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BASF SE

BASF SE is a leading global chemical company focused on industrial transformation.

Lobbying Activity

BASF Urges EU to Simplify Advanced Materials Regulations

13 Jan 2026
Topic — The European Commission seeks to strengthen capacities and strategic autonomy for advanced materials.
Message — BASF calls for a risk-based regulatory framework and fast-track approvals for new materials. They propose using regulatory sandboxes to accelerate innovation cycles and simplify existing rules.12
Why — Reducing regulatory hurdles would speed up market entry and lower innovation costs for BASF.3
Impact — Environmental and health groups may lose protections if precautionary principles are replaced by risk-based standards.4
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Meeting with Niclas Herbst (Member of the European Parliament, Committee chair)

13 Jan 2026 · Industriepolitischen Weichenstellungen für Europa: Clean Industrial Deal

Meeting with Markus Ferber (Member of the European Parliament)

13 Jan 2026 · Competitiveness in the European industry

Meeting with Christian Ehler (Member of the European Parliament)

13 Jan 2026 · Industriepolitik

Meeting with Oliver Schenk (Member of the European Parliament)

13 Jan 2026 · Chemie- und Pharmasektor in der EU

Meeting with Marion Walsmann (Member of the European Parliament)

13 Jan 2026 · Climate goals in the european industrial policy

Meeting with Raphaël Glucksmann (Member of the European Parliament)

5 Dec 2025 · US tariffs

Meeting with Andi Cristea (Member of the European Parliament)

20 Nov 2025 · Legislative developments in trade policy and the implementation of the EU-US Agreement

Meeting with Martin Hojsík (Member of the European Parliament)

17 Nov 2025 · Pesticides, biocontrol, omnibus

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

14 Nov 2025 · CLP, Cosmetics Regulation, Chemicals omnibus

Meeting with Bruno Tobback (Member of the European Parliament)

14 Nov 2025 · Chemical Omnibus

Meeting with Jutta Paulus (Member of the European Parliament)

14 Nov 2025 · Visit of BASF plant

Meeting with Michael McGrath (Commissioner) and

7 Nov 2025 · Discussion on the challenges faced by EU companies in China.

BASF urges technology-neutral framework for EU Circular Economy Act

6 Nov 2025
Topic — The consultation seeks input on the upcoming Circular Economy Act to enhance competitiveness.
Message — The company advocates for a framework supporting all recycling technologies and a flexible tracking system for alternative feedstocks. They recommend simplifying waste shipment rules for non-hazardous plastics and harmonizing end-of-waste criteria across Europe. Furthermore, they call for realistic targets that reflect the specific needs of different industrial sectors.123
Why — This would lower costs for alternative raw materials and protect European plants from cheap imports.45
Impact — Global exporters may face higher costs due to stricter customs codes and safety requirements.6
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Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and

6 Nov 2025 · Challenges and needs across the value chain for advancing safer and more sustainable chemistry

Meeting with Christine Singer (Member of the European Parliament)

6 Nov 2025 · Pflanzenschutz

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

5 Nov 2025 · Competition policy

Meeting with Andreas Glück (Member of the European Parliament) and Deutsche Industrie- und Handelskammer

28 Oct 2025 · Environment Policy

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis) and European farmers and

28 Oct 2025 · Roundtable on Simplification for Agricultural Innovation

Meeting with Peter Liese (Member of the European Parliament) and Volkswagen Aktiengesellschaft and Hyundai Motor Europe

28 Oct 2025 · Austausch

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

21 Oct 2025 · ELVR

BASF Urges Extension of Biocidal Data Protection Until 2030

14 Oct 2025
Topic — EU simplification proposal affecting data protection rules for biocidal product safety studies.
Message — BASF requests extending data protection for biocidal safety studies until the end of the review programme (31/12/2030), covering all studies generated since 2018 for a maximum duration of 10 years. They argue this extension is urgently needed to ensure fair cost-sharing among market participants and prevent free-riding on their investments in safety studies required by evolving regulatory requirements.123
Why — This would protect their investments of 399 million EUR in safety studies and prevent competitors from accessing their data without compensation.45
Impact — New market entrants and non-EU competitors lose the ability to access safety study data without sharing costs.67
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Meeting with Svenja Hahn (Member of the European Parliament)

9 Oct 2025 · Recent legislative developments in trade policy and the implementation of the EU–US agreement

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

7 Oct 2025 · Exchange on agriculture sectoral challenges and innovative solutions

Meeting with Raphaël Glucksmann (Member of the European Parliament)

3 Oct 2025 · Chemical industry

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

1 Oct 2025 · Simplification

BASF Urges Faster Market Access and Reduced Regulation for Innovation

30 Sept 2025
Topic — New EU framework to strengthen Europe's innovation ecosystem and competitiveness.
Message — BASF requests streamlined permitting for pilot plants, outcome-based rather than prescriptive regulation, and protection of intellectual property rights. They emphasize the need for faster product approvals and reduced bureaucracy, arguing that regulatory complexity hinders innovation more than lack of funding does.123
Why — This would accelerate their product development and reduce compliance costs and documentation burdens.45
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Meeting with Giorgio Gori (Member of the European Parliament) and Federazione Nazionale dell'Industria Chimica italiana

23 Sept 2025 · Upcoming REACH revision

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

16 Sept 2025 · End-Of-Life Vehicles Regulation

Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

BASF urges EU to prioritize competitiveness and infrastructure over 2040 climate ambition

4 Sept 2025
Topic — Amendment to EU Climate Law to include 2040 climate target toward 2050 neutrality.
Message — BASF requests the EU reshape policy to prioritize competitiveness and infrastructure over regulatory targets. They call for a full-blown Net Zero Infrastructure program of power lines and hydrogen pipelines, maintaining free ETS allocation and indirect cost compensation, and keeping chemicals out of CBAM. They want flexibility for companies to choose technologies and an adjustment mechanism for pragmatic regulatory changes.123456
Why — This would reduce compliance costs, protect their export competitiveness, and secure operating licenses beyond 2040.789
Impact — Climate ambition loses as delays and exemptions would slow emissions reductions.10
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BASF warns CBAM extension risks accelerating carbon leakage in chemicals

26 Aug 2025
Topic — Extension of EU carbon border adjustment mechanism to downstream chemical products.
Message — BASF requests the EU refrain from including organic chemistry in CBAM until proven effective across entire value chains. They propose extending EU-ETS free allocation beyond 2030, introducing CBAM CO2 price compensation for downstream products, and developing export protection mechanisms.123
Why — This would maintain their competitiveness against imports and avoid additional compliance costs during decarbonization investments.45
Impact — Climate advocates lose stronger border carbon pricing that would incentivize global emissions reductions.6
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BASF urges flexibility in mass balance rules for recycled plastics

18 Aug 2025
Topic — EU rules for calculating recycled content in single-use plastic bottles.
Message — BASF requests the EU allow all business models to participate in the mass balance approach, limit rules to verifiable certification without excessive bureaucracy, and revise the text before applying it to other legislation. They argue the current draft creates an uneven playing field by excluding established co-processing models.12
Why — This would protect their existing chemical recycling operations and avoid costly facility duplications.34
Impact — Environmental groups lose stricter tracking of recycled content through production chains.5
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BASF urges EU to harmonize agricultural data for digital farming

20 Jul 2025
Topic — The consultation seeks to create a coherent legal framework for data sharing across Europe.
Message — BASF proposes creating a universal vocabulary and machine-readable formats for agricultural data. They request a 'collect once, use multiple times' system to simplify farm reporting. The company also wants better access to public datasets like field boundaries and water bodies.12
Why — Unified standards would help BASF scale its digital farming services and reduce technical barriers.3
Impact — Small-scale pilot programs may lose support as policy shifts toward large-scale systems.4
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Meeting with Valérie Hayer (Member of the European Parliament)

17 Jul 2025 · weed control

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

15 Jul 2025 · Sustainability, including digital farming solutions, carbon farming, nature credits, biocontrol, bioeconomy

Meeting with Elena Donazzan (Member of the European Parliament)

15 Jul 2025 · Confronto sui temi rilevanti per l'industria chimica, in particolare piano d'azione per l'industria chimica e prossima revisione REACH

Meeting with Jutta Paulus (Member of the European Parliament)

12 Jul 2025 · Chemikalienpolitik

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

10 Jul 2025 · Biocide products

BASF demands market-based tools to accelerate industrial decarbonisation

7 Jul 2025
Topic — The EU is consulting on accelerating industrial decarbonisation while supporting competitiveness and productivity.
Message — BASF calls for a flexible mass balance approach to track alternative raw materials across complex supply chains. They also propose market pull mechanisms like end-product levies to make low-carbon production economically viable.12
Why — These measures would lower transition costs and create a financial case for green investments.34
Impact — Final consumers would likely bear the cost of the transition through additional product levies.56
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Meeting with Alexander Bernhuber (Member of the European Parliament, Rapporteur)

1 Jul 2025 · Biologische Pflanzenschutzmittel

BASF Urges EU Recognition of Bio-Attributed Chemicals

23 Jun 2025
Topic — The consultation seeks views on updating the EU's circular and regenerative bioeconomy strategy.
Message — BASF proposes using 'biomass-derived products' to include materials using mass balance accounting. They advocate for a feedstock-agnostic approach treating all sustainable raw materials equally. They urge making the strategy the primary reference for all biomass-related laws.12345
Why — This allows BASF to scale sustainable products using existing infrastructure without costly dedicated facilities.67
Impact — Producers of waste-based feedstocks lose the competitive advantage of policies specifically favoring their materials.8
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Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

18 Jun 2025 · Biocontroles

BASF Urges Extension of ETS Free Allowances Beyond 2030

17 Jun 2025
Topic — EU review of Emissions Trading System and carbon leakage protections.
Message — BASF requests extending ETS lifespan to align with 2050 climate neutrality, maintaining free allocation beyond 2030, and compensating indirect CO₂ costs. They want organic chemistry excluded from CBAM and negative emissions integrated into ETS.1234
Why — This would reduce their CO₂ compliance costs and maintain competitiveness against non-EU producers.56
Impact — Climate advocates lose stronger carbon pricing pressure for industrial decarbonization.78
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Meeting with Giorgio Gori (Member of the European Parliament)

17 Jun 2025 · Upcoming Chemicals Industry package

Meeting with Elisabetta Gualmini (Member of the European Parliament) and UTOPIA LAB S.R.L.

17 Jun 2025 · ITRE committee

BASF urges EU to simplify GMO approvals and biotech rules

11 Jun 2025
Topic — EU legislative proposal to accelerate biotechnology transition from laboratories to the market.
Message — BASF calls for a drastic simplification of the authorization process for GMO cultivation and imports. They advocate for a feedstock-agnostic approach to support all biotech sectors and ensure competitiveness.12
Why — Lowering these regulatory barriers would reduce the substantial time and costs required for market entry.3
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Meeting with Christine Singer (Member of the European Parliament)

11 Jun 2025 · Altfahrzeuge

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

5 Jun 2025 · Challenges and opportunities for the EU chemical industry

Meeting with Carlo Fidanza (Member of the European Parliament)

4 Jun 2025 · Introductory meeting

BASF urges EU data standards to unlock agricultural AI

3 Jun 2025
Topic — The European Commission is seeking feedback on accelerating industrial AI adoption.
Message — BASF calls for a unified data standard and shared naming conventions for crops. They argue public projects must provide machine-readable results to improve AI training.12
Why — Standardized data would improve AI efficiency and reduce BASF's computing and energy costs.3
Impact — Publicly funded research projects must adapt to more rigid digital reporting requirements.4
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Meeting with Pietro Fiocchi (Member of the European Parliament)

3 Jun 2025 · Tematiche ambientali

Meeting with Andrea Wechsler (Member of the European Parliament) and ExxonMobil Petroleum Chemical and Verband der Chemischen Industrie e.V.

2 Jun 2025 · EU Energy and industry policy

Meeting with Kurt Vandenberghe (Director-General Climate Action) and AIR LIQUIDE and Holcim Ltd

2 Jun 2025 · CCS-project Kairos@C

Response to Quantum Strategy of the EU

28 May 2025

BASF fully supports the upcoming EU Quantum Strategy as it represents a significant opportunity to support the development strengthening of a European Quantum ecosystem. The strategy should also pay special attention to user industries, such as the chemical industry, since the adoption of this technology can play a significant role in the sectors innovation and competitiveness. This includes the development of more sustainable production processes, for example, one possible application of quantum computing is the development of new catalysts. These can accelerate desired chemical reactions and play a central role in industrial chemistry, as they can significantly reduce energy consumption in the production of plastics and other products. Therefore, it is crucial to further expand the quantum computing ecosystem in Europe to keep up with this key technology in the future. Particularly: Funding for Research and development: need for increased funding and support for quantum research and development, both on computing capacity, algorithms, software and corresponding applications. Application processes should be simplified. National funding should be aligned with EU funding. Education and training: as technology matures, demand for a skilled workforce will also rise. The EU should propose initiatives to develop a skilled workforce through education and training programs. This should include new degree programs and professorships as well as stronger STEM promotion in early childhood and school education. Infrastructure: development of state-of-the-art quantum research facilities and more available computing capacity. Set suitable standards and norms as they play an important role, including minimizing the risk of dependence on a specific provider. Technology roadmap: to bring together all relevant stakeholders to focus and streamline activities. Industry should play a key role in the process to ensure alignment with market needs and ensure technology transfer from research to practice. The EU Quantum Strategy represents a significant opportunity to support the development of a sound European Quantum ecosystem. Focusing on these key areas will ensure that the EU remains competitive globally.
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Meeting with Gabriele Bischoff (Member of the European Parliament) and Deutscher Gewerkschaftsbund and

21 May 2025 · Austausch mit Gewerkschaftsspitzen aus Rheinland-Pfalz

Meeting with Matthias Jorgensen (Head of Unit Trade)

19 May 2025 · EU-US trade relations

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall), Vita Jukne (Cabinet of Commissioner Jessika Roswall)

15 May 2025 · Discussions on REACH, chemical recycling

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

We welcome the clarifications provided by the DA to introduce targeted and limited technical fixes. At the same time, following the targeted stakeholder consultation by IEEP, an extensive review of Annex I is necessary to avoid serious disruptions in the supply chains, with potential unintended negative effects on the supply of essential goods for the European market. To ensure that EU oleochemicals and surfactants industries remain relevant, it is essential that palm and palm kernel oils' derivatives are included in Annex I (see attachment for APAG/Cesio proposal). Not including the derivatives, will (1) create loopholes (i.e. making it possible to import the same chemistry under a similar HS Code, with one listed under Annex 1 and the other one not. This allows market players to change the HS code and gain a competitive advantage over companies following the EUDR process); (2) allow ways to circumvent the regulation by processing chemical products one step further outside Europe, which would disturb the level playing field for European producers and lead to job losses in Europe; and (3) shift production of oleochemicals and surfactants outside of Europe, leading to importing finished products instead of producing them in Europe. It is imperative that the EU Commission provides a detailed roadmap outlining clear next steps and a timeline for the Annex I review.
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Meeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur)

12 May 2025 · End of life vehicles regulation

Meeting with Andrea Wechsler (Member of the European Parliament)

6 May 2025 · EU Energy and industry policy

Meeting with Jessika Roswall (Commissioner) and

24 Apr 2025 · REACH revision/polymers

Meeting with Stéphane Séjourné (Executive Vice-President) and

24 Apr 2025 · REACH / POLYMERS

Meeting with Jessika Roswall (Commissioner)

23 Apr 2025 · REACH revision, polymers

Meeting with Andreas Glück (Member of the European Parliament) and TOPSOE A/S

10 Apr 2025 · Climate and Energy Policy

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and Neste Oyj

10 Apr 2025 · Biotechnology and biomanufacturing

Meeting with Stefan Köhler (Member of the European Parliament)

27 Mar 2025 · Politischer Austausch

Meeting with Aurelijus Veryga (Member of the European Parliament)

25 Mar 2025 · Sustainable Chemistry and Agricultural Solutions for the Future

Meeting with Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union) and European Chemical Industry Council and Umicore

19 Mar 2025 · Physical meeting - Exchange on Draft Guidance on CAM under the EU-UK TCA

Meeting with Klaus Berend (Director Health and Food Safety)

18 Mar 2025 · Plant protection products and their residues.

BASF backs update of EU plant variety protection rules

14 Mar 2025
Topic — Evaluation of EU legislation providing intellectual property protection for new plant varieties.
Message — BASF supports evaluating the system to ensure alignment with international standards regarding derived varieties and harvested material. They also suggest fine-tuning technical topics like the novelty of parental lines and confidentiality.12
Why — Updated rules would simplify operations and better protect their significant breeding investments.34
Impact — Farmers could face tighter restrictions on their ability to use farm-saved seeds.56
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Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

6 Mar 2025 · importance of circular economy measures

Meeting with Jens Geier (Member of the European Parliament)

5 Mar 2025 · Exchange on the The Competitiveness of the EU Chemical Industry Communication

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Mar 2025 · Clean Industrial Deal and the 2040 Climate goals

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen), Wioletta Dunin-Majewska (Cabinet of Commissioner Dan Jørgensen)

4 Mar 2025 · Chemicals

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)

27 Feb 2025 · Simplification and Implementation of the EU GMO legislation

Meeting with Maroš Šefčovič (Commissioner) and

21 Feb 2025 · High-level meeting with the Automotive industry

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné), Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

19 Feb 2025 · Exchange of views.

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and Schneider Electric and

19 Feb 2025 · Exchange on Housing and Efficient buildings initiatives in Europe

Meeting with Valérie Hayer (Member of the European Parliament)

14 Feb 2025 · biopesticides

Meeting with Svenja Hahn (Member of the European Parliament) and Microsoft Corporation and

14 Feb 2025 · Exchange on upcoming digital EU legislation

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair) and CropLife Europe

13 Feb 2025 · The role of the plant protection industry in promoting affordability, food safety and sustainability in EU agriculture

Meeting with Jessika Roswall (Commissioner) and

10 Feb 2025 · Visit of EU Commissioner Jessika Roswall to BASF Ludwigshafen site

BASF urges harmonized EU rules for battery recycling waste

27 Jan 2025
Topic — The consultation seeks to remove regulatory barriers hampering the cross-border movement of goods.
Message — BASF requests harmonized waste codes for battery materials like black mass. They advocate for fast-track notification procedures for pre-consented recycling facilities.12
Why — Common rules would reduce regulatory uncertainty and lower costs for cross-border battery recycling.3
Impact — Foreign recycling companies would lose access to European battery waste materials.4
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Meeting with Borys Budka (Member of the European Parliament, Committee chair)

22 Jan 2025 · CO2 footprint calculation for EV batteries

Meeting with Mariateresa Vivaldini (Member of the European Parliament) and FERROVIE DELLO STATO ITALIANE S.p.A.

16 Jan 2025 · Meeting conoscitivo

Meeting with Pietro Fiocchi (Member of the European Parliament)

15 Jan 2025 · Problematiche Chimica

Meeting with Fabrice Terrac (Acting Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

15 Jan 2025 · Economic security/trade topics and supply chain resilience

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

9 Jan 2025 · The new European Vision for Agriculture

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

BASF supports the key objectives of the Digital Product Passport in ESPR, particularly those aimed at addressing the shortcomings of the current rules, enhancing the sustainability of products, and contributing to the European economys green and digital transition. This aligns with BASFs new strategy to support customers in their green transformation. Our key messages regarding rules for service providers are: 1/ DPP system providers should be subject to certification since their role is crucial for transparent implementation of the EU Green Deal. 2/ Mandatory usage of decentralized, interoperable, non-proprietary technical standards by DPP system providers mitigates the risk of DPP system provider failure. Please find our more detailed position outlined in the attached file.
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Meeting with Markus Ferber (Member of the European Parliament)

10 Dec 2024 · ‘Clean Industrial Deal’ and priorities for the new legislative term

Meeting with Andrea Wechsler (Member of the European Parliament) and Neste Oyj and

10 Dec 2024 · EU Energy and industry policy

Meeting with Christine Schneider (Member of the European Parliament)

10 Dec 2024 · European Green Deal

Meeting with Alexander Bernhuber (Member of the European Parliament)

10 Dec 2024 · ENVI Prioritäten und Notwendigkeit eines "Clean Industrial Deals"

Meeting with Oliver Schenk (Member of the European Parliament)

10 Dec 2024 · Chemical industry in the EU

Meeting with Peter Liese (Member of the European Parliament)

10 Dec 2024 · Klimapolitik

Meeting with Jens Gieseke (Member of the European Parliament) and ExxonMobil Petroleum Chemical

10 Dec 2024 · Austausch zu EU Politik

Meeting with Peter Liese (Member of the European Parliament) and EUROMETAUX and

4 Dec 2024 · Austausch

Meeting with Stine Bosse (Member of the European Parliament)

21 Nov 2024 · European chemical regulation

Meeting with Kurt Vandenberghe (Director-General Climate Action) and AIR LIQUIDE

8 Nov 2024 · Kairos@C

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and European Chemical Industry Council and

7 Nov 2024 · Ambrosetti Club Europe - Transport and mobility priorities

BASF Urges Simpler Rules to Scale European Hydrogen Economy

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas emission savings from low-carbon fuels.
Message — BASF calls for feasible criteria for low-carbon hydrogen production without "excessively complex or unachievable obstacles." They propose grandfathering projects that reach investment decisions before August 2028 to maintain regulatory stability until 2038. Additionally, they advocate for a "technologically neutral approach" that harmonizes requirements for domestic and imported fuels.123
Why — Grandfathering existing infrastructure and simplifying certification would protect BASF's current investments and reduce compliance costs.45
Impact — Environmental groups may lose if lower emission surcharges allow fuels with higher methane leakage to qualify.6
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Meeting with Stefan Köhler (Member of the European Parliament) and Bayer AG and AnimalhealthEurope

23 Oct 2024 · Politischer Austausch

Meeting with Angelika Winzig (Member of the European Parliament)

23 Oct 2024 · Meeting with a representative of BASF

BASF Urges Balanced Battery Recycling Rules and LFP Grace Period

18 Oct 2024
Topic — The EU is establishing methods to calculate battery recycling and material recovery rates.
Message — BASF requests a temporary exemption for recycling certain battery types while industry builds capacity. They also want mandatory recovery of phosphorus and a broader definition for recycling intermediates that includes factory waste.123
Why — A grace period would help BASF avoid immediate high costs for underdeveloped recycling paths.4
Impact — Environmental groups lose as more battery materials could end up in landfills during exemptions.5
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Meeting with Yannis Maniatis (Member of the European Parliament) and WindEurope

17 Oct 2024 · Introductory Meeting

Meeting with Kristian Vigenin (Member of the European Parliament)

17 Oct 2024 · Upcoming legislation

Meeting with Aura Salla (Member of the European Parliament)

16 Oct 2024 · EU competitiveness

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Oct 2024 · EU-China relations

Meeting with Andrea Wechsler (Member of the European Parliament) and E.ON SE and

1 Oct 2024 · EU Energy and Industry Policy

Meeting with Nelly Bruno (Cabinet of Commissioner Iliana Ivanova) and DSM-Firmenich and International Fragrance Association

30 Sept 2024 · DISCUSSION ON REASEARCH AND INNOVATION IN FRAGRNACE INDUSTRY

Meeting with Brando Benifei (Member of the European Parliament)

25 Sept 2024 · Italian activities of the company, the sectors of excellence of Made in Italy: design, packaging, plastic recycling systems and automotive.

Meeting with Giorgio Gori (Member of the European Parliament) and The Food and Beverage Carton Alliance and European Electronic Component Manufacturers' Association

25 Sept 2024 · Presentation of priorities

Meeting with Daniele Polato (Member of the European Parliament)

25 Sept 2024 · Chemicals, chemistry, R&D, green transition, employment

Meeting with Irene Tinagli (Member of the European Parliament)

25 Sept 2024 · Introductory meeting

Meeting with Laura Ballarín Cereza (Member of the European Parliament)

23 Sept 2024 · Industrial Policy, Green Deal, Competitiveness Agenda

Meeting with Christine Singer (Member of the European Parliament) and CropLife Europe and European Anglers Alliance

18 Sept 2024 · Austausch neue Legislaturperiode

Meeting with Marion Walsmann (Member of the European Parliament)

11 Sept 2024 · Wettbewerbsfähigkeit europäischer Unternehmen der Chemieindustrie

Meeting with Angelika Niebler (Member of the European Parliament) and ENGIE and EnBW Energie Baden-Württemberg AG

10 Sept 2024 · EU Energy Policy

Meeting with Andrea Wechsler (Member of the European Parliament) and ENGIE and

10 Sept 2024 · EU Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and ENGIE and EnBW Energie Baden-Württemberg AG

10 Sept 2024 · Low-carbon hydrogen

Meeting with Kris Van Dijck (Member of the European Parliament)

27 Aug 2024 · EU industrial deal - EU regulatory burden - cost of energy

Meeting with Andrea Wechsler (Member of the European Parliament)

24 Jul 2024 · EU Energy and Industry Policy

Meeting with Christine Singer (Member of the European Parliament)

17 Jul 2024 · Austausch zur neuen Legislaturperiode

Meeting with Jens Geier (Member of the European Parliament)

17 Jul 2024 · Exchange on Expectations on the new European Parliament and EU Commission (EU Industry Policy, Global Trade, Green Deal, Energy Policy)

Meeting with Hildegard Bentele (Member of the European Parliament) and thyssenkrupp Steel Europe AG

16 Jul 2024 · EU Industry Policy

Meeting with César Luena (Member of the European Parliament)

16 Jul 2024 · Chemicals, Packaging, Batteries

BASF urges EU to recognize carbon capture utilization in emissions trading

15 Jul 2024
Topic — EU rules on when captured CO2 in products counts toward emissions reductions.
Message — BASF requests that the EU recognize the climate benefits of carbon capture and utilization for both short- and long-lived products. They argue the current system creates regulatory barriers and risks double counting when waste incineration enters the emissions trading system.123
Why — This would allow them to count captured carbon as emissions reductions across their product portfolio.45
Impact — Climate integrity suffers if short-lived products claim permanent carbon removal despite releasing CO2 at end-of-life.6
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Meeting with Christian Ehler (Member of the European Parliament) and Verband der Chemischen Industrie e.V.

9 Jul 2024 · Industrial policy

BASF demands alignment with global standards for battery footprinting

28 May 2024
Topic — This consultation defines the methodology for calculating carbon footprints of electric vehicle batteries.
Message — BASF calls for harmonizing the methodology with international standards to ensure consistency. They want specific electricity emission factors from power purchase agreements instead of national grid averages. Additionally, they propose relaxing the data cut-off threshold to 3% to reduce excessive effort.123
Why — This alignment would lower administrative burdens and protect the value of their renewable energy investments.45
Impact — High-carbon regions lose industrial investment as production shifts to states with greener energy mixes.6
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Meeting with Maroš Šefčovič (Executive Vice-President) and ExxonMobil Petroleum Chemical and

21 Apr 2024 · Exchange of views on the Global Plastics Treaty

Meeting with Markus Ferber (Member of the European Parliament)

17 Apr 2024 · European Green Deal

Meeting with Christian Ehler (Member of the European Parliament) and European Chemical Industry Council

15 Apr 2024 · Industrial policy

Response to Aligning the biodegradability criteria for polymers in EU fertiliisng products to the REACH restriciton on microplastics

5 Apr 2024

The European Commission looking at the environmental biodegradability criteria for polymers is an important and welcomed step in acknowledging this technology for certain solutions, particularly when they are agricultural. Certified soil-biodegradable mulch films can contribute to sustainably producing food and keeping agricultural soil healthy and productive for a longer time. Within the proposal we welcome that mulch films will be tested in the form of a micronized powder. This is common practice to prove the biodegradability of compostable and soil-biodegradable materials and is part of existing standards. Testing in powdered form ensures better reproducibility of the results as well as practical feasibility. Mulch films are typically produced with micrometric thickness. A requirement to test the final product (film) would lead to experimental issues most importantly and, among others, an impossibility to incorporate films with a large area into the soil while ensuring contact with the inoculum, an interference with the stirrer used for agitation of the liquid inoculum, a negative impact on the oxygen penetration due to the physical barrier created by the film, and a low reproducibility between replicates leading to invalid test results. Moreover, correlation between the disintegration under real-life conditions and biodegradation in closed bottle has been investigated in projects such as OPEN BIO or published in the literature, and the testing of the powdered item has proven to be predictive for the determination of the biodegradability of a material. Additionally, on the ecotoxicity with regards to earthworms, the text laid out is also correct in its form aligning to existing standards describing the biodegradation process in soils. The only inconsistency to underline is where the European Commission explains the biodegradation processes in aqueous environments in Recital 6 of the Delegated Regulation amending Regulation (EU) 2019/1009 of the European Parliament and of the Council as regards the inclusion of mulch films in Component Material Category 9. Here, the Commission rightly notes that it there is an assumption that the "... biodegradation process will continue after the 12-month testing period and will reach the 90 % within 24 months after the functionality period" however, it is not reflected in the draft legal text. It is extremely important to acknowledge this equally in the legal text to ensure consistency in interpretation, as well as allowing for continuously improving and updating testing methods to generate valid results fulfilling the requirements. Hence, for point 2. (b) of the Annex 2 we propose to adjust the inconsistency by including an alternative with the following language, which refers back to the 90% as well as the functionality period ensuring that biodegradability in the secondary (aqueous) environment is on a level playing field with that of a primary (soil) environment: (b) in compartment 2, i. ultimate degradation of at least 30 % relative to the degradation of the reference material in 12 months OR ii. degradation of at least 90 % relative to the degradation of the reference material in 24 months plus functionality period.
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Meeting with René Repasi (Member of the European Parliament)

15 Mar 2024 · EU-Speed-Dating zur Information der Mitarbeiterschaft

Meeting with Michael Bloss (Member of the European Parliament)

15 Mar 2024 · Competitiveness of the European Industry

BASF calls for qualitative criteria in offshore wind auctions

1 Mar 2024
Topic — The initiative provides guidance on design elements for national renewable energy auctions.
Message — BASF advocates for market-based mechanisms and qualitative tender criteria, such as industrial power purchase agreements and carbon reduction potential. They oppose certain government-backed subsidy schemes that prevent industrial companies from directly accessing renewable power projects.123
Why — Qualitative criteria prioritize industrial off-takers, ensuring BASF secures long-term renewable energy at competitive prices.45
Impact — National governments lose immediate auction revenue by capping financial bids and prioritizing qualitative factors.67
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Meeting with Terry Reintke (Member of the European Parliament)

1 Mar 2024 · Industrial policies, Energy transition, Sustainability, Ecological transformation

Meeting with Nicola Danti (Member of the European Parliament)

19 Feb 2024 · Meeting introduttivo

Meeting with Danilo Oscar Lancini (Member of the European Parliament)

14 Feb 2024 · exchange of views

Meeting with Franc Bogovič (Member of the European Parliament)

12 Feb 2024 · Meeting on energy topics

Meeting with Peter Liese (Member of the European Parliament)

9 Feb 2024 · Austausch ETS, CCU, CBAM

Meeting with Jens Geier (Member of the European Parliament)

1 Feb 2024 · Competitiveness chemical industry in Europe

Meeting with Anne Sander (Member of the European Parliament)

10 Jan 2024 · NGTs

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

9 Jan 2024 · general company introduction biotech activities, new genomic techniques

Response to Revision of the plant and forest reproductive material legislation

6 Dec 2023

BASFs View on the Commission Proposal for Regulation of Plant Reproductive Material (PRM) BASF supports the Commission proposal as it maintains the EU's established legal framework for variety registration and seed marketing which has been successful in facilitating the development and market release of improved varieties. This ensures a reliable supply of high-quality seeds for farmers and growers while remaining aligned with international conventions and standards. BASF supports the modernization of processes by involving the sector in specific tasks under official supervision, aiming to achieve cost savings for both private entities and official institutions. BASF believes that all PRM must fall under the legislation with minimum requirements for clear identification and marketing of healthy seeds (free of weeds, pests and diseases) This includes alternative materials like conservation varieties, heterogeneous material, and amateur varieties. Clear identification and marketing guidelines are necessary to ensure that seeds of these materials are healthy and accurately labeled and marketed. BASF appreciates the Commission's differentiated legislative approach, considering the unique requirements of different species and market segments. However, we believe that certain provisions within the legislation require more flexibility for local authorities to adapt to the needs of market segments (e.g. uses allowed for pre-authorization trials of vegetable seed). BASF reaffirms the role of plant breeding and innovative varieties in contributing to all aspects of sustainability. While the current VCU testing system for agricultural species is suitable, extending it to highly differentiated segments of vegetable varieties may be challenging and costly for both private operators and official authorities. Implementing such system may lead to a significant reduction in the number of available varieties for European growers and add additional costs along the value chain. Therefore, the practical development of the respective protocols and the criteria eligible for Value for Sustainable Cultivation and Use (VSCU) will be decisive. Herbicide-Tolerant Varieties are an essential tool for weed management. BASF encourages the Commission to build upon existing on-farm efforts to prevent the emergence of resistant weeds by incorporating the stewardship recommendations provided by developers. By recognizing and incorporating these efforts into the regulatory framework, responsible use of herbicide-tolerant varieties and sustainable management of weeds will be incentivized. It is important to note that at the time of application for variety registration, there is no cultivation yet, so only a plan setting out the conditions can be submitted. BASF has concerns about Article 47.1 g, which allows Member States to independently decide the usefulness of specific traits and establish cultivation conditions for varieties with those traits. This provision creates uncertainty for breeders who invest long-term resources in developing new varieties. At a minimum these provisions if further actioned by a Members State should be based on the latest scientific and technical knowledge or be proportionate to the objective being pursued.
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Meeting with Christian Ehler (Member of the European Parliament) and European Chemical Industry Council and Verband der Chemischen Industrie e.V.

29 Nov 2023 · REACH, NZIA

Meeting with Danilo Oscar Lancini (Member of the European Parliament)

29 Nov 2023 · Meeting

Meeting with Maria Angela Danzì (Member of the European Parliament)

28 Nov 2023 · Packaging

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

27 Nov 2023 · Physical meeting - Discussion on CBAM

BASF Calls for EU to Slash Redundant Industrial Reporting Tasks

23 Nov 2023
Topic — European Commission initiative to reduce administrative reporting burdens for companies by 25%.
Message — BASF calls for eliminating duplicate dossiers for chemical approvals and abolishing Intrastat trade reporting. They also suggest limiting the data required for the new Digital Product Passport.123
Why — BASF would save millions of euros by eliminating redundant documentation and streamlining digital submissions.45
Impact — Statistical agencies and market watchdogs lose detailed data on cross-border trade and product compositions.6
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Meeting with Francesca Peppucci (Member of the European Parliament, Shadow rapporteur)

9 Nov 2023 · COM(2023)217 - Proposal for a regulation of the European Parliament and of the Council on detergents and surfactants, amending Regulation (EU) 2019/1020 and repealing Regulation (EC) No 648/2004

BASF Demands Fewer Restrictions on New Genomic Plant Products

2 Nov 2023
Topic — The EU is proposing a legal framework for plants developed through new genomic techniques.
Message — BASF requests fewer limits on genetic changes and opposes mandatory seed bag labeling. They argue organic farmers should access innovations to prevent increased supply chain costs.123
Why — These changes would reduce operational costs and protect BASF's competitiveness against international trade rivals.45
Impact — Consumers lose transparency if labeling is removed, and organic purists lose NGT-free standards.6
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BASF calls for flexible soil health rules for farmers

31 Oct 2023
Topic — The EU is proposing new laws to monitor and restore soil health.
Message — BASF proposes creating a specific agricultural productive land category and using a gradual health score rather than a binary classification. They also advocate for a voluntary toolbox of best practices instead of mandatory requirements.12
Why — These changes would protect agricultural productivity and prevent land from being unfairly labeled unhealthy.3
Impact — Environmental protection efforts could be weakened if mandatory restoration standards are replaced by voluntary guidelines.4
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur) and European farmers and

26 Oct 2023 · Table ronde avec les représentants de l'industrie sur la proposition de règlement sur les nouveaux OGM

Meeting with Norbert Lins (Member of the European Parliament)

17 Oct 2023 · NGTs

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

5 Oct 2023 · REACH, Geothermal INI, CLP

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

3 Oct 2023 · Exchange on the gas market directive

Meeting with Jordi Solé (Member of the European Parliament)

29 Sept 2023 · Future of the chemical industry in Catalonia and the EU within the framework of the Green Deal and Europe's industrial strategy

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur)

20 Sept 2023 · Green Claims

Response to Revision of EU rules on textile labelling

18 Sept 2023

The European Commission strives for scaling fiber-to-fiber recycling to tackle the increasing amount of textile waste in Europe. Hence, we propose to oblige textiles producers to explicitly declare the recycled content derived from post-consumer garment waste. This would significantly increase transparency and enable consumers to make informed buying decision. Furthermore, declaring the post-consumer fiber-to-fiber recycled content, which can be considered as the gold standard in textile recycling, provides a potential differentiation potential for brands. Additionally, we urge the European Commission to enforce unambiguous declarations of materials used in textiles specifying the exact chemical nature of polymer / fiber used. Today, various polyamide types (mainly polyamide 6 and polyamide 6.6) are used in garments, but often just labeled as polyamide or Nylon without specifying the exact type. This is a sever hurdle for fiber-specific sorting which is a prerequisite for fiber-to-fiber recycling.
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

14 Sept 2023 · Exchange on hydrogen production and EU industry policy

BASF urges EU to remove CO2 double-pricing for chemicals

31 Aug 2023
Topic — The EU is assessing measures to optimize carbon capture and storage technology deployment.
Message — BASF requests the removal of regulatory barriers like double CO2 pricing in the emissions trading system. They recommend implementing Carbon Contracts for Difference and building infrastructure for carbon transport and storage.12
Why — This would reduce compliance costs and ensure the company remains competitive during its transition.34
Impact — Waste management facilities would face higher costs if CO2 pricing moves to incineration.56
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Meeting with Jens Geier (Member of the European Parliament)

31 Aug 2023 · Exchange on STEP (staff level)

BASF Urges Scale-up and System Integration for Hydrogen Valleys

30 Aug 2023
Topic — Strategic priorities to double Hydrogen Valleys and reach renewable hydrogen targets.
Message — BASF prioritizes scaling up technologies like electrolysers while emphasizing a system-wide approach for funding and infrastructure. They advocate for leaner requirements and simpler application processes for these programs.123
Why — Streamlined funding and regional integration would enhance BASF's industrial competitiveness and operational efficiency.45
Impact — Producers of specific hydrogen colors lose out to a technology-neutral carbon footprint approach.6
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and ENGIE and

29 Aug 2023 · Energy transition and security

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and

26 Jul 2023 · Sustainable Finance European Sustainability Reporting Standards & EU Taxonomy

BASF seeks longer transition and hazardous substance exemptions

21 Jul 2023
Topic — The initiative requires companies to substantiate environmental claims using specific Product and Organisation Footprint methods.
Message — BASF requests extending the transition period to at least 30 months. They want environmental claims allowed for products containing hazardous substances. The company suggests using international standards and the mass balance approach.123
Why — This ensures BASF can market complex chemicals as sustainable without facing immediate verification delays.45
Impact — Environmental groups lose stricter European-specific methods designed to reduce corporate greenwashing.6
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BASF Warns ESRS Reporting Burdens Threaten European Competitiveness

6 Jul 2023
Topic — This consultation concerns the first set of European Sustainability Reporting Standards for companies.
Message — BASF seeks to remove requirements for reporting gross climate risks and quantitative social metrics. They propose qualitative descriptions to avoid disclosing sensitive production data to competitors.123
Why — These changes would protect proprietary business information and reduce significant regulatory compliance costs.45
Impact — Transparency advocates and regulators lose access to granular data on global pollution impacts.67
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Response to European Critical Raw Materials Act

30 Jun 2023

BASF welcomes the publication of the Critical Raw Materials Act (CRMA) as it introduces a necessary set of measures to secure the sustainable implementation of the Twin Transition, as well as the resilience of many European frontrunning industries, including the chemical industry. We support in particular the ambitious 2030 production goals proposed in the Act, as well as the bold schemes for accelerating project permitting, the introduction of an EU-level framework to monitor critical materials value chains, and the ESG provisions. At BASF, we are committed to strengthen our supply chains and recycling processes of key raw materials. We aim at processing 250,000 metric tons of recycled and waste-based raw materials annually by 2025, and we are particularly addressing battery recycling as an additional growth market, so as to ensure that valuable metals remain in the production cycle for as long as possible. At our Schwarzheide site in Germany, for instance, where a cathode active materials plant is already under construction, we have recently launched a new prototype plant for battery recycling so as to significantly increase recovery rates of lithium, nickel, cobalt, and manganese from end-of-life lithium-ion batteries.
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Meeting with Thierry Breton (Commissioner) and

26 Jun 2023 · Overview of chemicals industry situation, transition pathway for chemicals industry, REACH revision

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski) and Polskie Stowarzyszenie Ochrony Roślin

23 Jun 2023 · Current legislative initiatives: Sustainable Use Directive and Farm to Fork; New Geonomic Techniques; Chemical Strategy for Sustainability and its impact on the food sector and agriculture

Meeting with Petar Vitanov (Member of the European Parliament)

31 May 2023 · Plant Protection Industry Bulgaria

Meeting with Andreas Glück (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG

24 May 2023 · Reform des Strommarktdesigns

BASF urges wider regulatory support and faster green permitting

23 May 2023
Topic — A proposal to boost EU production of technologies essential for climate neutrality.
Message — BASF requests that fast-track permitting and financial support be extended to all strategic industrial sectors. They call for a cumulative cost impact assessment to ensure new rules do not hinder international competitiveness. Additionally, they want battery cathode active materials explicitly defined as components to qualify for strategic project status.123
Why — The company would secure faster project approvals and eligibility for strategic funding.45
Impact — Other industrial projects could face slower approvals as authorities prioritize specific net-zero technologies.6
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Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur)

17 May 2023 · Critical Raw Materials Act

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

BASF supports the overall objectives of the European Commissions proposal on the Ecodesign for Sustainable Products Regulation (ESPR). We believe that the chemical industry is well positioned to contribute to the EU Green Deals circular economy objectives, including the Chemicals Strategy for Sustainability (CSS), through the sustainable product innovations we bring to the market. To achieve the ambitious goals of the ESPR it is necessary to involve the chemical industry to ensure that requirements will be implementable and have a meaningful and positive sustainability impact. BASF produces chemicals that are in almost all the shortlisted end-use and intermediate products for ESPR. This demonstrates how central the chemical industry is for the green transition and how chemistry is an enabler for a more sustainable lifestyle for society. Therefore, we would like to offer our expertise on how best to regulate chemicals under ESPR to maximize the objective of circularity. Our Key Messages Chemicals and chemical production processes are already highly and well-regulated through REACH, CLP and IED. Regulation of chemicals as an intermediate product group under the ESPR bears a strong risk of double and potentially conflicting regulation. Chemicals should instead be regulated via their end-products under the ESPR. This way they can be evaluated in combination with their specific function in the product and its application to allow a holistic view across the entire life cycle and to avoid trade-offs. To avoid distortion between sectors and products, the same methods and standards should be used across all product groups (e.g. for recycled content or carbon footprint). Existing and internationally well accepted standards, e.g. ISO standards should be the basis of the sustainability assessments supported by sector-specific guidelines as the TfS guideline for GHG emissions. All sustainability requirements need to be enforceable to ensure a level playing field and ensure sustainability product claims are verifiable. Start with simple and homogenous product groups under the ESPR. When the process for regulating these product groups is tested and established for a number of simple cases, only then should more complex and wide-spread product groups be regulated. Please see attached position paper for further details.
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Meeting with Irène Tolleret (Member of the European Parliament) and Bayer AG and CropLife Europe

10 May 2023 · Pesticides

Meeting with Anna-Michelle Asimakopoulou (Member of the European Parliament, Rapporteur for opinion) and Umicore

10 May 2023 · Exchange of Views

BASF warns EU taxonomy targets for chemicals are unrealistic

2 May 2023
Topic — The EU is defining sustainable economic activities to guide green investment decisions.
Message — BASF requests more realistic targets for recycled plastic content and the inclusion of carbon capture technologies. They also argue that environmental testing requirements for pharmaceutical ingredients are impractical and should be simplified.12
Why — These changes would lower compliance costs and allow existing chemical products to qualify as green.3
Impact — Environmental groups lose protections as fewer chemical substances would be restricted in packaging materials.4
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BASF Urges Realistic Standards for EU Environmental Taxonomy

2 May 2023
Topic — Proposed EU rules defining sustainable activities for water, circularity, pollution, and biodiversity.
Message — BASF requests lowering the 65% recycled content targets and relaxing chemical restrictions that exceed current safety laws. They also argue wastewater requirements must be linked to technological availability and economic feasibility.123
Why — BASF would avoid high laboratory costs and prevent existing plants from being excluded from green finance.45
Impact — Environmental groups lose stricter limits on hazardous chemicals and more ambitious plastic recycling targets.6
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Meeting with Maria Arena (Member of the European Parliament) and European Chemical Industry Council

28 Apr 2023 · CLP

Meeting with Atidzhe Alieva-Veli (Member of the European Parliament)

26 Apr 2023 · Meeting

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur)

19 Apr 2023 · Packaging Waste

Meeting with Jens Geier (Member of the European Parliament)

11 Apr 2023 · Exchange on the electricity market design and energy prices

BASF calls for flexible labelling and clearer chemical substance definitions

24 Mar 2023
Topic — The consultation seeks to revise EU rules on chemical hazard classification and labelling.
Message — BASF requests derogations for complex substances and more flexible deadlines for updating product labels. They advocate for broader use of fold-out labels to simplify internal trade. Grouping principles for classification must be scientifically robust to avoid overclassification.123
Why — Flexibility reduces compliance costs and avoids losing critical raw material supply chains.45
Impact — Consumers and regulators may face slower hazard updates and reduced data transparency.67
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BASF Urges EU to Reduce Foreign Subsidy Reporting Requirements

6 Mar 2023
Topic — Procedures for the European Commission to investigate distortive foreign subsidies in markets.
Message — BASF seeks to reduce reporting burdens by raising financial thresholds for notifications. They also request a transitional period until 2026 to implement new data systems.12
Why — Reducing these requirements would save the company from massive administrative compliance costs.34
Impact — The Commission loses oversight of smaller subsidies that might still distort competition.56
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Meeting with Mohammed Chahim (Member of the European Parliament) and Port of Antwerp-Bruges International

6 Mar 2023 · FF55

Meeting with Michael Bloss (Member of the European Parliament)

17 Feb 2023 · Aktuelle Industrie-, Energie und Außenwirtschaftsthemen

Meeting with Anna Cavazzini (Member of the European Parliament)

17 Feb 2023 · Aktuelle Industrie-, Energie und Außenwirtschaftsthemen

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

16 Feb 2023 · Critical Raw Materials package

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

13 Feb 2023 · Gas package, Electricity Market Design (staff level)

Meeting with Jens Gieseke (Member of the European Parliament) and vbw - Vereinigung der Bayerischen Wirtschaft e. V.

31 Jan 2023 · Austausch zur Europapolitik

Meeting with Mairead McGuinness (Commissioner) and

10 Jan 2023 · Taxonomy, ESG ratings, CSRD

Meeting with Pascal Canfin (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs

8 Dec 2022 · Green Deal

Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion)

30 Nov 2022 · Meeting on agriculture related legislation

Response to European Critical Raw Materials Act

25 Nov 2022

EU businesses are progressively witnessing a significant increase in demand of strategic materials and components that is not being met by existing production capabilities. At the same time, the EU is facing threats of losing production due to decreasing global competitiveness, especially in the area of energy intensive basic products. This leads to shortages in downstream product supply, some of them with strategic importance (i.e. for those products linked to the implementation of the Twin Transition). Such a context, in conjunction with an increasing weaponization of strategic resources, urgently calls for dedicated actions to: 1) Increase supply availability and resilience via an ambitious global strategy to secure responsible and diversified imports, avoiding an overdependence on unsustainable single suppliers Policy option 1, 2 and 3; 2) Foster a circular economy for secondary raw materials via improved regulatory integration within the Single Market, and via horizontal waste collection and reuse activities across the Member States Policy option 4; 3) Provide a predictable legislative framework so to foster growth, financing and investments in the sector (e.g. on processing and reformulation, R&D, etc.) Additional policy recommendation.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

24 Nov 2022 · General discussion on ongoing files

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Nov 2022 · On the side of the EU Raw Materials week High Level Conference, the parties met to discuss current issues related to raw materials supply.

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Tesla Motors Netherlands B.V. and

14 Nov 2022 · Preparation of the critical raw materials act

Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

19 Oct 2022 · Pflanzenschutz (SUR)

BASF urges clearer criteria and longer transitions for hazard classes

18 Oct 2022
Topic — The European Commission is revising chemical classification rules to include new hazard classes.
Message — BASF requests precise legal definitions for new hazard classes to eliminate uncertainty. They advocate extending transition periods for mixtures to allow downstream users time to adapt. They also believe new classes should be introduced globally before being applied in Europe.123
Why — Longer transition periods and clearer definitions would prevent redundant workloads and reduce legal costs.45
Impact — Public health and environmental groups lose if stricter evidence requirements delay chemical classifications.6
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Christine Schneider (Member of the European Parliament, Shadow rapporteur)

23 Aug 2022 · nature restoration

Meeting with Susana Solís Pérez (Member of the European Parliament) and Kreab Worldwide

28 Jun 2022 · Green Deal and Chemical Strategy

BASF Warns Industrial Emissions Revision Threatens European Competitiveness

23 Jun 2022
Topic — Updating EU legislation on industrial emissions to support cleaner environment and health.
Message — BASF wants to keep the existing process for setting emission standards and ensure legal clarity for permits. They argue for avoiding new administrative burdens and protecting confidential business data. The company suggests relying on existing chemical safety regulations instead of new rules.123
Why — This would prevent expensive retrofitting of older plants and protect existing industrial revenues.45
Impact — Environmental groups would lose easier access to information and the ability to challenge permits.6
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

22 Jun 2022 · Corporate Sustainability Due Diligence

Response to Sustainable Products Initiative

20 Jun 2022

Response to the Public Consultation of the Ecodesign for Sustainable Products Regulation BASF supports the overall objectives of the European Commission’s proposal on the Ecodesign for Sustainable Products Regulation (ESPR). We believe that the chemical industry is well positioned to contribute to a more circular economy through the sustainable product innovations we bring to the market that will contribute to furthering the objectives of the EU Green Deal. To achieve the ambitious goals of the ESPR it is necessary to involve the chemical industry to ensure that requirements will work in practice. Therefore, in this response to the public consultation BASF focuses on recommendations to the European Commission to achieve an implementable and workable regulation that will allow industry to contribute to more sustainable products in the future. BASF suggests the following points to make the ESPR a success. Our Key Messages  Sustainability requirements should be comparable, enforceable and limited to the most relevant criteria and substances in the final product selected product by product  Duplication of existing legislation, in particular chemical regulation of substances, has to be avoided  Digital Product Passport should be implementable, ensure interoperability, allow access to data on a need-to-know basis only and prioritize data security  The chemicals sector shall be included in the Ecodesign Forum  A phased implementation timeline is necessary to manage the transition successfully, and with suitable incentives to achieve the objectives of the ESPR Please see attachment for further details and recommendations.
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BASF welcomes EU due diligence rules but seeks limited scope

23 May 2022
Topic — The consultation addresses new rules for corporate sustainability due diligence in value chains.
Message — BASF requests that due diligence obligations be limited to direct suppliers instead of the entire value chain. They call for clearer definitions to ensure legal certainty and avoid varying national interpretations. Additionally, they argue companies should only be held liable for their own direct actions.123
Why — This would lower compliance costs and reduce legal exposure from third-party actions.45
Impact — Victims of human rights abuses deep in the supply chain lose legal protection.6
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

19 May 2022 · Discussion on security of supply, diversification and energy prices.

Meeting with Veronika Vrecionová (Member of the European Parliament)

10 May 2022 · AGRI strategy with regard to Green deal and possible innovative approaches in agriculture and farm2fork

Meeting with Michael Bloss (Member of the European Parliament)

13 Apr 2022 · Energietransformation in der Chemieindustrie

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

BASF appreciates the EU Commission’s assessment that new/complimentary policies are critical to protecting EU energy-intensive and trade-exposed industries from carbon leakage, providing incentives for investments in new technologies and allowing for durable business cases in Europe to make the industrial transformation towards a climate-neutral economy work. We believe that Europe can become a global leader towards carbon-neutrality followed by others if industrial policy and climate policy go hand in hand, allowing EU manufacturers to compete in the global marketplace. No incomplete CBAM However, the policy framework laid out by the COM for a CBAM in July 2021 does not fulfill the criteria needed to provide sound carbon leakage protection. BASF sees fundamental and probably unsolvable hurdles: Disadvantages for EU producers of ammonia, nitric acid and their value chain products will arise both at EU and global markets. This affects downstream products like e. g. polyamide, polyurethanes, amines and other indispensable products and applications. Some severe issues are: • No export rebates: Products will become more expensive compared to non-EU producers at the global market. • No consideration of indirect cost: Importers of products covered under a CBAM will only bear part of the indirect carbon costs compared to EU producers. • No CBAM on value chain products: Importers of value chain products will have an unfair advantage. Severe circumvention via the value chains can be expected. • A default value of 10% of the worst EU installations for those importers who do not deliver data: Especially processes based on coal chemistry will have an incentive to not provide any data and save both import and bureaucracy costs  We request to fully exclude ammonia, nitric acid and their value chains from any additional cost envisaged by a CBAM, where Carbon Leakage protection cannot fully be assured: Protection by ETS free allocation must be completely maintained. Also, there should be no additional costs on imports, as they increase EU downstream production costs. No “full” CBAM unless full WTO compatibility can be assured In theory, some hurdles could be overcome by a “complete” CBAM which (a) covers the whole value chain up to the final goods, covering both direct and indirect emissions and which (b) would give a rebate on carbon costs at the border. In addition, an export rebate for avoidance costs for installations producing CO2 free would be needed to level the playing field towards exports from conventional production. Otherwise, it would make it even harder to develop global markets for CO2-free products, which can contribute to finance the necessary investments for the transition in the EU. In fact, both WTO conflicts and huge bureaucratic burdens may arise, which means that more practical solutions still need to be developed. New approaches needed  We ask the COM to come up with a solution that considers all policy options in a fair and transparent process along the following criteria: • Fully compliant with free-trade rules and open markets (WTO standards) • Long term, stable set-up to steer industry towards carbon neutrality • Strengthening of manufacturing, competitiveness and innovation in the EU • Applicable for all industrial sectors and value chains • Limiting bureaucracy to minimum needs The EU ETS did well with keeping carbon leakage protection EU-internal to avoid trade frictions and protecting exports. New policies such as CBAM changing this may face tremendous challenges, given the effort needed to drive the transformation in sectors which are economically and technologically challenging to decarbonize. EU industry must be able to compete in the global marketplace during the trans¬formation process. We ask the Commission to work towards a political framework which allows to fully implement all parts of the green deal: climate neutrality and growth. As CBAMs cannot deliver this, alternatives must be sought.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

At BASF we are committed to become climate neutral by 2050 in all our operations globally. Emission reduction in the chemical industry requires the electrification of heat and power use and processes. As a result, the RED is of high relevance for us. 1. Measures to increase availability and access to RES are an inevitable precondition for industry transformation and the overall success of the energy transition: We welcome ambitious targets for a steep increase of RES electricity, speed-up of permitting and better cooperation in offshore planning incl. cross-border grid planning. We value the Commissions intention to foster joint projects between member states. However, we see a further need to foster a more transparent, liquid and standardized procurement framework within the European Energy market. Furthermore, it must be ensured that the right to apply GoOs is not limited to energy suppliers but also given to other market participants. An inevitable precondition for the RED to be successful is an effective and efficient EU wide energy transport infrastructure. In this regard an increase of the share of RES electricity in industry is an intention we share and are eager to achieve. 2. Cost-efficient RES ramp up can be supported by market integration and the use of industrial demand potential: Member States need to encourage subsidy-free investments into renewable energy generation. For this purpose, the uptake of renewable PPAs should be encouraged and barriers to renewables integration removed. Industrial contributions to the funding of the installations can reduce financial risks associated with investments in subsidy free wind or photovoltaic parks. However, to stimulate such investments, renewable electricity from these very installations should be exempted from policy-induced surcharges. 3. Regulatory burdens on RES use through requirements for additional quality features need to be avoided as they hamper investments in RES-based technologies: Green power criteria, as they will be defined via a delegated act for the production of RFNBOs based on Art. 27, must not hinder electrification, for example by conditioning RES use to locality criteria, bidding-zone restrictions or limited full-load hours. 4. Any “hydrogen target” for industry needs to focus on encouraging industry to deploy efficient and realistic options which reduce CO2 emissions of hydrogen production: Climate-friendly hydrogen (i. e. hydrogen with a low CO2 footprint) as feedstock in chemical manufacturing is one of several important measures on our way to meet ambitious CO2 reduction targets. We are eager to reduce hydrogen-related emissions by a couple of complementary measures: 1. the set-up of an electrolyzer 2. further developing methane pyrolysis and 3. investigating the use of CCS at our Antwerp site. We believe that RED III could be an important framework to ramp-up renewable hydrogen in hard to decarbonize industries if it adheres to the following conditions: -RES electricity needs to be available, also at locations with low local/ regional RES capacity. Narrow criteria must not be applied for the ramp-up of H2 integration for essential feedstock use in cost-sensitive and trade-exposed industries (see point 3). -All climate-friendly hydrogen technologies must be accepted equally and counted towards a hydrogen target for the industrial sector. -Any hydrogen target needs to reflect the different potentials available in various member states due to environmental conditions, RES prices, long-term hydrogen strategies and other CO2 avoidance options. -It needs to be acknowledged that existing hydrogen production capacities can have limitations (see examples in the attachment). Here, a hydrogen target should focus in a first step on on-purpose hydrogen. Investments in future plants can provide more possibilities and should be encouraged. -Policies need to be in place to address the economic gaps of alternative hydrogen technologies.
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Meeting with Didier Reynders (Commissioner) and

8 Sept 2021 · Substainable Corporate Governance, Fit for 55

Meeting with Christian Ehler (Member of the European Parliament)

7 Sept 2021 · Horizon Europe

BASF urges EU flexibility and coherence in sustainability reporting

13 Jul 2021
Topic — The European Commission is revising rules for how companies report their sustainability performance.
Message — BASF requests adequate flexibility, longer transition periods, and alignment with international reporting standards. They urge the Commission to clarify vague terminology and prioritize a limited number of meaningful disclosures.12
Why — This approach helps the company lower compliance costs and protect commercially sensitive business data.34
Impact — Investors and civil society groups lose access to detailed data if disclosures are limited.5
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Response to Conversion to a Farm Sustainability Data Network (FSDN)

29 Jun 2021

BASF Feedback to the Commission Inception Impact Assessment on the creation of a Farm Sustainability Data Network BASF Agricultural Solutions welcomes the initiative to transform the existing Farm Accountancy Data Network into a more comprehensive tool that would cover all three pillars of sustainable development: economic, social and environmental. At BASF, we consider sustainability to be an integral requirement of modern farming. Sustainability is central to a farmer’s daily work and drives improvement efforts on the farm. As a result, over 10 years ago, BASF started developing a Life Cycle Assessment (LCA) tool called AgBalance® that helps farmers to review and plan their operational contributions across all three sustainability pillars. AgBalance® uses comprehensive farm data to measure downstream impacts on the environment, economic performance and even on society, giving results and recommendations for optimization of individual farm needs. Informed by our experience in developing AgBalance, we are taking this opportunity to share suggestions for developing the comparable future Farm Sustainability Data Network (FSDN). Criteria integrated into the new FSDN will need to reflect the complexity of agricultural sustainability The environmental, economic and social pillars of sustainable development are equally important to a successful transition to ever more sustainable food systems. BASF recommends that all criteria included should be based on scientific evidence and that none of the three pillars of sustainable development is overlooked. We are particularly concerned by the announced inclusion of the objectives and targets of the farm-to-fork and biodiversity strategies as part of the criteria for the FSDN as no cumulative impact assessment has been carried out for those measures. Furthermore, we advise that the FSDN be based on the following criteria, which are critical to AgBalance®’s high performance and relevance: Environment Criteria to evaluate environmental sustainability should include climate change, eutrophication, biodiversity, soil, land use, water, impacts of crop protection products and of fertilisers. Society At BASF, we believe social sustainability is an equally important pillar of sustainable development. BASF’s SEEbalance® methodology, which is integrated into the AgBalance® model, provides a useful and reliable tool for assessing the social impact of farming activity. Economy As the basis of the FSDN, the FADN already offers a sound methodology for collecting macroeconomic data and evaluating the impact of EU farming policy on the economic performance of European farms. This data network should be maintained and developed further. AgBalance® considers economic accounts of revenues and expenses, focussing economic analysis on subsidies and agricultural products’ selling prices, as well as the agricultural system’s variable and fixed costs. Conclusion Measuring sustainability is essential to understanding and managing the impact of both the EU Green Deal and the Farm to Fork Strategy. Clear measurements will help decision-makers anticipate the outcomes and assess the potential results of their draft policies’ implementation. This is a complex process, and better understanding and balancing the various trade-offs involved in policy decisions requires a rational, science-based and multi-disciplinary approach. Over the past 10 years, BASF has developed a powerful measurement tool for farm sustainability, and we are eager to share our experience and expertise to support the development of an EU FSDN that benefits the entire EU. A technical documentation over AgBalance and SEEbalance are available in attachment.
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BASF Urges One-Year Delay for Complex EU Taxonomy Reporting

2 Jun 2021
Topic — The consultation defines how companies report their alignment with EU sustainable investment standards.
Message — BASF requests a one-year delay for new sustainability reporting rules. They argue for less granular data to avoid complexity and confusion. They also request the removal of historical five-year reporting requirements.1234
Why — A delay reduces compliance costs and protects against potential competitive disadvantages.5
Impact — Investors lose detailed historical data required to evaluate long-term corporate sustainability transitions.67
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Meeting with Thierry Breton (Commissioner) and

24 Mar 2021 · Commissioner Breton meeting with CEOs from Energy Intensive Industries on Industrial strategy & fit for 55.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

BASF welcomes the initiative and the opportunity to provide feedback. A refurbished and improved building stock in the EU will help pave the way for a decarbonized and clean energy system, as the building sector is one of the largest energy consumers in Europe, responsible for more than one-third of the EU’s emissions. It is necessary to increase building renovation to ensure the contribution of the building stock to the climate ambition. Achieving a highly energy efficient and decarbonized building stock by 2050, the current ambition of the EPBD, requires additional instruments to increase the rate and depth of building renovation. BASF therefor supports a combination of the Option 2 (non-regulatory measures) and the Option 3 (Amend the EPBD to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation). BASF supports all measures that can increase rate and depth of renovation and recommends: - to define a specific energy efficiency target for the building stock to ensure it contributes to the 2030 targets according to its potential. - to follow the “energy efficiency first” principle to reduce the energy demand of buildings. It requires high-performance building envelopes as a starting point. - to pay particular attention to affordability and financing mechanisms of renovation work. - to adopt a performance-based, material neutral and life cycle approach to the environmental performance of buildings. - to ensure quality of renovation works by involving the right competent professionals for energy efficiency aspects but also for safety aspects. BASF will be pleased to contribute to the further consultation process.
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Meeting with Pascal Canfin (Member of the European Parliament)

9 Feb 2021 · Green Deal

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Jan 2021 · RRF

Response to Revision of the Communication on important projects of common European interest

15 Dec 2020

BASF welcomes the Commission’s initiative to review the Communication on important projects of common European interest (IPCEI) before its expiration on 31 December 2021. We appreciate the opportunity to provide feedback on the roadmap. Please find our summarized response hereafter. For the full version please see the document attached. Initiation Phase: Although the concept of IPCEI is very relevant and the dedicated communication from 2014 well structured, the procedure is perceived as complex and slow, with no clear rules and/or guidance on how to effectively proceed to enable successful and speedy implementation of IPCEIs. While BASF understands that this negotiation and determination process is necessary prior to the exact definition of the IPCEI scope, speeding up this process by assigning clear roles and responsibilities, also for the Commission, would be welcomed. For a successful IPCEI it is necessary that prospective applicants are already engaged in the shaping process. The start of the process must be transparently communicated and participation in the process must be possible for all. Funding Gap: It is specified in the Communication that the “funding gap refers to the difference between the positive and negative cash flows over the lifetime of the investment, discounted to their current value on the basis of an appropriate discount factor reflecting the rate of return necessary for the beneficiary to carry out the project notably in view of the risks involved”. The evaluation of the funding gap should be clarified, as it is not clear how the technological, financial and regulatory risks involved can effectively be taken into account. The definition of the counterfactual scenario and the proposed definition for the funding gap can make the evaluation of the necessity and proportionality of the aid difficult. Maximum Funding: The maximum permissible grant amount is limited by the eligible cost and the funding gap. While grant amount and eligible cost are nominal values, the funding gap is a discounted value. The current procedure of simply defining the funding gap as the maximum grant amount does not adequately reflect this fundamental difference and makes the declared goal of closing the funding gap impossible to reach. A clear rule about how to discount the funding when comparing the grant to the funding gap is needed. Reporting: The foreseen reporting lines are challenging confidentiality measures and introduce a duplication of reporting structures. Instead, while best practice data and collaborative information should be reported to the EU stakeholders (alliance, European Commission) and between the participants in order to build an ecosystem for the respective strategic value chain of the IPCEI, sensitive data (project specific data, milestones, KPIs) should be reported to the actual grantor Member State only. Thus, business confidential information can be protected while at the same time synergies for the value chain are created. We also recommend to fully digitalize the project controlling and administration process e.g. with tools like “profi online” to simplify the process for all participants. Agility and speed are essential for IPCEI projects. While EU rules permit starting work on the project without jeopardizing eligibility once the proposal has been submitted, national rules (e.g. in Germany) often do not provide this possibility. Future IPCEI rules should therefore include regulation that the invitation to submit a project portfolio also serves as the permit to start first activities (on the own risk of the applicant) and such allow participants to gain valuable time in the implementation of the project. The EU and Member States are using different tools (funding programs) for R&I Funding. Not every tool fits every purpose. IPCEI should only be used for projects which are considerably large in significance and investment and for partners which can manage both.
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Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

7 Dec 2020 · CCSU project Port of Antwerp

BASF Warns Against Disproportionate Emission Burdens on European Industry

26 Nov 2020
Topic — The EU is reviewing the Emissions Trading System to achieve higher climate targets.
Message — BASF demands that carbon leakage protections remain a central pillar and that non-ETS sectors share the emissions reduction burden proportionately. They urge the use of hybrid policy solutions like climate excises or contracts for difference to protect industrial competitiveness.123
Why — These measures would protect BASF from global competitors and reduce the financial risk of investing in new technologies.45
Impact — Non-ETS sectors like transport and buildings would face stricter regulatory requirements and higher emission reduction targets.67
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Meeting with Maroš Šefčovič (Executive Vice-President) and

13 Nov 2020 · BASF ground-breaking ceremony

Meeting with Frans Timmermans (Executive Vice-President) and European Chemical Industry Council

5 Nov 2020 · Decarbonisation; chemicals strategy for sustainability

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

13 Oct 2020 · Trade policy

Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

12 Oct 2020 · CCSU project in the port of Antwerp

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen), Bjoern Seibert (Cabinet of President Ursula von der Leyen), Fernando Sampedro Marcos (Cabinet of President Ursula von der Leyen), Maria Luisa Cabral (Cabinet of President Ursula von der Leyen), Mary Veronica Tovsak Pleterski (Cabinet of President Ursula von der Leyen), Nicole Dewandre (Cabinet of President Ursula von der Leyen), Olivier Smith (Cabinet of President Ursula von der Leyen), Per Haugaard (Cabinet of President Ursula von der Leyen), Valeria Miceli (Cabinet of President Ursula von der Leyen) and

31 Jul 2020 · The State of the Union in 2020 - The Digital Transition at the core of Europe's Recovery - [Via Webex]

Meeting with Valdis Dombrovskis (Executive Vice-President)

28 Jul 2020 · Presentation of the Value Balancing Alliance and BASF’s Value-to-Society accounting; Presentation of environmental accounting and its wider adoption in the industry; Revision of Non-Financial Reporting Directive

Meeting with Louise Groenfeldt (Cabinet of Executive Vice-President Margrethe Vestager)

3 Jul 2020 · To discuss ETS guidelines

Response to A EU hydrogen strategy

8 Jun 2020

BASF welcomes the opportunity to give its feedback on smart sector Integration and EU hydrogen strategy. Please find enclosed our detailed contribution. BASF comments on both consultations in this document. Our comments are guided by the list of questions proposed by the Commission.
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Response to Strategy for smart sector integration

8 Jun 2020

BASF welcomes the opportunity to give its feedback on smart sector Integration and EU hydrogen strategy. Please find enclosed our detailed contribution. BASF comments on both consultations in this document. Our comments are guided by the list of questions proposed by the Commission.
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Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

27 May 2020 · EU ETS State Aid Guidelines on indirect cost compensation

Meeting with Thierry Breton (Commissioner) and

11 May 2020 · Discussion on the impact of COVID-19

BASF Demands Competitiveness Safeguards in Higher 2030 Climate Targets

14 Apr 2020
Topic — EU initiative to increase the 2030 greenhouse gas reduction target to 55%.
Message — BASF wants the 2030 climate target tested for feasibility during economic recovery. They request stronger carbon leakage protections and higher emission cuts for buildings.12
Why — Removing renewable energy surcharges would lower electricity costs for large industrial sites.3
Impact — The building and automotive sectors would bear a heavier emission reduction burden.4
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Meeting with Christine Schneider (Member of the European Parliament)

17 Mar 2020 · Implementation EU Green Deal and Farm to Fork Strategy

Response to Farm to Fork Strategy

16 Mar 2020

Throughout this process, we consider it essential that the European Commission engages with the agri-food industry, from seed to fork. BASF would be pleased to offer its expertise to the Commission to develop a coherent, evidence-based Farm to Fork Strategy for a climate and environmentaly friendly, healthy and sustainable food system. Please see attached word document with BASF's Feedback on the Farm to Fork Strategy Roadmap
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BASF calls for competitive framework for EU climate neutrality

6 Feb 2020
Topic — This consultation concerns enshrining the 2050 climate neutrality objective into European Union legislation.
Message — BASF requests a policy framework that safeguards competitiveness while promoting breakthrough technologies. They support continuing free emission allocations and oppose including transport in carbon markets.123
Why — This would shield the company from high carbon prices and lower compliance costs.45
Impact — Environmental advocates lose as free permits and sector exclusions may delay decarbonization.6
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Response to A new Circular Economy Action Plan

20 Jan 2020

1 Products policy: no one-size-fits-all Sustainable product policies should be adapted to the field of application and in due consideration of the entire life cycle. For short lived goods like packaging material the waste management step contributes more to the overall sustainability performance. Long-living goods, however, e.g. in the construction industry are designed for durability and reliability during their use phase, ideally avoiding that a product becomes waste. Enforcement of the waste hierarchy and availability of waste management options, in particular prevention, re-use as well as mechanical, chemical and organic recycling, must accommodate this complexity and diversity of requirements. Sustainable products policy should not regulate the material as such, but the material in its respective use. “Level(s)”, the framework developed by the EU Commission for building assessment is an appropriate tool. 2 Providing reliable, verifiable and comparable information Information on chemical safety: REACH requires that industry and authorities ensure safety of chemical products and articles made thereof. It also provides for communication in the value chain. Hence, there is an obligation to ensure chemical safety as such rather than leaving the consumer by himself with a broad array of information and let him decide what to do with it. Information on circularity, e.g. the content of recyclate contained in a product, its recyclability or an analysis of the product’s performance throughout its life cycle are necessary for the consumer to allow him contributing to the circular economy in an informed manner. This includes information allowing appropriate handling/sorting of waste, e.g. for bio-degradable material. A gradual shift from fossil raw material to either waste based or bio-based raw material requires application of the mass balance approach, which relies on a reliable, verifiable and comparable way to generate and disseminate quantitative information on the use of these alternative raw materials. While 3rd party certification schemes are in place and used, these schemes should be harmonized and mutually accepted to ensure a trustworthy, large scale chain of custody. EU wide standards or a set of legally defined requirements would provide a sound basis for allocation schemes. 3 Modernization of certain waste laws We see the need to enforce existing waste legislation along the waste hierarchy, rather than creating new legislation or revising the existing laws. End of waste criteria should be the same in all EU member states and should allow waste owners to declare that their material has ceased to be waste and to certify compliance with relevant substance laws, e.g. REACH and the CLP regulation in a legally resilient manner. This will be an important precondition to transport, store and process material recycled from plastic waste as secondary raw material including as oil for further chemical processing. When revising legislation or defining details, such as the essential requirements for packaging, it is essential to leave room to accomodate upcoming and new technologies and materials. 4 Global level We support that the EU considers action on waste management in regions where the lever for improvement is larger than it is in Europe. The industry has already engaged in the Alliance to End Plastic Waste (AEPW). 5 Enabling technologies Chemical recycling can handle waste which is not mechanically recycled and deliver recycled content for demanding applications like food contact. This technology requires significant development work and investment to reach the required capacities. The decisions to invest work and capital will depend on a political consensus, that chemical and mechanical recycling are on the same level of the waste hierarchy and their combination provide the right approach to closing the material loop in a circular economy.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

7 Jan 2020 · European Green Deal and Industry

Meeting with Günther Oettinger (Commissioner)

30 Apr 2019 · European industrial policy

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

Dear Madam and Sir, Please find our comments attached. Best regards, K. Dietrich
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and ArcelorMittal and

22 Nov 2018 · taxonomy and EU IFRS

Meeting with Frans Timmermans (First Vice-President) and Shell Companies and

26 Oct 2018 · Discussion about Plastics Strategy, Circular economy

Meeting with Elżbieta Bieńkowska (Commissioner) and

4 Sept 2018 · Alliance of Energy Intensive Industries - 2050 strategy

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

4 Sept 2018 · Sustainable Development Goals

BASF SE urges stable policy and industry-focused climate strategy

10 Aug 2018
Topic — The consultation aims to develop a long-term EU strategy for greenhouse gas emissions reductions.
Message — BASF argues carbon is essential, making the term “decarbonizing EU industrial production” misleading. They demand a stable policy framework to maintain global competitiveness and investment trust. The group requests that industrial stakeholders be included to provide technical and market insights.123
Why — A stable framework would help BASF avoid costs from carbon market interventions and safeguard production.45
Impact — Environmental groups lose if policy targets are lowered to match industrial technical and economic constraints.6
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Response to Evaluation of the CARIFORUM Economic Partnership Agreement

20 Jul 2018

Besides the core question of implementation of the EU-CARICOM EPA, it would be useful to also evaluate possible positive (or negative) influences of other trade agreements trading relations of both parties are direct subject to e.g. the WTO trade facilitation agreement, GSP ... etc. to also determine where certain topical areas are best addressed from a stakeholder perspective and to also understand how EU activities in this context are best organized.
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Meeting with Günther Oettinger (Commissioner)

27 Jun 2018 · Industrial Policy

BASF urges EU to keep gas-based benchmarks for carbon permits

17 Apr 2018
Topic — The consultation revises rules for free allocation in the EU Emissions Trading System.
Message — BASF wants free allocation calculations to use the median of the reference period while excluding unrepresentative years. They recommend basing fall-back benchmarks on natural gas and excluding biomass-driven installations from efficiency calculations. They argue against penalizing efficiency improvements that reduce activity levels.12345
Why — These proposed rules would reduce the company's financial exposure to carbon pricing.6
Impact — Climate goals are undermined by maintaining benchmarks based on carbon-intensive fossil fuels.7
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Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas)

23 Nov 2017 · Innovation Principles and Industry

Response to Amendments of the Annexes to REACH for registration of nanomaterials

6 Nov 2017

BASF welcomes the EU-Commissions publication of the draft Annexes. It is an important step towards more clarity, predictability and legal certainty for registrants of nanomaterials and downstream users. We support the comments made by Cefic, NIA and other industry associations but would like to add further comments based on our expertise with nanomaterials. Specific comments to the draft recitals and Annexes are provided in detail in the attached file. Generally we would like to stress that the proposed changes will highly impact the registration of nanomaterials. Many of them are phase-in substances which are on the market since long and for which data have been generated in the past. For animal welfare and efficiency reasons it is important that priority will be given to the use of existing data instead of generating new data. Nanotechnology is a key-enabling technology. It is innovation driver for many sectors such as the electronics, the automotive or the construction industries. An increasing number of new nanomaterials will therefore have to be registered under REACH. The competitiveness and innovation power of European industry will also depend how successful it can introduce these materials to the markets. For that reason, we strongly support recital 6 that the changes in requirements must be appropriate and proportionate and we ask to consider this when taking the final decisions about the REACH Annexes. Moreover, we would like to remark that in the current draft, the information requirements for each set of forms is determined by the total registered tonnage. This could result in a huge number of new data requirements. For reasons of workability, proportionality, animal welfare and cost-efficiency, formation of large groups should be supported and accepted. In addition, the formation of different groups for different endpoints should be encouraged. This is already recommended in the Guidance documents but should be also particularly addressed in the recitals. The “tonnage-issue” is also important with a view to innovation, which could be the preparation of a new nanoform of an existing substance. For new “products” with mainly small volumes, REACH registration is already a big hurdle and should be limited to the necessary. Recital 7 of the current draft suggests that downstream users must inform the registrants when a nanoform is transformed into another nanoform in the subsequent processing of the nanomaterial. In the current REACH regulation, downstream users must already inform the registrants about the use of the substance and only registered uses are allowed to be brought on the markets. Transformation is not specific for nanomaterials and their detection among the most challenging in analytics at present. Also other substances transform during further processing. We therefore suggest deleting that part of the recital and to limit information requirements on use scenarios. With regards to animal welfare additional in vivo endpoints, e.g. toxikokinetics, and additional (eco)toxicological studies should be only requested when their additional value for risk assessment is justified. Finally, we would like to comment that a lot of progress has been made regarding OECD Guidelines and ECHA Guidances. However, the concept of nanoforms and grouping is still under development. Only in 2018 the EU-H2020 funded GRACIOUS project will start with the aim to refine the concept. In the interim time, flexibility with regard to the implementation of the REACH Annexes will be needed as well as communication between ECHA, Competent Authorities and registrants. BASF offers to discuss its comments in more detail. We place a high level of confidence in the EU-Commission that it will succeed to present a final draft that considers the precautionary principle while at the same time not compromising innovation according to the Innovation Principle. Contact: Carolin Kranz, carolin.kranz@basf.com, tel.: 0049 621 60-43
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Response to Implementing act on the Union list

2 Nov 2017

Dear Sirs, BASF SE wants to make an additional comment on the Commission's draft implementating regulation and its enclosed Union List: - Individual novel food notifications following the procedure of article 3 (4) in combination with article 5 of the Regulation EC No 258/97 have been filed in the past, and have been noted and published by the EU Commission. - One of these notifications is BASF's submission related to plant sterol esters to be used in food supplements due to a positive opinion of the responsible authority of Germany on the substantial equivalence compared to free phytosterols used in food supplements before May 1997. - This individual notification is currently not covered by the novel food authorizations as presented in the Union List. - Please enclose this in the future Union List to ensure that there is no uncertainty to the legal status of BASF's plant sterol ester being used in food supplements. Yours sincerely, Sebastian Aurich for BASF SE.
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Meeting with Vytenis Andriukaitis (Commissioner) and

24 Mar 2017 · Regulatory approval of plant protection products

Meeting with Jyrki Katainen (Vice-President)

10 Jan 2017 · Innovation and Competitiveness

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

7 Dec 2016 · EU approval of active substances for plant protection products. Bentazone.

Response to Commission Regulation amending Annex III to Directive 2008/98/EC

16 Aug 2016

In the CLP plastics (and alloys) have a special status as usually the migration of hazardous additives is very much retarded. In the consequence the hazard of those mixtures is significantly different from the additive itself. That is especially true for quite common additives with aquatic toxicity. Therefore according to CLP and the guidance for CLP there is a derogation possible if it can be shown that the mixture behaves different from the individual substances. Examples are shown in the CLP guidance for aquatic toxicity. Studies with a lot of plastics with additives classified for aquatic toxicity resulted in no aquatic toxicity often even in the worst case of masterbatches (to be diluted with plastic raw material at the converter) with very high concentrations up to 50% of additive content. Therefore this way of derogation for plastics (and alloys) by not very expensive experiments should be possible also for waste classifications. Otherwise we will have huge inconsistencies for classification of products in the safety data sheet (non hazardous) and the recommended handling also in the safety data sheet for the same material/mixture as hazardous waste. To my knowledge there are already those kind of leaching & aquatic toxicity tests implemented for waste classification for landfills in some member states.
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Meeting with Günther Oettinger (Commissioner)

16 Jun 2016 · digitization of industry

Meeting with Günther Oettinger (Commissioner)

16 Jun 2016 · digitisation of industry

Meeting with Jos Delbeke (Director-General Climate Action)

26 May 2016 · ETS - carbon leakage

Meeting with Kilian Gross (Digital Economy)

10 May 2016 · EEG Eigenstrom

Meeting with Alexander Italianer (Secretary-General Secretariat-General)

3 Dec 2015 · Business Europe CEO day

Meeting with Jyrki Katainen (Vice-President) and

3 Dec 2015 · Business Europe CEO day

Meeting with Frans Timmermans (First Vice-President)

3 Dec 2015 · Business Europe CEO day

Meeting with Carlos Moedas (Commissioner) and BUSINESSEUROPE and

3 Dec 2015 · Business Europe CEO day

Meeting with Maroš Šefčovič (Vice-President) and

30 Oct 2015 · creation of a network of Energy Union Business Ambassadors

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

2 Jun 2015 · Meeting with BASF (Mr P. Leonard & Mr W. Weber)

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and Bayer AG and

12 Feb 2015 · Digital Single Market, Innovation

Meeting with Dominique Ristori (Director-General Energy)

7 Jan 2015 · European Energy Policy priorities