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Chemical Industry Federation of Finland (Kemianteollisuus ry)

CIFF

The Chemical Industry Federation of Finland ensures the competitiveness of chemical companies in Finland.

Lobbying Activity

Meeting with Eero Heinäluoma (Member of the European Parliament)

25 Nov 2025 · Ajankohtaiset EU-asiat

Meeting with Pekka Toveri (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry)

17 Nov 2025 · Current Topics in EU

Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

1 Oct 2025 · Bioeconomy; European Innovation Act

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

1 Oct 2025 · Low Emission Carbon, Climate Law

Finnish Chemical Industry Seeks Clarity on Nature Credits Framework

30 Sept 2025
Topic — EU roadmap for integrating nature and biodiversity action into business operations.
Message — The organization requests clear objectives and science-based verification for the Nature Credits framework. They emphasize the need to clarify how Nature Credits relate to existing ISO standards, certification schemes, and sustainability platforms, questioning what added value credits would provide beyond current commitments.1234
Why — This would reduce administrative burden and prevent duplicative reporting requirements across frameworks.56
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Finnish Chemical Industry Demands Circular Carbon Strategy and ETS Reform

10 Sept 2025
Topic — EU's global climate and energy strategy for green diplomacy and external policy engagement.
Message — The federation requests a comprehensive Circular Carbon Strategy covering all alternative carbon sources, mandatory targets for non-fossil feedstocks, and amendments to existing legislation to harmonize waste, climate, and product safety regulations. They demand better carbon leakage protection, including full ETS allowances for exports and careful CBAM extension assessment.12345
Why — This would reduce their raw material costs and protect them from carbon leakage risks.67
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Meeting with Elsi Katainen (Member of the European Parliament)

1 Sept 2025 · Topical issues for chemical industry

Meeting with Jessika Roswall (Commissioner) and

27 Aug 2025 · Meeting to discuss EU chemicals policy

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen), Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

3 Jul 2025 · Chemicals industry and security

Chemical Industry Federation of Finland urges narrower reporting scope

27 Jun 2025
Topic — The EU initiative requires companies to disclose information about unsold consumer products they dispose of.
Message — The scope should initially be limited to durable consumer goods or specific product groups. This gives companies time to prepare for new reporting systems and verification processes.12
Why — Limiting the scope would reduce immediate compliance costs and administrative workloads for companies.3
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

20 May 2025 · EU Sustainability regulation

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

12 May 2025 · STEM & competitiveness

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

8 Apr 2025 · Water Resilience Strategy and Circular Economy

Meeting with Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

7 Mar 2025 · Follow up to competitiveness compass and simplification

Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

6 Mar 2025 · Competitiveness and sustainability of the Nordic - Baltic chemical industries

Meeting with Merja Kyllönen (Member of the European Parliament)

4 Mar 2025 · Kemianteollisuuden ajankohtaiset

Meeting with Anniina Iskanius (Cabinet of Executive Vice-President Henna Virkkunen)

12 Feb 2025 · Exchange of views on competitiveness compass and upcoming commission work programme for 2025

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

3 Feb 2025 · Biotech and Biomanufacturing

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

29 Jan 2025 · Ajankohtaiset kemianteollisuuden asiat

Meeting with Outi Slotboom (Director Internal Market, Industry, Entrepreneurship and SMEs)

29 Jan 2025 · Information exchange on Finnish chemical industry priorities and upcoming EU policy initiatives

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

28 Jan 2025 · Exchange of views on climate transition plan of the sector, Clean Industrial Deal.

Meeting with Eero Heinäluoma (Member of the European Parliament)

27 Jan 2025 · Ajankohtaisaiheet

Meeting with Mika Aaltola (Member of the European Parliament)

9 Jan 2025 · EU Affairs

Meeting with Eero Heinäluoma (Member of the European Parliament)

9 Dec 2024 · Ajankohtaisaiheet

Meeting with Pekka Toveri (Member of the European Parliament) and Kemira Oyj

20 Nov 2024 · Current Topics in EU politics

Meeting with Mika Aaltola (Member of the European Parliament)

19 Nov 2024 · EU Competitiveness

Meeting with Aura Salla (Member of the European Parliament)

19 Nov 2024 · The Commission's upcoming work program and its possible approach to energy and climate regulation

Meeting with Mika Aaltola (Member of the European Parliament)

6 Nov 2024 · Energy and Climate Policy

Finnish Chemical Industry Urges Alignment for Low-Carbon Fuel Standards

25 Oct 2024
Topic — The European Commission is defining the methodology to calculate greenhouse gas savings for low-carbon fuels.
Message — The federation requests clear criteria for sourcing non-fossil electricity and alignment with existing renewable fuel rules. They emphasize maintaining a level playing field between low-carbon and renewable energy sources.123
Why — The chemical industry would gain necessary regulatory certainty for producing synthetic aviation fuels.4
Impact — Renewable fuel producers lose out if low-carbon fuels reduce the market ambition for green energy.5
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Meeting with Li Andersson (Member of the European Parliament)

16 Oct 2024 · Biotech & EU regulation

Meeting with Katri Kulmuni (Member of the European Parliament) and Bayer AG and Orion Corporation

16 Oct 2024 · Ajankohtaiset EU-lakihankkeet

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

15 Oct 2024 · European skills policy

Meeting with Katri Kulmuni (Member of the European Parliament)

2 Oct 2024 · Päivitetty ilmastotiekartta

Meeting with Ville Niinistö (Member of the European Parliament)

1 Oct 2024 · Upcoming 2040 climate legislation

Meeting with Maria Guzenina (Member of the European Parliament)

24 Sept 2024 · Regulation

Meeting with Aura Salla (Member of the European Parliament)

18 Sept 2024 · EU competitiveness

Meeting with Elsi Katainen (Member of the European Parliament)

12 Sept 2024 · Ajankohtainen energiapolitiikka

Meeting with Eero Heinäluoma (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry)

17 Jul 2024 · Ajankohtaisaiheet

Meeting with Alviina Alametsä (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

26 Jun 2024 · Exchange of views

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

18 Apr 2024 · Europe’s competitiveness

Meeting with Nils Torvalds (Member of the European Parliament)

17 Apr 2024 · State of the EU politics

Meeting with Henna Virkkunen (Member of the European Parliament)

4 Apr 2024 · European industrial policy

Meeting with Elsi Katainen (Member of the European Parliament)

4 Apr 2024 · Current EU affairs

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

20 Mar 2024 · Green and circular economy

Meeting with Elsi Katainen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

13 Dec 2023 · Current political agenda

Meeting with Nils Torvalds (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

12 Dec 2023 · Finnish export industries

Meeting with Ville Niinistö (Member of the European Parliament)

12 Dec 2023 · Current EU policies

Finnish Chemical Federation Urges Simplified EU Reporting Rules

1 Dec 2023
Topic — The European Commission initiative aims to reduce corporate reporting burdens by twenty-five percent.
Message — The Federation wants the EU to use existing data sources like customs and statistics. They suggest aligning sustainability reporting with other regulations to avoid overlapping requirements. They also request limiting value chain disclosures to simplify data collection.123
Why — Streamlined reporting would free up specialized staff for safety and environmental improvements.45
Impact — Environmental groups lose access to detailed data on impacts within global supply chains.6
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Meeting with Petri Sarvamaa (Member of the European Parliament)

13 Nov 2023 · Topical issues in EU budgetary politics

Response to Drinking water - conformity assessment procedure

10 Nov 2023

Chemical Industry Federation of Finland supports the aims of the recast initiative to ensure the safety of materials in contact with the drinking water. The environmental circumstances and soil properties differ among member states, which should be taken into account in EU-wide harmonised approach. Well functioning drinking water supply is essential for the civil society and for companies. We support fully the Finnish State position in this matter. Finland's water quality requires the use of zinc-proof brass containing small amounts of lead in water equipment installations. The Commission has not included the brass alloys used in Finland and Sweden on the positive list of metallic materials, as they in the commission's view, dissolve too much lead in the water. Lead ends up in water mainly from materials used in water installations. Finnish and Swedish experts have calculated this to present 90 % (the natural lead concentrations in raw water are low), which would practically mean that the brass alloys are entitled to be included in the positive list. For the continuity of water supply and for sufficient transition periods for industry it is important that brass alloys based on national approvals are included in the positive list. The transition period until 2030 proposed by the Commission is not sufficient to develop and standardize new rep-lacement materials, adapt production to the new materials and bring them to the market. It is still unclear if zinc loss-resistant and lead-free or low-lead materials on the positive list or on the market could be used in water installations in Finland. Our market is also limited, which might not encourage all producers to develop materials resistant to zinc loss. The present proposal weakens the situation of Finnish industry in the internal market. The companies supplying zinc-loss-resistant brass grades are not able to adapt their production processes and the companies using the products would need to use non-zinc loss-resistant brass parts in water systems, which would cause premature damage and leakage, which typically increase moisture and mold damage as a result. In the Commission's proposal, only two alloys resistant to zinc loss have been included in the positive list. One of these cannot be recycled because it contains silicone and is therefore not compatible with other recyclable materials. The material of the second one is not standardized, so its composition is not exactly known. This can lead to problems in industrial production processes and unpredictable corrosion of products in water systems. Based on above our proposal for amendments are For the supplementing Directive (EU) 2020/2184 of the European Parliament and of the Council by laying down conformity assessment procedures for products that come into contact with water intended for human consumption and the rules for the designation of conformity assessment bo-dies involved in those procedures. Article 11 Entry into force and application This Regulation shall enter into force on the twentieth day following that of its publicati-on in the Official Journal of the European Union. It shall apply from 31 December 2026. However, for products which are assessed to be in conformity with national hygiene re-quirements for products that come into contact with water intended for human con-sumption and for which the national conformity certificate is still valid on 31 December 2026, it shall apply from [OP please insert the date = the last day of the twelfth (not fourth) year after the entry into force of this Regulation].
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Response to Drinking water - establishing the European Positive Lists of starting substances

10 Nov 2023

Chemical Industry Federation of Finland supports the aims of the recast initiative to ensure the safety of materials in contact with the drinking water. The environmental circumstances and soil properties differ among member states, which should be taken into account in EU-wide harmonised approach. Well functioning drinking water supply is essential for the civil society and for companies. We support fully the Finnish State position in this matter. Finland's water quality requires the use of zinc-proof brass containing small amounts of lead in water equipment installations. The Commission has not included the brass alloys used in Finland and Sweden on the positive list of metallic materials, as they in the commission's view, dissolve too much lead in the water. Lead ends up in water mainly from materials used in water installations. Finnish and Swedish experts have calculated this to present 90 % (the natural lead concentrations in raw water are low), which would practically mean that the brass alloys are entitled to be included in the positive list. For the continuity of water supply and for sufficient transition periods for industry it is important that brass alloys based on national approvals are included in the positive list. The transition period until 2030 proposed by the Commission is not sufficient to develop and standardize new rep-lacement materials, adapt production to the new materials and bring them to the market. It is still unclear if zinc loss-resistant and lead-free or low-lead materials on the positive list or on the market could be used in water installations in Finland. Our market is also limited, which might not encourage all producers to develop materials resistant to zinc loss. The present proposal weakens the situation of Finnish industry in the internal market. The companies supplying zinc-loss-resistant brass grades are not able to adapt their production processes and the companies using the products would need to use non-zinc loss-resistant brass parts in water systems, which would cause premature damage and leakage, which typically increase moisture and mold damage as a result. In the Commission's proposal, only two alloys resistant to zinc loss have been included in the positive list. One of these cannot be recycled because it contains silicone and is therefore not compatible with other recyclable materials. The material of the second one is not standardized, so its composition is not exactly known. This can lead to problems in industrial production processes and unpredictable corrosion of products in water systems. Based on above our proposal for amendments are For the implementing decision of laying down rules for the application of Directive (EU) 2020/2184 of the European Parliament and of the Council by establishing the European positive lists of starting substances, compositions and constituents authorised for use in the manufacture of materials or products that come into contact with water intended for human consumption. Article 3 Transitional provision Starting substances, compositions and constituents which have been approved by a Member State competent authority during the period from 13 July 2021 to 31 December 2026 in accordance with national provisions may be used in the manufacture of materials or products that come into contact with water intended for human consumption until 31 December 2036 (instead of 2030) , provided they comply with the parametric value of 5 µg/l Pb (lead) at the tap as set out in Part B of Annex I to Directive (EU) 2020/2184. Appendix II (starting on page 239) contains a positive list of metallic materials with no zinc loss-resistant materials currently used in the Nordic countries. Appendix V (starting on page 290) shows the allocation percentages for soluble materials for different substances. The allocation percentage of lead (page 293, second row, co-lumn 7) should be 90 not 50, and concentration (column 6) 4.5 not 2.5.
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Meeting with Pirkko Ruohonen-Lerner (Member of the European Parliament)

9 Nov 2023 · Laadukkaat harjoittelupaikat

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

8 Nov 2023 · Relevant energy, environment and resource legislation

Meeting with Elsi Katainen (Member of the European Parliament)

8 Nov 2023 · Energy and climate topics

Finnish Chemical Industry Opposes EU Export Ban on Hazardous Chemicals

31 Jul 2023
Topic — EU proposal to ban production and export of hazardous chemicals prohibited within the EU.
Message — The federation requests exemptions for chemicals with safe industrial uses in the EU, like sodium chlorate used in pulp production. They argue existing Prior Informed Consent procedures already protect importing countries through safety data sheets and labeling requirements.12
Why — This would allow them to continue exporting profitable industrial chemicals to non-EU markets.3
Impact — Non-EU countries lose protections if EU exports are replaced by suppliers with weaker safety standards.45
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Finnish chemical industry warns of excessive sustainability reporting burden

30 Jun 2023
Topic — New standards for companies to report environmental, social, and governance impacts and risks.
Message — The federation requests the Commission reduce the volume and granularity of reporting requirements. They seek clearer definitions for metrics and a sector-specific approach for chemical substances.123
Why — This would lower administrative costs and prevent competitors from calculating sensitive production volumes.45
Impact — Financial actors would receive less granular data regarding chemical pollutants and value chain impacts.67
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Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

28 Jun 2023 · Urban wastewater treatment, industrial emissions directive

Meeting with Ville Niinistö (Member of the European Parliament)

27 Jun 2023 · Chemicals

Meeting with Mauri Pekkarinen (Member of the European Parliament)

28 Apr 2023 · Meeting concerning battery industry

Meeting with Henna Virkkunen (Member of the European Parliament)

29 Mar 2023 · Paid traineeships

Finnish Chemical Industry Urges Fairer Wastewater Cost Sharing

14 Mar 2023
Topic — Revision of EU laws to protect human health and the environment from wastewater.
Message — CIFF opposes targeting only pharma and cosmetics for wastewater treatment costs. They want the responsibility system to include all economic operators releasing pollutants. They also request science-based substance lists.123
Why — A broader responsibility system would reduce the financial burden on Finnish chemical manufacturers.4
Impact — Other industrial sectors would lose their current exemption from wastewater treatment fees.5
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Meeting with Silvia Modig (Member of the European Parliament)

8 Mar 2023 · Carbon removal certification and sustainable carbon cycles (staff level)

Meeting with Petri Sarvamaa (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

7 Mar 2023 · IED and Zero Pollution

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and Bio-Rad Laboratories

6 Mar 2023 · Urban wastewater treatment

Meeting with Silvia Modig (Member of the European Parliament)

3 Feb 2023 · EU’s chemicals strategy for sustainability

Meeting with Alviina Alametsä (Member of the European Parliament)

8 Dec 2022 · climate and energy politics

Meeting with Nils Torvalds (Member of the European Parliament)

28 Sept 2022 · ITRE

Meeting with Henna Virkkunen (Member of the European Parliament)

28 Sept 2022 · EU Energy & Climate Policies

Meeting with Alviina Alametsä (Member of the European Parliament)

12 Jul 2022 · Future of chemical industry in Finland, EU regulation of Chemical industry, chemical industry as part of EU strategic autonomy

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

29 Jun 2022 · European green deal, energy and raw materials

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Jun 2022 · Fit for 55, EED, RED III, CBAM

Finnish Chemical Industry Warns EU Emissions Rules Could Stall Green Transition

22 Jun 2022
Topic — Proposed revision of the EU Industrial Emissions Directive regulating pollution from industrial facilities.
Message — The federation requests more flexible implementation of strictest emission limits, faster guidance on transition plans by 2025 instead of 2028, and recognition of existing company climate actions. They argue the proposal increases bureaucracy and costs while focusing on minor improvements rather than breakthrough innovations.123
Why — This would reduce compliance costs and administrative burdens while providing more time to adapt existing operations.45
Impact — Environmental groups lose stricter pollution controls as industry seeks more flexibility in meeting emission standards.6
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Meeting with Petri Sarvamaa (Member of the European Parliament)

21 Jun 2022 · Agriculture & Forestry

Meeting with Henna Virkkunen (Member of the European Parliament)

21 Jun 2022 · EU Energy Policy

Finnish chemical industry urges flexible carbon capture rules

17 Jun 2022
Topic — New EU methodology for assessing greenhouse gas savings from transport fuels.
Message — CIFF demands accepting all CO2 sources otherwise emitted to the atmosphere and removing the 2035 carbon capture phase-out. They also request using Guarantees of Origin for tracing emissions reductions throughout value chains.123
Why — The proposals would provide regulatory predictability and prevent delays in developing production capacity.45
Impact — Producers outside the EU currently benefit from inconsistent lifecycle emission accounting rules.6
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament) and Hycamite TCD Technologies Ltd

2 Jun 2022 · Carbon industry

Meeting with Nils Torvalds (Member of the European Parliament)

20 Apr 2022 · Climate, energy, digital policies

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

11 Apr 2022 · Topical discussion around energy and digital politics and Ukraine, Finnish trade politics

Meeting with Silvia Modig (Member of the European Parliament)

29 Mar 2022 · Fit for 55 -package

Response to Evaluation and revision of the Weights and Dimensions Directive

17 Feb 2022

Finnish Chemical Industry supports European wide weight and dimensions standardization and the aim to decrease emissions from commercial vehicles and improvement of road safety. However, also national regulation is required to ensure different industrial density, railroad and road network, and infrastructure is taken into account. Local regulation such as in Finland and Sweden which allows heavier and longer commercial vehicles must continue. Also, bi-lateral agreements between nations should be allowed also in the future. It is important that the commercial transportation is as efficient as possible. This supports low emission targets. Emissions must be calculated in such a way that calculations reflect reality as must as possible. One should not only calculate emissions of a single transport operation. On the contrary, emissions must be calculated based on amount of transported goods i.e., emissions per transported ton. Thus, it is not possible to achieve maximum efficiency and low emissions by using smaller single transportation volume. Use of smaller trucks will lead to higher emissions: 1. More transportation transactions are needed. This will cause higher transportation energy consumption, which will lead to higher emissions. This is evident in case one must organized 3 trips when earlier only 2 were needed. Low emission engine technology is not yet a viable alternative for heavy duty vehicles. 2. Smaller volumes mean more trucks are needed because commercial transportation is time sensitive. Thus, not only transportation emissions will increase but also need to manufacture more trucks will lead lower resource efficiency and will cause more emissions. A lifecycle analysis should be applied. From transportation and occupational safety performance point of view, increasing transportation frequency by smaller volumes is not beneficial: 1. Loading and unloading are the most dangerous events in the whole transportation chain in the chemical industry. Increasing number of loading and unloading transactions, will increase number of unwanted occupational and process safety incidents. 2. Having more truck on the roads is not going to improve road safety. Also, there is no evidence that bigger trucks decrease road safety. Weights and dimensions EU-regulation must be aligned with all other regulations concerning road transportation of chemicals e.g., international ADR-regulations and local regulations concerning transportation of dangerous goods. Chemical Industry Federation Finland represents almost 400 Chemical Companies in Finland.
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Meeting with Silvia Modig (Member of the European Parliament)

2 Nov 2021 · Fit for 55 -package

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Chemical Industry Federation of Finland's response to the draft dele-gated regulation on establishing the technical screening criteria for de-termining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives The Chemical Industry Federation of Finland welcomes the possibility to comment the draft delegated regulation and finds it important that a common EU taxonomy legislation is made with the target to increase investments in the green transition of the EU economy. We see that it would be important to include as many economic activities as possible to avoid some sector to be without a commonly agreed criterion. Therefore, the Chemical Industry Federation of Finland welcomes Commissions statement that the taxonomy will be broadened in the future by the Platform of Sustainable Finance. However, the development of the taxonomy must be built and rely on whole lifecycle analysis not only on some part of the lifecycle. The criteria must also be realistic, and science based. As we see it, the draft as it is presented now, would not encourage the forerunners in their sectors to continue with their efforts that they have taken. Too high thresholds undermine transitional and innovative efforts currently undertaken by the chemical industry, while limiting the investment universe. Please find detailed contribution in the attached document in following activities: 3.16 Manufacture of plastics in primary form 3.9 Manufacture of hydrogen 4.13 Manufacture of biogas and biofuels 5.9 Material recovery from non-hazardous waste 5.11 Transport of CO2
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Finnish chemical industry urges performance-based energy efficiency metrics

21 Sept 2020
Topic — The Commission is revising energy efficiency rules to meet higher 2030 climate targets.
Message — CIFF requests shifting from measuring absolute energy use to performance-based metrics. The directive should support industrial electrification and the deployment of green hydrogen.123
Why — This would allow the industry to increase electricity consumption for decarbonization efforts.4
Impact — Environmental groups prioritizing total energy reduction may see overall consumption increase.5
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Response to Modernising the EU’s batteries legislation

8 Jul 2020

The Finnish Chemical Industry Federation has established a specified Battery Group, which consists of key companies in the battery value chain, from mining of valuable battery metals to the recycling of batteries. We welcome the possibility to give our input to the Roadmap consultation "Modernising the EU's Batteries legislation". We welcome the adaption of the existing Directive to a more comprehensive regulation for batteries. Improving the legislative landscape impacting batteries and working towards better coherence across the sectors, is key to establishing a sustainable and competitive European battery industry. It is crucial to identify and eliminate unnecessary overlaps with other EU legislation. The innovation potential and competitiveness of the EU battery value chain has to be ensured. The expansion of the legislative scope to a broader battery technology spectrum, allows to better capture new or emerging technologies in the future. Tt is important to take the applications of the various technologies into account when revising relevant legislation We welcome the recognition of the carbon footprint and social responsibility across the value chain as essential sustainability indicators for batteries. Carbon footprint criteria, for instance, will increase transparency and provide the consumers with relevant information about the battery’s environmental footprint. It should be based on where the battery and its key components such as cathodes, are produced, as well as by CO2 per kWh. Companies that use CO2 free sources of electricity for the manufacturing of battery cells should be rewarded, by e.g. receiving credits, as this could be a strong incentive to minimize the carbon footprint in the entire value chain. Subsequently, there should be ambitious and equal recycling targets, both for imported and EU manufactured batteries, taking into account the environmental impacts of the recycling processes and the economic value of the materials contained in the batteries. This should include specific recovery targets for recycling (e.g. cobalt & lithium), and incentives to reuse recycled metals in new batteries. The EU should set up an effective control mechanism to prevent used batteries and critical raw materials from leaking out of the EU in order to secure the future supply of these materials. With hazardous substances in battery cell manufacturing and the use of recycled materials, a risk based approach should be applied when setting threshold limits. The new regulatory framework should be based as close as possible on market realities in order to guarantee the best efficiency possible in the management of batteries’ life cycle and the treatment of waste batteries.
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Finnish chemical industry urges focus on risk-based approach

18 Jun 2020
Topic — The European Commission is consulting on a new chemicals strategy for sustainability.
Message — The federation requests that overlapping requirements be removed instead of creating additional regulation. Management of chemicals should rely on scientific risk-based approaches. They demand impact assessments to avoid disproportionately costly and bureaucratic obligations.123
Why — Streamlining regulations would reduce industry workloads and support predictable long-term investment conditions.45
Impact — Environmental advocates lose the opportunity for tougher new regulations on endocrine disruptors.6
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Finnish chemical industry urges scaling of zero-emission hydrogen technology

8 Jun 2020
Topic — This consultation explores actions to support the production of clean hydrogen.
Message — They request support for scaling hydrogen production through demonstrations and infrastructure. Abundant, cost-competitive, and emission-free electricity is essential for their operations. They also suggest using public procurement and fast-tracked permits.123
Why — The industry would gain new ways to manufacture low-carbon liquid fuels.4
Impact — Existing fossil fuel suppliers would face new competition from cleaner energy.5
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Finnish chemical industry demands globally competitive green electricity

8 Jun 2020
Topic — EU strategy to link energy systems for deeper decarbonization and climate neutrality.
Message — They request secure distribution of emission free electricity that is cost competitive globally. They call for financing pilot projects and clear rules for carbon accounting between sectors.123
Why — Financial support and cheap renewable energy would help maintain their global market competitiveness.45
Impact — Fossil fuel providers will see reduced demand as chemical plants shift to electrification.67
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Finnish chemical industry warns against expanding industrial emissions rules

21 Apr 2020
Topic — A legislative review aimed at updating EU rules for industrial pollution and sustainability.
Message — The federation opposes extending the regulation's scope to new areas, fearing the drafting process will become overloaded. They urge the Commission to pause new technical reviews until the revised law is officially in place.123
Why — The organization would avoid increased administrative complexity and the cost of complying with overlapping climate regulations.45
Impact — Environmental groups lose a potentially powerful mechanism for forcing industrial sectors to decarbonize and embrace circularity.67
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Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Oct 2019 · The industry representatives raised the following topics: Carbon Border Tax, Circular Economy, Carbon neutrality, Industrial Policy Strategy and skills

Finnish chemical industry opposes titanium dioxide dust classification

8 Feb 2019
Topic — Amending rules for the classification, labeling, and packaging of chemical substances.
Message — The federation opposes the classification of TiO2 because it is based on its physical dust form rather than toxic properties. They argue that labeling requirements for non-dust mixtures lack scientific support and will harm recycling efforts.123
Why — Companies avoid higher waste management costs and the disruption of materials recycling.4
Impact — Waste treatment facilities and recycling sectors face operational hurdles and higher costs.5
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Meeting with Jyrki Katainen (Vice-President) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Technology Industries of Finland (Teknologiateollisuus ry)

11 Dec 2018 · Finnish EU-presidency and EU innovation policies

Chemical Industry Federation of Finland seeks evaluation delay

3 Dec 2018
Topic — Evaluation of the Industrial Emissions Directive regarding pollution reduction from large industrial sites.
Message — The federation claims it is too early to conclude the directive's impact. They suggest waiting for full implementation and a follow-up period. They also want flexibility for high-performing states.123
Why — Delaying the review prevents new regulatory burdens while current requirements are still being implemented.4
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

13 Jun 2018 · Industrial policy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

14 Sept 2015 · Energy Union