogether.
Already today, the EU chemicals legislation is based on both hazard and risk and
consistent with World Trade Organization rules. For instance, we do not allow
chemicals that we know cause cancer or that are toxic for our reproductive system in
consumer products/mixtures. The proposed extension to other critical hazards such as
endocrine disruption to further protect consumers and children is no different.
However, we do not exclude that there will be concerns raised by trading partners in
the World Trade Organization.
What is your view about the proposed ban on export of chemicals and articles t h at
are restricted for use in the EU?
Currently, most EU legislation (including REACH and pesticides) allows manufacturing
of products forbidden for use in the EU on EU territory, for export to other countries.
However, we need to show more coherence and not put the health or the environment
of others, outside the EU, at risk with products that we do not want to use in the EU for
health and environmental concerns.
The chemicals strategy is the occasion to show that we do not only want to strengthen
controls of what we import in the EU, but also make sure that what we export is safe.
This is very much in line with the European Green Deal commitment to lead the way on
health and environmental standards globally.
How do you plan to address implementation, enforcement and compliance issues?
We are already working together with Member States, the European Chemicals
Agency (ECHA) and stakeholders to address key issues with the implementation of the
current legal framework.
Member States are responsible for implementation and enforcement of the EU
legislation. We are supporting the national authorities on enforcement issues, such as
border controls by customs authorities. The Commission is also interested in looking
into how digital technologies could improve enforcement.
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Meeting with CEFIC CEO delegation
Brussels, 13 January 2021
Background
European Green Deal
The European Green Deal includes a zero pollution ambition. The chemicals strategy for
sustainability is the first deliverable. It will be followed by a zero pollution action plan for
water, air and soil in 2021.
Chemicals Strategy for Sustainability
The chemicals strategy aims at better protecting citizens and the environment against
hazardous chemicals, encouraging innovation for the development of safe alternatives
and increasing global competitiveness of the EU chemicals industry.
In order to increase protection of health and the environment, the Commission pr oposes
to ban the most harmful substances from consumer products. Also very persistent
chemicals, such as the group PFAS (perfluoroalkyl chemicals), known as “forever
chemicals” are proposed to be banned. EU laws will be strengthened to ensure that
substances of concern are only allowed if their use is necessary for health, s afety or is
critical for the functioning of society and if there are no acceptable alternatives.
The strategy also aims to boost innovation, promote competitiveness and increase the
EU’s strategic autonomy. It wil promote chemicals, materials and products that are safe
and sustainable by design. It will also promote and support the development of green and
smart technologies and innovative business models to enable the transition towar ds low -
carbon and low environmental impact manufacturing processes in t he chemicals sector.
The strategy wil promote the EU’s resilience of supply of chemicals used in essential
applications for society through EU funding and investment mechanisms. It will establish
and update a research and innovation agenda for chemicals, to fill knowledge gaps on the
impacts of chemicals, and foster multidisciplinary research and digital innovations for
advanced tools, methods and models, also to reduce animal testing.
The EU regulatory framework for hazard and risk assessment and management of
chemicals is comprehensive and complex. A
‘one substance, one assessment’ process
will be introduced to reduce the burden for all actors, enable more consistent and faster
decision-making.
The enforcement of chemicals legislation will be stepped u p by strengthening the
principles of
'no data, no market', carrying out audits in Member States, and setting up
uniform conditions and frequency of checks for certain products. The implementation of
the new market surveillance regulation in 2021 as well as measures to reinforce the EU
Customs Union will strengthen enforcement within the EU and at the external borders.
EU chemicals industry
Chemical manufacturing is the fourth largest industry in the EU and 59% of chemicals
produced are directly supplied to other sectors, including health, construction, automotive,
electronics, textiles.
Global sales of chemicals were EUR 3 347 billion in 2018, and is expected to double by
2030. However, the EU’s global sales share is on the decline. With a forecast of movin g
from second to third position by 2030, being overtaken by the United States while China
remains number one and on the rise.
EU chemicals industry: facts and figures 2018 (Source: CEFIC)
Turnover
EUR 565 billion
Direct jobs
1.2 million
Number of companies 26 600
Capital spending
EUR 21 billion
R&D investment
EUR 10 billion
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Meeting with CEFIC CEO delegation
Brussels, 13 January 2021
Global sales share
16.9%
Chemicals will be a key enabler for the European Green Deal as they are the building
blocks of low-carbon, zero pollution and energy- and resource-efficient technologies,
materials and products. Increased investment and innovative capacity of the chemicals
industry to provide safe and sustainable chemicals will be vital to offer new solutions and
support both the green and the digital transitions.
The new market surveillance regulation
Regulation 2019/1020 on market surveillance and compliance of products updates the
enforcement framework for the 70 EU legislative acts that are included in its Annex. T his
covers essentially all EU legislation with safety, environmental or other public interest
requirements that affect the design and labelling of non -food products.
The new regulation aims to modernise market surveillance by:
preventing non-compliances by providing information to and working with businesses;
providing more effective enforcement tools to address online sales;
improved cooperation, between Member States, between market surveillance and
customs authorities, and through an EU product compliance network.
The Regulation also provides for the designation of EU testing facilities that could receive
funds from the EU budget. These will be public facilities that all market surveillance
authorities can access with the aim to remove obstacles, leading to increased testing. The
Commission is analysing in which sectors there is most need for this.
Most of the Regulation will start to apply on 16 July 2021. However, the EU Product
Compliance Network (including financing) will be operational already in January 2021.
The Single Market programme and market surveillance
One of the objectives of the EU's Single Market programme for the years 2021 to 2027 is
to improve the functioning of the internal market and strengthen the competitiveness of
EU enterprises, including small and medium enterprises.
The programme brings together activities currently financed under six differe nt
programmes with a total budget of EUR 4.2 billion. Funding will be used to support a
stronger focus on market surveillance. The indicative budget is EUR 105 million.
Contacts – briefing contribution: [...] (GROW), tel.: […]
[…] (GROW), tel.: […]
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Meeting with CEFIC CEO delegation
Brussels, 13 January 2021
Chemical strategy for sustainability – Sectoral European Green
Deal for chemicals
CEFIC has called for a sectoral European Green Deal for chemicals to help fulfil the
enabling role of Europe’s chemical industry. It has generally been supporting the
European Green Deal and in particular, the objectives related to a circular economy and
climate neutrality. However, CEFIC has been more critical of the Green Deal’s zero
pollution ambition for a toxic-free environment. Their position is that Europe’s chemical
industry will be key to build the solutions needed for climate neutrality (e.g. for insulation
panels, wind turbines, electric batteries) and that it needs support in order to decarbonise
its own production processes.
Main messages
The chemicals strategy for sustainability calls for a transition to chemicals that are safe
and sustainable by design and across their lifecycle.
This strategy addresses key gaps to innovation and competitiveness in the EU’s
chemicals policy, for example inadequate lack of predictability, insufficient information
on chemicals, lack of funding for innovative solutions and lack of skilled workforce.
The strategy puts in place regulatory and non-regulatory measures to boost innovation
and strengthen the EU legal framework for the tran sition to safe and sustainable
chemicals, including by mobilising funding and investments for research and their
commercialisation and uptake.
Research and innovation funding, such as the Innovation fund, cohesion funds and
recovery instruments will fully support the transition to safe and sustainable chemicals.
In July 2020, the first call for proposals of EUR 1 billion was launched and the chemical
industry submitted many proposals. They are currently being evaluated, and project
proponents will be informed in spring. Also, a special call for small-scale pr ojects with
capital costs between EUR 2.5 and EUR 7.5 million is currently open until 10 March.
We also put in place several measures to strengthen knowledge on chemicals for all
actors, simplify EU’s regulatory processes and establish better controls of the
chemicals and products which enter the EU market, in order to ensure a level playing
field.
The adoption of the strategy is just the beginning of the process. I count on your full
support to implement the strategy and deliver fully its ambition and objectives.
Defensives
We have suggested to broaden the chemical strategy and decarbonisation
strategies into a sectoral green deal for our industry, covering the full
transformation our sector and customers will need to go through in the next
decades. That means, next to further strengthening and simplifying the legal
frameworks a holistic and thorough impact assessment of all affected value chain s
for the Chemicals strategy for sustainability. Challenge is that the Green deal
momentum may require companies / sectors to obtain a collective understanding
on strategic directions and gather relevant data which is not possible or very
difficult under current competition rules. The same questioning occu r f or da t a f or
Chemicals strategy for sustainability impact assessments. How this could be
facilitated? Will there be an overall impact assessment on the sector?
We want to help industry in this massive transformation and support innovative
solutions.
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Meeting with CEFIC CEO delegation
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The Commission is attached to the respect of the Better Regulation principles, and will
assess in detail the possible impacts of relevant legislative proposals announced in the
chemical strategy. We have already been able to rely on extensive evaluations of our
legal framework on chemicals.
We also believe it is important to guarantee coherence and synergies during the
implementation of the Strategy and its various actions. A High Level Roundtable will be
set up, involving key stakeholders.
The Roundtable will help monitor the implementation of the Strategy and make sure
synergies are exploited and coherence is ensured.
In parallel key performance indicators will be developed.
The chemicals strategy for sustainability presents opportunities but also far-
reaching challenges. This is recognised by the provision in the strategy for a h igh -
level round table to advise the Commission. We warmly welcome this idea and
would aim to be an active participant at CEO level. The target start date is Febru ar y
2021. In view of the urgency and importance, can you advise how this r ou n d t ab le
will be set up by the targeted date and how we can help? Will you take a role as well
as we very much depend on a safe competition environment as well?
We very much welcome your support and availability to support the strategy and the
high-level roundtable.
The strategy addresses all aspects of chemicals, from industrial innovation to
protection of the environment and human health. To implement it, we need all
stakeholders to actively participate.
This is why we have announced a high-level roundtable with representatives from
industry, science and the civil society to fine-tune our actions and realise the strategy’s
objectives in dialogue with all actors and stakeholders concerned. We are currently
starting the process to define the participation and the mission of the roundtable, and
we plan to launch a call for participation before end-March 2021.
We hope to be able to have the first meeting at the beginning of spring 2021.
How is the strategy supporting innovation and competitiveness?
This strategy addresses key gaps to innovation and competitiveness in the EU’s
chemicals policy, for example lack of predictability, insufficient information on
chemicals, lack of funding for innovative solutions and lack of skilled workforce.
With the strategy, we first establish a long-term vision which will ensure regulatory
predictability and secure long-term investments, which will enable the EU industry to
reap the first-mover advantage.
Research and innovation funding, such as the Innovation fund, cohesion funds and
recovery instruments will fully support the transition to safe and sustainable chemicals.
We also put in place several measures to strengthen knowledge on chemicals for all
actors, simplify EU’s regulatory processes and establish better controls of the
chemicals and products which enter the EU market, in order to ensure a level playing
field.
Open strategic autonomy
The COVID-19 pandemic has demonstrated that manufacturing and supply chains
have become increasingly complex and globalised. The EU must strengthen its open
strategic autonomy, the resilience of value chains and diversify sustainable sourcing for
those chemicals that are crucial for us.
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Meeting with CEFIC CEO delegation
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Chemicals – even the most hazardous ones – will be key to reach the Green Deal
objectives, how will you guarantee that those can still be used?
The concept of “essential uses” guarantees that there are no obstacles to substances
to be used in applications with an important societal value (e.g. health protection
including protective equipment, or technologies for climate neutrality), but also that we
push towards making use of safer alternatives when those exist.
The purpose of defining criteria for essential uses is not to define gen erally that a
technological product or that the general use of chemicals is essential or not. It is the
use of a chemical in a specific application and the specific feature it p rovides that
defines whether it is essential or not.
The concept is already defined under the Montreal Protocol on Substances that
Deplete the Ozone Layer of 26 August 1987. We will build on that to define it further
and apply it in chemical legislation, starting with REACH. The involvement of
stakeholders and the sharing of expertise will be key.
How does the strategy contribute to climate neutrality?
The strategy promotes, firstly, the production and use of chemicals for application s
which are essential for society, including for climate neutrality and energy/resource
efficiency.
Secondly, as we know that the chemical sector is one of the most energy-intensive
industries, the strategy announces a set of actions and incentives to promote the green
transition of the sector and of its value chain.
Thirdly, as the main objective of the strategy is to push for chemicals which are safe
and sustainable along their life cycle, we will assess how to best introduce information
requirements under REACH on the overall environmental footprint of chemicals,
including on emissions of greenhouse gases.
Contacts – briefing contribution: […] (CLIMA C.3), tel.: […]
[…] (ENV B.2), tel.: […]
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Meeting with CEFIC CEO delegation
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Industry alliances
CEFIC supports the European Hydrogen Alliance Industry roundtable and new Hydr oge n
IPCEI, and Batteries, where they are a member of the European Battery Alliance. They
are engaged in project and consortia to develop batteries, hydrogen pyrolysis, E-cracker s
and several projects on chemical recycling.
Defensives
The Commission is encouraging the creation of Alliances prompting new ways to
collectively develop and innovate. The chemical strategy applies to many more
sectors than ours – all our customers are impacted. Key consumer goods and
automotive companies will be key for example. How best can we safely work
together? Via innovation platforms with value chains? Can you help us with a
framework or is this just DG RTD? We are interested in your expectations on our
lead in hydrogen, batteries and low-carbon industry alliances. Could you share
some views how we can cooperate within the framework of competition policy?
The Commission is currently defining the framework for all the actions related to
innovation and the industrial transition to safe and sustainable chemicals, to ensure
coherence and effectiveness.
We will also update our industrial strategy during the first half of this year, in light of the
effects of the COVID-19 crisis and make sure there are no unnecessary overlapping.
We agree that the transition to safe and sustainable chemicals should be undertaken
not only by the chemicals industry but also by its value chain, and inter -sectorial
cooperation will be key.
Thus, our approach is based on
industrial ecosystems, i.e. taking into account all
players in a value chain, from large to small companies, from training and research
institutions to suppliers.
Industrial
alliances are an important tool. They help look at all value chain steps to
identify technology needs, investment opportunities, or regulatory barriers. Such value
chain cooperation is especially important for the green transition and the circular
economy.
We are aware that the constituency of CEFIC has and is been very involved in different
initiatives (hydrogen, plastics, batteries). This is very important and we look for war d to
continue this cooperation.
Important progress is already being achieved in the scope of the circular plastics
alliance.
Low-carbon alliance
The development of an alliance on low-carbon has been considered to help the energy-
intensive industry ecosystem on its way for the transition towards a climate -neutral and
circular EU economy by 2050.
The energy-intensive industries are discussing the type of instrument would be the
most suitable to promote their need for joint action among the stakeholders in the
energy-intensive industries ecosystem.
Potential coordinated investments in low-carbon industries could also take place via an
IPCEI.
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Meeting with CEFIC CEO delegation
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Hydrogen alliance
As you well know, the European clean hydrogen alliance provides a platform where the
chemicals industry can develop cooperation along the whole hydrogen value chain and
exchange on future plans on hydrogen production and consumption in various
applications.
The alliance will deliver a project pipeline to implement on the 2030 objectives of the
EU Hydrogen Strategy. While all projects need to comply with State aid rules, the
IPCEI projects are subject to individual assessment by the Commission.
Background
Energy-intensive industries
Energy-intensive industries (EIIs), embedded in many strategic value chains, make up
more than half of the energy consumption of the EU industry. EIIs produce goods and
materials that enable reduction of emissions in other sectors of the economy, including
transport, construction and power generation. Given the long investment cycles for these
industries, meeting the 2050 targets requires fast action.
The high-level group on energy-intensive Industries, advising the Commission on policies
relevant to energy-intensive industries since 2015, developed a masterplan with
recommendations to build the policy framework needed to manage this transition while
keeping our industry competitive. The masterplan presents an integrated policy framework
with recommendations to ensure that these industries can contribute to Europe’s 2050
climate-neutrality ambitions. It outlines actions that could provide the right market signals
to attract new investments in Europe, help companies implement cost -effective pathways
towards climate-neutrality and seize new business opportunities in Europe and abroad.
The masterplan also focuses on the need to ensure a just transition and considers the
need to equip workers with new skills and help communities dependent on these
industries to manage the transition.
Low-carbon industries alliance
Its objective is to bring together players in the energy-intensive industries’ ecosystem,
committed to working towards climate-neutrality and circularity by 2050, in order to
facilitate large projects to deploy breakthrough technologies in the EU, help remove
barriers to innovation and improve policy coherence.
Planning of this alliance has started with steel, chemicals and cement, as already
identified in the work of the strategic forum on low-CO2 industries’ strategic value chain.
These sectors already have sectoral roadmaps, potential breakthrough technologies,
close sectoral integration, a relatively small number of production sites (<30 for steel,
around 40 crackers for chemicals and just over 200 for cement), and their products play a
role in most industrial ecosystems. The alliance would be open for other players in the
ecosystem to join (including civil society, trade unions, regions), based on their expression
of interest to foster the al iance’s objectives. The steel, chemicals and cement sectors see
a need for IPCEIs and will involve Member States closely. AT has shown interest to
promote an IPCEI on low-carbon industries, the discussions are still preliminary.
The industry is suggesting that working level arrangements for the alliance would be
managed by them and the Commission would involve other stakeholders through the
high-level group on energy-intensive industries. The lead industries would create or
nominate a legal entity and hire a manager to lead the work. Political leadership fr om the
Commissioner will be essential, possibly through regular steering board meetings with a
core group of CEOs. We understand that Commissioner Gabriel is interested in being
involved in this alliance, given the close link to the Horizon Europe partnerships on clean
steel and on climate-neutral and circular industry.
The industry associations presented their ideas on the Al iance at the HLG Sherpas’
meeting on 3 July to Member States and other stakeholders. The aim has been to finalise
the development work by the end of 2020. However, GROW has signalled to the three
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Meeting with CEFIC CEO delegation
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industrial associations leading the development work, that the process is lacking inclusion
of other stakeholders, is too much focused on IPCEI and further clarity is needed to the
governance of the alliance. On 19 November 2020, the three industry associations
presented an updated plan, but the issues with inclusiveness remain.
In practice,
resetting the development work is necessary. Estimation on the launch of this
alliance will be confirmed at a later stage.
Clean hydrogen alliance
The six thematic roundtables of the European clean hydrogen alliance will elaborate a
project pipeline that delivers on the 2030 objectives of the EU hydrogen strategy and
strengthens the EU dimension and industrial capacities. Some of t hese hydrogen projects
will require public investments from a number of Member States to be viable.
The co-chair of the industry roundtable of the Alliance is SSAB, one of the three
companies that collaborate in the HYBRIT project, which aims to be the fir st steel
company in the world to produce fossil-free steel.
In preparation of large collaborative multi-country projects, several Member States have
launched national calls for expression of interest for a hydrogen Important Project of
Common European Interest (IPCEI).
In December 2020, 22 Member States and Norway signed a manifesto for the
development of a European clean hydrogen value chain, recognising the importance of
promoting cross-border collaboration and of working on large-scale joint investment
projects in order to support the development and deployment of hydr ogen technologies
and systems. Industrial applications of hydrogen are explicitly mentioned in the scope.
Replacing fossil energy (incl. coal) by hydrogen generated with renewable energy enables
significant decarbonisation of the sector.
The first pilot plants using renewable and/or low-carbon hydrogen are currently being set
up will make it possible to refine the processes.
At current price levels, replacing coal with hydrogen would drive up the price of a ton of
steel by about one third. This gap will likely narrow in the coming years, and could
disappear by 2030, if carbon and carbon-emission pricing drive up the cost for fossil
production at the same time as larger markets for low-emission products develops.
The value chain for hydrogen needs to be built at the same time with the steel making
capacities, so that sufficient quantities of renewable and low-carbon hydrogen will be
available at an affordable cost. This requires significant expansion of renewables
capacities and potentially also imports of renewable and low-carbon hydrogen.
Circular Plastics Alliance (CPA) – including chemical recycling
Design for recycling: work plan adopted
22 priority product categories that the CPA commits to make recyclable. A few more
will be added in early 2021.
Product teams (operational, industry experts) for each priority product. 8 product teams
in the packaging sector.
While the achievement of the 10 mil ion tonnes target can only be “proven” in 2025, there
are
essential milestones towards the 10 million tonnes in 2021:
the quantification of the untapped potential in recycling, collection & sorting of
plastic waste (report to publish in early 2021): this is the CPA “roadmap towards the 10
mil ion tonnes”;
the mapping of the investment needs, also due in early 2021;
the update of the pledges / voluntary commitments to use more recycled plastics –
DG GROW intends to assess the progress made in spring 2021.
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Meeting with CEFIC CEO delegation
Brussels, 13 January 2021
A
competition compliance programme has been established so that the CPA is in full
compliance with EU and national rules on competition (approved by DG COMP).
The consensus in the CPA is that
chemical recycling complements mechanical
recycling (e.g. focus on waste that is not suitable for mechanical recycling).
CEFIC leads this part of the work of the CPA.
Chemical recycling will require efforts by the value chains as much as mechan ical
recycling. This is about re-designing the value chains, from product design to collection
and sorting of waste, to integration of the secondary raw materials back into new products
(and finding customers). This is where the CPA plays a strategic role.
Contacts – briefing contribution: […] (GROW), tel[…]
[…] (GROW), tel.: […]
[…] (GROW), tel.: […]
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