Ref. Ares(2013)3692635 - 10/12/2013
Ref. Ares(2018)1227256 - 06/03/2018
2013-12-09
European Commission
Mr Jean Luc Demarty , Director-General DG Trade
Mr Heinz Zourek, Director-General DG Taxud
Copy:
Mr Daniel Calleja Crespo, DG Entr
[Art. 4.1(b)]
, DG Entr
Inter-service consultation on industrial policy – access to bio-based raw
materials
Dear Mr Demarty, Mr Zourek,
In the context of the industrial policy currently subject to inter-service consultation, we
are writing to you to request your support in improving access to the bio-based raw
materials we need in order to meet the demand of our partners in the European
industry.
We, producers of bio-based chemicals, see a growing market in the EU for bio-based
products, with demand in particular from the automotive, paint, hygiene, household
articles and packaging sectors, and our companies are committed to further expanding
our activities relating to bio-based chemistry.
We therefore warmly welcome the efforts being made by the Commission within the
framework of the bioeconomy strategy. However, we are at the same time concerned
that policy developments do not take into account the impact of trade and customs
policy on the competitiveness of the European bio-based industry. Measures that are
often mentioned, such as the PCC regime and Free Trade negotiations with the Ukraine,
MERCOSUR and the USA, are either too short term to give the predictability needed for
investments, or too far away in time.
Within the current policy framework, the European bio-based industry is struggling to
compete with fossil-based production, which can import its feedstock duty free, and
with bio-based production outside the EU (e.g. in the US and Brazil), which can source
renewable feedstock at world market prices. This situation of reverse tariff escalation –
where finished products based on renewable raw materials are imported at low or no
duties, whereas the raw materials used in production still incur high import duties –
means the future is too uncertain to invest in production facilities in Europe.
The most important raw material for our industry is bioethanol. The elimination of the
EU import duty on bioethanol destined for the production of chemical intermediates use
(i.e. non-fuel applications), would thus be the most obvious solution for increased
investments.
Electronically signed on 06/03/2018 08:52 (UTC+01) in accordance with article 4.2 (Validity of electronic documents) of Commission Decision 2004/563
