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Bundesverband Glasindustrie e.V.

BV Glas

The Federal Association of the German Glass Industry (Bundesverband Glasindustrie e.V.)

Lobbying Activity

Response to Electrification Action Plan

8 Oct 2025

Der BV Glas begrüßt die Möglichkeit, sich am Call for Evidence der Europäischen Kommission zum Electrification Action Plan zu beteiligen. Die Elektrifizierung stellt für die Glasindustrie den zentralen Hebel zur Dekarbonisierung dar und kann bei Nutzung von CO-freiem Strom Emissionen nahezu vollständig vermeiden. Technologisch sind vollelektrische und hybride Schmelzöfen einsatzbereit, ihre breite Einführung scheitert jedoch an hohen Strompreisen, langen Netzanschlusszeiten, hohen Investitionskosten und unzureichenden Fördermechanismen. Der Strombedarf elektrifizierter Anlagen vervielfacht sich gegenüber fossilen Öfen, während Großhandelspreise in der EU strukturell hoch bleiben. PPAs könnten zwar langfristige Preissicherheit bieten, sind für die konstant bandlastige Glasproduktion jedoch kaum geeignet, da sie auf volatile Einspeisungen ausgerichtet sind. Hinzu kommt, dass staatliche Beihilfen etwa nach CISAF oder CEEAG zeitlich begrenzt und finanziell unzureichend sind, um die Elektrifizierung wirtschaftlich tragfähig zu machen. Der BV Glas empfiehlt daher: gezielte Unterstützung für grundlastfähige PPAs aus erneuerbaren Energien, um Kostendifferenzen abzufedern, eine beihilferechtliche Ausgestaltung von CfDs, die den PPA-Markt nicht verdrängt, den Ausbau öffentlicher Garantieinstrumente (z. B. über die EIB) zur Absicherung industrieller Stromverträge, eine Erweiterung der Strompreiskompensation auf bislang ausgeschlossene, aber stark stromintensive Sektoren wie die Glasindustrie, sowie Maßnahmen zur Verkürzung und Transparenz von Netzanschlussverfahren, etwa durch das Prinzip First ready, first served und eine stärkere Einbindung der Industrie in die Netzplanung. Nur durch eine gezielte Kombination dieser Instrumente kann die Elektrifizierung der energieintensiven Industrie gelingen, ohne die Wettbewerbsfähigkeit Europas zu gefährden.
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Meeting with Alexandra Geese (Member of the European Parliament) and EVONIK INDUSTRIES AG and WirtschaftsVereinigung Metalle

30 Oct 2024 · Standortbesuch, Clean Industrial Deal

Meeting with Angelika Niebler (Member of the European Parliament)

27 Nov 2023 · EU energy policy

Response to Drinking water - establishing the European Positive Lists of starting substances

14 Nov 2023

Regarding the annex page 284/285, the composition of borosilicate glass should be in line with the borosilicate glass composition of the Glass-BREF. - The Glass-BREF provides a maximum concentration for Al2O3 of 7 %. This maximum concentration is important as Al2O3 leads to a corrective increase in the resistance of borosilicate glass, without completely compensating for the advantageous lower melting temperature. Please change the maximum concentration of Al2O3 to 7 % according to the BREF. - Regarding the minimum concentration of B2O3 the Glass-BREF provides a minimum concentration of 5 % for borosilicate glass. Please change the minimum concentration for B2O3 to 5 % according to BREF. - BREF provides for a max concentration of 12 % for Na2O. Please change the maximum concentration of the range to 12 % according to BREF - BREF provides for a max concentration of 2.5 % for K2O. Please change the maximum concentration of the range to 2.5 % according to BREF.
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Meeting with Monika Hohlmeier (Member of the European Parliament)

9 Nov 2023 · PPWR

Meeting with Christian Doleschal (Member of the European Parliament)

9 Nov 2023 · EU Green Deal

Meeting with Christine Schneider (Member of the European Parliament)

29 Jun 2023 · PPWR

Response to European Critical Raw Materials Act

25 May 2023

With the Critical Raw Materials Act (CRMA), the European Commission is presenting a regulation aimed at strengthening Europe's sovereignty with regard to the supply of raw materials. BV Glas welcomes this initiative, because strategic and critical raw materials are also used to manufacture glass products, especially in the special glass industry. Lithium, which is mainly used to produce glass ceramic panels for electric cooktops (induction/radiant) but also smartphone displays and fire doors, plays a particularly important role. In order to reduce the criticality of the raw material, projects are already underway at company level in Germany and Europe to recycle glass ceramic cooktops and use the processed cullet to manufacture new cooktops. Lithium is currently included in the list of strategic raw materials with the restriction "battery grade". BV Glas suggests removing this restriction, as it is also needed as "technical grade" in the glass industry. With the removal of the restriction, projects already underway at company level for the recycling of glass ceramic panels for electric cooktops could be recognised as "strategic projects" and the goal of the circular economy, which is formulated in Art. 25, could be promoted accordingly. BV Glas points out that the implementing acts provided for in Art 25 para. 5 and para. 7 allow for the possibility of stakeholder participation in the context of the Commission's better regulation agenda. Participation of the stakeholders concerned should take place in any case. For further details please see the attached document.
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and

28 Mar 2023 · Packaging Waste

Response to European Critical Raw Materials Act

25 Nov 2022

For the production of glass-ceramic panels for electric cooktops (induction / radiant) several raw materials that are listed as Critical Raw Materials by the EU (notably Lithium) are needed. Lithium is a critical component of glass-ceramics and cannot be substituted. For the year 2025 we expect around 15 million glass-ceramic cooktops to be sold in the EU, containing an estimated 4,350,000 kg of lithium carbonate. Over the past years, a rapid growth in the global Electric Vehicle sector led to a significant increase in raw material costs for battery materials especially Lithium. European companies from the glass-ceramic sector are increasingly competing with the Electric Vehicle battery industry for the critical supply of lithium. However, every year several million glass-ceramic cooktops end-up in the different European recycling systems. Cullet of glass-ceramic panels from these cooktops are a potential secondary raw material source to produce new glass-ceramic cooktop panels for the European home appliance industry. Due to the Lithium contained in the cullet its use as secondary raw material in the production would significantly reduce the demand for lithium by manufacturers of glass-ceramic cooktop panels. Unfortunately, current EU rules do not sufficiently facilitate the recycling of these glass-ceramic cooktop panels from relevant waste streams in a manner that utilizes the critical raw materials within the panels. Based on the current WEEE Directive it is not required to separate the glass-ceramic-panel from collected cooktops. Currently, not even a separate collection necessary for this separation is carried out. A separation of glass-ceramic-panel and cooktop is mandatory condition for the use of the cullet as secondary raw material for the production of new panels. Because this separation is currently not carried out, the recycled cooktops can only put to low value uses that do not utilize the lithium and the other critical raw materials in the cooktops. This is a huge loss of value to the EU economy and a source of avoidable strain on the environment and climate. The EU at the forefront of the circular economy should close this gap in the WEEE Directive, make the separate collection of cooktops and the separation of the glass-ceramic-panel from the cooktop mandatory and thus significantly improve the supply of critical to the European glass industry.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

22 Jun 2022

The Federal Association of the German Glass Industry (BV Glas) is a central point of contact for everything glass related. One of its most important functions is to provide key information about the German glass industry and about glass as a material not only to industrial users and decision-makers, but also the craft and retail trades, opinion leaders in the fields of science, research, politics and media, as well as to consumers. BV Glas also represents its members’ interests in the public sphere. As the central association for the German glass manufacturing industry, it is a key national and international player in all important areas of economic policy. The glass industry in Germany is of the opinion that an Industrial Emissions Portal is not necessary. The existing E-PRTR-system should remain in place without extensions so as not to overload the system. The E-PRTR gives a good overview of the emissions of the different sectors. BV Glas does not see a necessity for further data. In particular, we would like to warn that the planned level of detail would allow clear conclusions to be drawn about the production of individual plants in the future. The glass industry rejects this. Irrespective of the fact that there is usually potential for improving legislation, the question arises as to how urgent the need is for the present regulation and whether it comes at the right time. BV Glas is of the opinion that the amendment should be postponed. Please find enclosed more detailed information about our views regarding the proposal for a regulation on reporting of environmental data from industrial installations and establishing an Industrial Emissions Portal.
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Response to EU rules on industrial emissions - revision

22 Jun 2022

The Federal Association of the German Glass Industry (BV Glas) is a central point of contact for everything glass related. One of its most important functions is to provide key information about the German glass industry and about glass as a material not only to industrial users and decision-makers, but also the craft and retail trades, opinion leaders in the fields of science, research, politics and media, as well as to consumers. BV Glas also represents its members’ interests in the public sphere. As the central association for the German glass manufacturing industry, it is a key national and international player in all important areas of economic policy. Since the IED is working well, the question arises whether the timing for the amendment is right. Currently, the industry is facing great challenges due to the transformation process. This transition also goes together with a significant regulatory pressure exerted on the industry in the EU, in a limited timeframe, moreover at a time of crises, where the Covid-19 waves are being followed by the im-pacts of war in the Ukraine. In this exceptional situation - also with a view to a gas shortage situation - the industry must not be burdened additionally. The proposals for the IED amendment will lead to stricter requirements for industrial plants. The application of the strictest possible emission limit values from the emission range is a major change and contradicts the idea of the BREF process. The glass industry in Germany has the impression that the organisational obligations of plant operators will increase significantly. This will lead to considerable additional burdens for many businesses. Additionally, the planned rules will inevitably lead to longer permitting procedures. In order to make progress in the transformation of the industry, however, it is essential to speed up the approval procedures. In this respect, many of the planned regulations appear counterproductive. The increased comprehensive approach will make it more difficult to clearly delineate the different regulatory areas. BV Glas is doubtful whether dealing with a lot of different regulatory areas like health, energy efficiency, recycling and water, which all have legal provisions of their own, under the roof of the IED is effective. Please find enclosed more detailed information about our views regarding the proposed IED revision.
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Response to Carbon Border Adjustment Mechanism

16 Nov 2021

Please find our position in the attached file. BV Glas is part of the European federation Glass Alliance Europe.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

BV Glas, the German association of the glass industry, is part of Glass Alliance Europe (GAE) , the European Alliance of Glass Industries. We welcome the opportunity to provide feed back based on the position of our European sector federation GAE: A more elaborated position paper is attached to the contribution. Ensuring cost-effectiveness The glass industry supports the objectives set in the Climate Law, but stresses the importance to achieve these objectives in the most cost-efficient manner. In this context, all measures aimed at increasing the carbon prices without affecting the climate ambition are unnecessary slowing down the transformation of the EU industry (which face a huge challenge as they need to reduce their CO2 emissions by 61% between 2005 and 2030). This is e.g. the case for the rebasing (one-off cancellation of allowances) and the strengthening of the Market Stability Reserve (MSR). Addressing Carbon Leakage In order to achieve this ambitious reduction target, industry will have to invest massively in low-carbon technology. However, the high carbon prices, and the lack of a level playing field with non-EU regions, makes this extremely challenging. It is therefore essential to reinforce the existing carbon leakage protection measures as long as no global carbon pricing system exists. This can be done by applying the following measures: 1. The Cross-Sectorial Correction Factor (CSCF) needs to be avoided. To ensure this, the 3% flexibility between auctioning and free allocation shares needs to be increased. This is largely possible, since the impact assessment on the 2030 targets acknowledged that the abatement potential of the power sector (which is the historical reference of the auctioning share) is much larger than energy intensive industries’ (i.e. 70% vs. 22%). 2. In the same spirit, allowances in the MSR could be given to industry to avoid the CSCF instead of being cancelled. 3. The ETS secondary legislation should be revised to account for the impact of the COVID crisis. According to the current rules, free allocation for the period 2026-2030 will be based on the average production levels in the period 2019-2023. This will penalise EU companies which had unrepresentatively low production in 2020 due to covid pandemic. Other reference years should be used to calculate the Historic Activity Level. 4. Should a CBAM be introduced, it should co-exist with free allocation. From a legal point of view, the co-existence of free allowances and a CBAM under the EU ETS umbrella can be WTO compatible (see the legal study by AEGIS Europe https://static1.squarespace.com/static/5537b2fbe4b0e49a1e30c01c/t/60ec0a57e370ac6322a86209/1626081879682/AEGIS+Europe+-+CBAM+WTO+Legal+Analysis+-EXECUTIVE+SUMMARY-+KS+and+NCTM+-+Confidential+3+June+2021+REV.pdf). The consistency with WTO rules can be achieved by treating importers and EU manufacturers on the same footing, requiring importers to only buy allowances above the benchmark levels.. 5. As electrification is one option for the glass industry to decarbonise, it should be added in the list of sectors eligible for indirect compensation Supporting industry to transform Setting ambitious climate targets will not be enough to succeed in decarbonising our society. Public authorities should also massively invest in renewable energy (green electricity, Hydrogen, biomass) and infrastructures as this is not in the hands of industry. More financial support is also needed for industry to invest in low-carbon technologies. The glass industry therefore welcomes the increase of the Innovation Fund, but is of the opinion that this increase should mainly come from the auctioning revenues, and not from the free allocation share (as proposed by the Commission) because that makes the introduction of the CSCF more likely.
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Response to Revision of the Energy Tax Directive

14 Oct 2021

The glass industry wants to continue to support the EU on the path to climate neutrality. With its diverse products ranging from high performance glazing products to resource-saving container glass, reinforcement glass fibres in wind turbines, special glass for the semiconductor industry, the European glass industry is an essential contributor to the energy transition. To reach carbon neutrality, European glass manufacturers will have to invest massively in R&D and new technologies. This investment effort will take place in a context of high CO2 prices and energy prices. Maintaining the competitiveness of European manufacturers already exposed to unfair competition from countries with no or laxer climate policies is therefore essential. However, GAE has noted with concern that the draft Energy Taxation Directive 2022 no longer explicitly mentions mineralogical processes in Article 3 (b) which are out of scope. Considering the energy intensity and high trade intensity faced by the European glass industry, keeping the current applicable tax exemption is essential for its international competitiveness. Adding mineralogical processes in the new ETD would cost hundreds of millions of Euros to the glass industry. This would constitute a double burden with the Emission Trading Scheme, and severely undermine the capacity for the glass industry to invest in low carbon technology and succeed its energy transition. Based on above considerations, GAE asks the EU Commission to keep 'mineralogical processes' in the list of uses of energy products and electricity in Article 3 1. (b) of the Proposal for a COUNCIL DIRECTIVE restructuring the Union framework for the taxation of energy products and electricity.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

BV Glas supports the goal of the Commission to achieve a higher level of protection of citizens and of the environment against hazardous chemicals and believes that its products are aligned with these criteria. However, the actions foreseen by the European Commission seem to pose a lot of new requirements on companies. These requirements will lead to enormous costs and efforts for companies. Each individual measure should be weighed against the respective consequences and the principle of proportionality should be observed. BV Glas would like to contribute to the CLP revision process. The initial thoughts of the Glass Industry in Germany on the revision of the EU legislation on hazard classification, labelling and packaging of chemicals can be found attached.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

BV Glas supports the goal of the Commission to better protect citizens and the environment against hazardous chemicals and encourage innovation and believes that its products are aligned with these criteria. However, in the revision of the REACH Regulation, considerable tightening of the regulations is planned. BV Glas would like to contribute to the REACH revision process. In general, from an industry's point of view, the departure from the approach of risk-based chemicals regulation is particularly critical. In detail, the initial thoughts from the Glass Industry in Germany on the seven concrete field of actions identified by the European Commission can be found attached.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

BV Glas, the Federal Association of the German Glass Industry, supports the EU's ambition to take further steps towards a zero pollution ambition. However, the glass industry is not convinced that the EU Action Plan Towards a Zero Pollution Ambition for air, water and soil is the best way forward. It does not take sufficiently into account that environmental impacts are part of industrial processes and not every substance is hazardous to the environment and health in every concentration. Therefore, the glass industry prefers a risk-based approach which takes into consideration the individual case. For our complete position paper please see the attached file.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

BV Glas is the Federal Association of the German Glass Industry. We welcome the opportunity to give feedback to the revision oft he E-PRTR at this early stage. The reporting modalities are of huge practical relevance and our members informed us about problems and inconsistencies on this field. This concerns the PRTR report and emission declaration, more work only where necessary technical modalities and plausibility check. See the attached file for the details.
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