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Export and import of hazardous chemicals

Environment

Regulation (EU) No 649/2012 on export and import of hazardous chemicals implements the Rotterdam Convention, which provides certain rules on the international trade in hazardous chemicals. It aims to ensure that unwanted imports are prevented and that information on hazards, risks and safe handling is exchanged when these chemicals are exported. In addition, the Regulation implements the Stockholm Convention on persistent organic pollutants (POPs) as regards the provisions on export. Export of POPs is banned, unless certain exemptions apply. Th

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Public consultation

ID: 14685

Lobbying Activity

26 responses

Trade unions demand EU reform to unblock chemical safety listings

EUROPEAN TRADE UNION CONFEDERATION, 31 Jul 2025

The ETUC calls for a mechanism to stop countries blocking hazardous chemical listings. They demand the EU lead reforms to modernize the current consensus-only listing procedure. This ensures workers in the Global South have the right to know about toxins.
This would improve global worker safety by ensuring risks from chemicals are properly communicated.
Chemical producers and traders would lose the ability to protect profits by blocking regulations.

Consultation response

Greenpeace European Unit, 5 Aug 2025

Greenpeace EU welcomes the draft delegated act amending Regulation (EU) No 649/2012 on the export and import of hazardous chemicals, to the extent that it introduces new harmful chemicals in its scope. However, we would like to emphasise that export notifications, as provided under Regulation…

Friends of the Earth urges ban on EU export of banned pesticides

Friends of the Earth Europe, 31 Jul 2025

The organization demands the European Commission automatically prohibit export of all pesticides banned in the EU for health or environmental reasons by adding them to Annex V of Regulation 649/2012. They call for ending the practice of manufacturing hazardous chemicals like carbendazim and metribuzin for export to countries with weaker protections.
This would prevent EU-based corporations from profiting by manufacturing banned toxic substances for export.
Chemical companies lose profits from manufacturing and exporting banned pesticides to vulnerable countries.

PAN Europe Demands Ban on Exporting EU-Banned Pesticides

Pesticide Action Network Europe, 10 Aug 2025

PAN Europe urges the EU to prohibit exporting pesticides banned within its borders. They demand an end to the double standard of manufacturing toxic chemicals for foreign markets.
This would protect global health and align EU trade with its environmental principles.
Large agrochemical companies would lose revenue from selling hazardous chemicals in foreign markets.

German environmental group demands EU ban exports of hazardous pesticides

Bund für Umwelt und Naturschutz Deutschland e. V., 11 Aug 2025

The organization demands that all pesticides banned in the EU for health or environmental reasons be automatically prohibited from export to third countries. They argue that notifying importing countries is insufficient protection and that the current proposal fails to address the double standard of allowing exports of substances too dangerous for EU use.
This would prevent global environmental injustice and uphold their stated mission of protecting health and environment worldwide.
Chemical manufacturers lose the ability to profit from exporting banned pesticides to countries with weaker regulations.

EFFAT Urges EU to Halt Export of Banned Pesticides

European Federation of Food, Agriculture and Tourism Trade Unions, 6 Aug 2025

EFFAT demands an automatic export ban on all pesticides prohibited within the EU for health or environmental reasons. They argue that simple notification procedures fail to protect global communities and ecosystems from toxic impacts.
Workers would benefit from safer global food systems and preventing toxic residues returning to Europe.
Agrochemical giants would lose lucrative markets for substances currently banned for use on European soil.

ICA Europe warns chemical restrictions threaten strategic copper production

International Copper Association Europe, 11 Aug 2025

The association opposes restricting coal tar pitch, arguing it is essential for smelting operations. They seek specific exemptions to ensure the copper industry remains stable and productive.
Maintaining access would prevent factory shutdowns and reduce reliance on foreign copper imports.

Euroalliages warns chemical import rules threaten strategic metal production

EUROALLIAGES, 11 Aug 2025

Euroalliages requests exemptions for coal tar pitch when used as an intermediate. They propose aligning import decisions with existing chemical safety regulations like REACH.
Maintaining current import permissions preserves the industry's ability to operate electric furnaces.
Strategic industries like defense and renewables face production risks and delays.

Rainforest Alliance Urges Ban on Hazardous Pesticide Exports

Rainforest Alliance, 4 Aug 2025

They urge the Commission to ban exports of pesticides prohibited within the European Union. They demand these substances be automatically added to the list of banned exports. This would end the double standard of sending hazardous chemicals abroad.
This would protect the farming communities and ecosystems the organization serves in over sixty countries.
Agrochemical firms would lose revenue from manufacturing and selling hazardous pesticides to non-EU markets.

Czech Chamber of Commerce warns of rising chemical export bureaucracy

Hospodářská komora České republiky, 4 Aug 2025

Expanding the list of substances results in an increasing administrative burden for enterprises and state administration. This leads to a situation where authorities must explain requirements to non-EU states, causing delays.
Reducing administrative requirements would lower compliance costs and speed up international chemical exports.

Portuguese NGO demands EU ban exports of prohibited pesticides

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 31 Jul 2025

The organization demands that any pesticide banned in the EU for health or environmental reasons be automatically added to the export ban list. They argue the current proposal fails to address the EU's 2020 commitment to stop exporting banned hazardous chemicals.
This would align EU export rules with its domestic health and environmental standards.
Workers and citizens in non-EU countries lose protection from cancer-causing pesticides and environmental pollution.

Consultation response

Ekō, 5 Aug 2025

Any amendments to Regulation (EU) 649/2012 should result in stopping the trade of all hazardous chemicals that have been banned because they have been found too dangerous to be used in Europe. Under the current proposed amendments, this is not the case. Simply requiring prior informed consent for…

KGHM warns against listing coal tar pitch as hazardous

KGHM Polska Miedź Spółka Akcyjna, 11 Aug 2025

KGHM opposes the inclusion of high temperature coal tar pitch in the regulation. They argue it is essential for copper smelting and lacks viable substitutes.
This ensures uninterrupted copper production and avoids higher costs from sourcing alternatives.
EU green energy goals suffer if domestic copper supply for technologies is disrupted.

Consultation response

Child Rights International Network, 7 Aug 2025

As an international childrens rights organisation, the Child Rights International Network (CRIN) would like to emphasize the urgent need for the EU to ban the production and export of hazardous chemicals altogether. While we welcome the draft delegated act amending Regulation (EU) No 649/2012, we…

Graphite industry group opposes listing coal tar pitch as hazardous

European Advanced Carbon and Graphite Materials Association, 8 Aug 2025

The association objects to listing coal tar pitch in the regulation's annexes. They argue it would increase bureaucracy for a material essential to graphite production.
This would prevent unnecessary administrative burdens and safeguard the competitiveness of European graphite production.

Consultation response

Fairtrade Labelling Organizations International e.V., 11 Aug 2025

Fairtrade International welcomes the draft delegated act amending Regulation (EU) No 649/2012 on hazardous chemical exports and imports but stresses that export notifications alone do not adequately protect health and the environment. Exporting chemicals known to be harmfulespecially to countries…

Consultation response

Dreikönigsaktion der Katholischen Jungschar Österreichs, 5 Aug 2025

As a development organisation committed to global justice and with a focus on the rights of children, DKA Austria, the development agency of the Catholic Childrens Movement in Austria, strongly urges the European Commission to fully align EU rules on the export and import of hazardous chemicals…

Consultation response

Pestizid Aktions-Netzwerk e.V., 7 Aug 2025

While PAN Germany values Regulation (EU) No 649/2012 and its contribution to transparency in pesticide trade, and the newest amendments and additions of pesticides and biocides to the lists of chemicals in Annexes I and V to Regulation (EU) No 649/2012, we repeat, that Regula-tion (EU) No 649/2012…

Consultation response

Biom Association, 1 Aug 2025

As a concerned non-governmental organisation from Croatia working in the field of nature protection, we call on the European Commission to take decisive action and end the export of pesticides banned in the EU due to proven risks to human health and the environment. It is deeply unjust that…

Chemical distributors seek SME support and export flexibility

European Association of Chemical Distributors, 5 Aug 2025

The organization requests transitional measures for new substance listings and a clear distinction between pure substances and mixtures. They also advocate for targeted training for smaller firms and a case-by-case approach to export bans.
These requests aim to prevent supply chain disruptions and lower compliance burdens for smaller distributors.
Developing nations might face continued exposure to chemicals banned in the EU under suggested export flexibilities.

Consultation response

European Network of Scientists for Social and Environmental Responsibility, 1 Aug 2025

As a concerned organisation, I am writing to urge the European Commission to fully align EU rules on the export and import of hazardous chemicals with its own health and environmental standards. What we are seeing is an immoral double standard: certain pesticides are banned in the EU because they…

Consultation response

Lipu Odv, 1 Aug 2025

LUnione Europea ha fatto enormi progressi per tutelare i propri cittadini e lambiente dallesposizione a sostanze chimiche pericolose, elevando i propri standard sanitari e ambientali. Nonostante ciò permane un enorme vulnus nella legislazione che permette la produzione e lesportazione degli stessi,…

Polish chemical chamber seeks exemption for strategic copper material

Polska Izba Przemysłu Chemicznego, 11 Aug 2025

PIPC requests an exemption for a coal tar product used in copper smelting. They argue restrictions create burdens that could halt strategic raw material production.
This would help the industry avoid costly administrative delays and production shutdowns.
Environmental groups lose as this allows continued use of restricted chemicals without oversight.

Consultation response

Douglas Products Packaging Company LLC, 11 Aug 2025

We appreciate the opportunity to provide our comments regarding the proposed Commission Delegated Regulation amending and correcting Regulation (EU) No 649/2012 of the European Parliament and of the Council as regards the listing of pesticides and industrial chemicals (the PIC Regulation)…

Consultation response

Związek Pracodawców Polska Miedź (The Polish Copper Employers' Association), 11 Aug 2025

Legnica, 8 sierpnia 2025 r. ZPPM / 14S / VIII / 2025 Komisja Europejska Sekretariat Generalny Komisji Europejskiej Rue de la Loi 200/ Wetstraat 200 B - 1049 Brussels Bruxelles/Brussel/ Bruksela Belgium / Belgia Stanowisko Związku Pracodawców Polska Miedź w sprawie projektu rozporządzenia…

DigitalTrade4.EU calls for digitalizing hazardous chemical trade documents

DigitalTrade4.EU, 7 Aug 2025

The consortium envisions a seamlessly interconnected Europe powered by harmonized standards for digital trade documents. They propose linking permit registries with digital passports to ensure real-time verifiability of chemical data.
Standardized digital processes would reduce administrative costs and speed up cross-border chemical shipping.