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Alzchem Trostberg GmbH

Alzchem

Alzchem ist ein weltweit aktives Spezialchemie-Unternehmen, das in seinen Betätigungsfeldern überwiegend zu den Marktführern gehört.

Lobbying Activity

Meeting with Pietro Fiocchi (Member of the European Parliament)

5 Nov 2025 · Tematiche ambientali

Meeting with Markus Ferber (Member of the European Parliament)

4 Nov 2025 · Reach implementation

Meeting with Christine Singer (Member of the European Parliament)

14 Oct 2025 · Chemikalien

Meeting with Angelika Niebler (Member of the European Parliament)

25 Aug 2025 · Kalkstickstoff-Beschränkungsverfahren

Meeting with Christine Singer (Member of the European Parliament)

14 Apr 2025 · REACH

Meeting with Herbert Dorfmann (Member of the European Parliament)

7 Apr 2025 · Discussion about the work of the Intergroup on Sustainable Livestock

Meeting with Markus Ferber (Member of the European Parliament)

31 Mar 2025 · REACH Implementation

Response to Export and import of hazardous chemicals - review of the list of chemicals subject to international trade rules

16 Aug 2024

We would like to thank you for the opportunity to comment on the planned amendment to the PIC Regulation at an early stage. With regard to the proposed amendment to the classification of cyanamide based on the Implementing Decision (EU) 2023/1097 listed in recital 15, we recommend that it not be included in the current amendment. As an appeal for annulment is currently being heard by the European Court of Justice against the Commission's decision (Case T-536/23), it is possible that the decision will be annulled. A final ruling is not expected until the end of 2024 at the earliest, more likely in 2025. As a new amendment to the PIC Regulation would very likely only take place after a considerable time delay, this would result in considerable expenses and possible damage for us as a manufacturer. As cyanamide is approved and in high demand in many third countries, we believe that a premature change in classification is unnecessary and should therefore only be considered once the legal process has been completed.
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Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export

31 Jul 2023

Please see our feedback in the attached position paper.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

23 Mar 2023

With regard to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022, we would like to comment on various points that are critical from our point of view. Please find our comments in the attached document.
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Meeting with Christine Schneider (Member of the European Parliament)

1 Mar 2023 · Dünger

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

15 Feb 2023 · EU regulation concerning calcium ciananmide and diabetes

Meeting with Maria Noichl (Member of the European Parliament)

13 Jan 2023 · Betriebsratstreffen

Response to Introducing new hazard classes–CLP revision

18 Oct 2022

Alzchem Trostberg GmbH does not support the introduction of the new CLP hazard classes because of the following reasons : - EU CLP should be aligned with the UN GHS process before before implementation not vice versa, this contradicts the approach of the harmonized classification system all members have agreed on. - Adding the new hazard classes to CLP does not lead to further benefit for public health and environment and leads to duplication of regulation: EU REACH already provides mechanisms to regulate all substances that would be covered by adding new hazard classes under CLP. Adverse effects resulting from endocrine disruptors are already covered by existing CLP hazard classes (STOT, CMR) and result in appropriate risk management measures. - The CLP revision is only the first step for implementing the new hazard classes, all further regulations including REACH have to be adopted in regard to new and additional testing methods. No draft on proposed methods is available until now. How can a law be implemented without defining the testing conditions? (e.g. OECD methods, testing requirements per annual volume in REACH Annexes VII to X). - The criteria for the determination both of ED (especially separation between Category 1 and Category 2) and also PBT and PMT are still not clearly defined and experts are questioning the methods currently discussed. A sound scientific base should be available before implementing new regulations. - The criteria for Endocrine disruptors (ED) should reflect the WHO definition with only one category for classification, where the adverse effect in an intact organism is a consequence of an endocrine mode of action. How can a different definition of ED in EFSA and ECHA be handled in practical for chemicals that are both used in food or feed and as building blocks in the chemical industry? - Certain paragraphs and definitions of ED in the draft legal text are vague and open to interpretation undermining legal certainty. Lengthy and complicated guidance development and bottlenecks during the classification process should be avoided. - PMT/vPvM properties: The technical and policy discussions over the past years have confirmed the absence of a reliable and robust methodology that would make it possible to decide whether a substance can qualify as Mobile or very Mobile. For M classification the Commission made clear during the ad-hoc CARACAL meeting (10 October) that other information (e.g. leaching, monitoring) could prevail over the log Koc criteria. The legal text should clarify how the other information listed as information necessary for the assessment together with WoE (modelling, other adsorption/leaching, monitoring data etc.) is to be taken into account to conclude if the substance meets or does not meet the M/vM classification criteria. This draft should be adopted for legal clarity on how and which results from higher tier studies such as leaching would be assessed against Koc. We suggest a clear wording regarding positive and negative results, relevance, quality and consistency. - Classification of mixtures: Introduction of generic concentration limits of 0.1% triggering classification of a mixture for PBT/ PMT and vPvB/vPvM comparable to CMRs properties is not understandable. This leads to classification of almost all substances that are not ready biodegradable either to vPvB or to vPvM, although they are not toxic and are valid also for by-products that can’t be avoided during production. - Long term effects: Restrictions of chemicals or chemical classes that are used as intermediates will result in significant disadvantages in development of new products and will further strengthen the dependency of other countries (e.g. China, India) in all sectors by a general ban of chemicals. Even inevitable by-products could lead to a restriction of products. Is that acceptable after having learned that alliances are fragile and can be broken quickly?
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Response to Fight against counterfeiting

22 Feb 2022

Feedback of Alzchem Trostberg GmbH to the call for evidence, “EU toolbox against counterfeiting” As a producer of speciality chemicals, we welcome any kind of initiative by the European Commission to strengthen the fight against counterfeit goods. However, this initiative should not only focus on protecting brands. Illegal copies and counterfeit products constantly affect the chemicals industry. We strongly suggest extending the scope of this initiative to the broad range of products manufactured in the EU under high social and ecological standards that have to compete with illegal or counterfeit imports. Damage to the economy, public health and the environment is not only caused by counterfeit products but also by imported products that infringe patent rights and circumvent EU regulations. As a producer of speciality chemicals, we have seen our products being counterfeited and challenged by unfair competition. We would like to give an example, which demonstrates the need for a broader scope of this initiative: Pursuant to Regulation (EC) No 1107/2009, Art. 28 ff. every product intended for the use as “A plant protection product shall not be placed on the market or used unless it has been authorized in the Member State concerned in accordance with this Regulation.” The EU has undoubtedly the highest standards in the world for the authorisation and use of plant protection products (PPPs). Therefore, companies require huge investments of time and money to receive the authorisation of an active substance for a PPP. These investments can only pay off if the industry is protected from illegal competition from counterfeit or unregistered PPPs. Otherwise, research and development of new and environmentally friendly PPPs will come to a standstill. Currently, illegally imported and/or counterfeit PPPs have already achieved a considerable market share and this illegal market is growing uninterruptedly. Counterfeit PPPs continue to escape any form of control. These products do not only infringe EU-Regulation 1107/2009 but also do not comply with European quality and safety standards. This is especially concerning since the appearance of genuine and counterfeit products is often very similar and not distinguishable for users. Because of this, these counterfeit products pose a severe threat to public health and the environment. Online platforms are playing an increasingly important role in the importation and distribution of illegal PPPs. Unfortunately, it is not enough only to take action against the sale of non-registered or counterfeit PPPs. It is also necessary to combat trade in the active substances of PPPs. Even if an active substance is authorised in the EU, offering this substance on online platforms to unauthorised companies or to end-users encourages the illegal formulation, distribution and use of unregistered PPPs. This type of trade threatens the health of farmers and the public, endangers the environment and deprives domestic industries of revenue and Member States of taxes. Furthermore, it generates high profits for organised crime. We therefore call on the Commission to extend the scope of its initiative on the trade in counterfeit and/or unregistered PPPs as well as PPP active substances. Operators of online platforms must be forced to stop business that violates EU rules, harms European industry and endangers human health and environment.
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Meeting with Asger Christensen (Member of the European Parliament)

20 Apr 2021 · Methane emission