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CIRFS: European Man-made Fibres Association

CIRFS

CIRFS: European Man-Made Fibres Association is the representative body for the European man-made fibres industry.

Lobbying Activity

Response to Evaluation of EU Rules of Origin

2 Dec 2025

CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 70% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca. 4.3 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality. Please find attached CIRFS views on the evaluation of of EU Rules of Origin.
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Response to Circular Economy Act

6 Nov 2025

Mandatory Recycled Content Requirement For man-made fibres the EU should introduce a binding traceable recycled content obligation at product level in the upcoming Circular Economy Act. This will create market certainty and drive innovation in recycling technologies whilst maintaining the EU industry competitive in markets where it would otherwise be at a cost disadvantage.Gradual and Predictable Roadmap Targets should ideally be phased in progressively, according to a clear timeline that incentivizes economic operators and encourages investment, while avoiding disruptions to the supply chain. Consultation with Industry Both the level of ambition and the implementation pathway should be defined in close consultation with fibre producers, retailers, recyclers, and other stakeholders to ensure technical feasibility, economic viability, and alignment with sectoral realities. Flexible approach as to Recycling Fibre-to fibre recycling is desirable, but may be, in some instances, very challenging. It can also have a negative environmental impact due to potential lack of local fibre waste streams that leads to transport of low density waste across long distances. Open loop recycling should therefore be allowed. It may be the most efficient solution in a number of proven cases and allow for the recycled materials to be re-used inside the EU, rather than being exported. A flexible approach to recycling technologies, including mechanical, thermo-mechanical and chemical recycling is more suited to tackling the complexities of textile waste recycling. In the context of chemical recycling and bio-mass balance, a mass balance approach should be formally recognized. The recognition and inclusion of mass balance for both bio-based, bio-attributed, and chemically recycled feedstocks within EU legislation and sustainability frameworks is needed to reduce uncertainty and signal long-term policy support. A common methodology should apply to all advanced recycling technologies, ensuring legal certainty for investment and supply of high-quality secondary raw materials. For polyolefins, where mechanical recycling leaves contaminants, in many applications, advanced recycling/mass balance is the only viable option. EU-harmonized EPR and polluter pays principle: Collection and sorting must also be addressed, at the level of those who place products on the market. Retailers and brands, not fibre producers, determine product design, material composition, and ultimately the recyclability of garments and household textiles. Mandatory EU-wide collection targets will be necessary to ensure sufficient feedstock for recycling and to reduce the current reliance on exports and incineration. The role of post-industrial waste: Separate collection of textiles is not yet implemented at EU level, we recommend enabling the use of post-industrial waste to achieve recycled content targets, at least during the transition to a full scale-up of the EU collection and recycling infrastructure. To avoid any misuse, we support a strict definition of post-industrial waste, based on EN standard 45557:2019, ensuring that this exclusively covers those materials that have been discarded during a production process and have been treated in a re-processing facility, with the aim of excluding unsold goods. Bio-based Polymers: There should be funding available to enable the circularity of biopolymers,. Biodegradation under natural conditions should be considered an "end-of-life" waste management mode under the CEA, and by extension the Waste Framework Directive and Eco-design for Sustainable Products Regulation. Harmonized and recognized tests and standards are needed and should go beyond mere time requirements. Product Environmental Footprint: A much more meaningful PEF methodology, applied in LCA and environmental footprint which is not in use in PEF today would be based on allocating CO2 removals credits to biomass when produced AND giving CO2 penalty to all CO2 released.
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Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

Please find attached the relevant CIRFS paper concerning the review of the EU ETS state aid guidelines for indirect carbon costs. CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 70% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca. 4.3 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

CIRFS is the representative body of Europes 12 billion MMF industry, covering approximately 70 percent of European production and sustaining around 20,000 jobs across 250 facilities throughout the Union. Please find attached dour views.
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Response to EU Strategy on medical countermeasures

9 May 2025

We welcome the EUs focus on enhancing strategic stockpiling, particularly in light of the lessons learned from the COVID-19 pandemic. Man-Made Fibres (MMF) are essential to the production of health and hygiene-related products, including personal protective equipment (PPE) such as face masks, gowns, wipes, and other medical materials. Our sector also supports critical industries such as transportation, defence, agriculture, fisheries, energy and construction. The MMF industry plays a key role in ensuring Europe's preparedness for future public health and defence crises, and it must be taken into consideration in the EU stockpiling strategy to strengthen both EU resilience and the broader economy. Europes heavy reliance on MMF importsparticularly from Chinahas created vulnerabilities that were exposed during global supply chain disruptions such as during the COVID-19 pandemic. Overcapacity in markets like China has led to unfair competition for European producers. Trade disruptions continue to pose a risk, as the sector faces growing competition from imports, especially from China, undermining market stability and threatening European jobs and industry. To address these issues, we propose a number of recommendations for the EUs stockpiling strategy. First, the EU should formally recognize MMF as a critical sector for public health and defence and ensure its inclusion in stockpiling frameworks. This recognition will help safeguard Europes readiness for future crises. Second, the EU should establish strategic reserves of MMF-based products and critical raw materials needed for healthcare and defence applications, underpinned by local content requirements. This would reduce dependency on external suppliers and improve the EU's rapid response capability. Third, the EU should provide financial aid to MMF companies to help maintain production capacities, support innovation, and protect jobs. Firth, the EU must take stronger action against unfair trade practices. Enhanced trade defence measures are essential to protect European MMF producers from unfair competition, especially from countries with overcapacity and state subsidies. We strongly support the EUs efforts to develop a stockpiling strategy and urge continued action to strengthen its ability to supply essential goods during times of crisis. The MMF industry remains committed to investing in Europe and contributing to a strong, resilient European industrial base. CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca. 4.3 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality.
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Response to Communication on the EU Stockpiling Strategy

9 May 2025

We welcome the EUs focus on enhancing strategic stockpiling, particularly in light of the lessons learned from the COVID-19 pandemic. Man-Made Fibres (MMF) are essential to the production of health and hygiene-related products, including personal protective equipment (PPE) such as face masks, gowns, wipes, and other medical materials. Our sector also supports critical industries such as transportation, defence, agriculture, fisheries, energy and construction. The MMF industry plays a key role in ensuring Europe's preparedness for future public health and defence crises, and it must be taken into consideration in the EU stockpiling strategy to strengthen both EU resilience and the broader economy. Europes heavy reliance on MMF importsparticularly from Chinahas created vulnerabilities that were exposed during global supply chain disruptions such as during the COVID-19 pandemic. Overcapacity in markets like China has led to unfair competition for European producers. Trade disruptions continue to pose a risk, as the sector faces growing competition from imports, especially from China, undermining market stability and threatening European jobs and industry. To address these issues, we propose a number of recommendations for the EUs stockpiling strategy. First, the EU should formally recognize MMF as a critical sector for public health and defence and ensure its inclusion in stockpiling frameworks. This recognition will help safeguard Europes readiness for future crises. Second, the EU should establish strategic reserves of MMF-based products and critical raw materials needed for healthcare and defence applications, underpinned by local content requirements. This would reduce dependency on external suppliers and improve the EU's rapid response capability. Third, the EU should provide financial aid to MMF companies to help maintain production capacities, support innovation, and protect jobs. Firth, the EU must take stronger action against unfair trade practices. Enhanced trade defence measures are essential to protect European MMF producers from unfair competition, especially from countries with overcapacity and state subsidies. We strongly support the EUs efforts to develop a stockpiling strategy and urge continued action to strengthen its ability to supply essential goods during times of crisis. The MMF industry remains committed to investing in Europe and contributing to a strong, resilient European industrial base. CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca. 4.3 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality.
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Response to New comprehensive strategic approach towards India

8 May 2025

CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca. 4.3 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality. The European man-made fibres (MMF) industry welcomes the opportunity to provide input to the forthcoming Joint Communication on the EU-India Strategic Partnership. In this context, CIRFS would like to highlight considerations that are crucial for ensuring that the future partnership fosters a balanced, fair, and sustainable environment for the textiles and man-made fibres sectors. The EU-MMF industry is a strategic sector, supplying essential raw materials to multiple downstream industries, including textiles, automotive, construction, defence, agriculture and hygiene. Trade relations with India, however, reveal significant imbalances. While the EU market has remained open to imports from India, which have been increasing in recent years, the Indian market has been gradually closing through the imposition of tariff and non-tariff barriers, significantly impacting EU exports of MMF. These imbalances are further exacerbated by the substantial and unfair cost advantages enjoyed by Indian producers. These include significantly lower compliance costs due to the absence or limited availability of social, labour, health, safety and environmental standards, no obligations to purchase CO certificates; lower energy taxes; and much cheaper energy and raw material prices - partly driven by direct imports of fossil fuels from Russia and the widespread use of coal as a primary energy source. These conditions raise serious concerns about fair competition and clearly demonstrate why unconditional free trade would place EU producers at a disadvantage. In addition, India has increasingly introduced non-tariff barriers that effectively isolate its market, negatively impacting EU exports. These measures are often justified as protection against unfair competition from China, but they also harm legitimate EU trade interests. We therefore call on the EU to fully consider the interests of our sector and to develop targeted measures that safeguard the competitiveness and long-term viability of the European MMF industry. A future strategic partnership must address these disparities. Please find attached our statement outlining our full views on a potential EU-India partnership.
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Response to Evaluation of the Public Procurement Directives

7 Mar 2025

On behalf of CIRFS, representing approximately 70% of the EU's man-made fibre production, we appreciate the opportunity to contribute this public consultation. In this context, we submit the following observations and recommendations: The current directives do not adequately protect the EUs strategic autonomy, particularly in cases of supply chain dependencies or disruptions due to global crises, such as health emergencies, energy shortages, or security threats. The lack of security considerations in procurement decisions exposes critical sectorsincluding defence, healthcare, mobility and infrastructureto significant vulnerabilities. A notable example is the 2023 procurement of military garments by the German Federal Ministry of the Interior. Although awarded to a German company, the contract resulted in the supply of fabric and spun yarn from China, despite the EUs capacity to produce these materials domestically. This case highlights the failure of public procurement policies to ensure supply chain resilience and secure EU-based production. Conversely, the Dutch police tender for ballistic vests demonstrates a more effective approach by requiring sourcing at the NATO and EFTA levels, thereby strengthening the EU's security and strategic autonomy. Joint public procurement initiatives in the defence sector can improve cost efficiency, enhance supply chain resilience, and strengthen the EUs strategic autonomy. A successful example is the Nordic Combat Uniform (NORDEFCO) procurement project, where Nordic countries collectively sourced military uniforms. Expanding such models across the EU would further secure supply chains and reinforce the EUs defence capabilities through coordinated procurement strategies. To reinforce Europe's industrial base and enhance supply chain resilience, local content requirements should be established across the entire value chain for goods procured through public tenders, particularly in sectors critical to security and defence. For instance, the procurement of textiles for defence should be, when appropriate, subject to mandatory EU sourcing requirements. Additionally, for any finished products incorporating textilessuch as personal protective equipment or textiles used in automobilesa local content requirement should apply throughout the value chain to reflect EU production capacities. However, when essential raw materials are not available in Europe, the possibility to source globally shall remain. The Berry Amendment in the United States serves as a pertinent legal precedent which requires the Department of Defence (DOD) to procure certain itemssuch as textiles, clothing, footwear, food, and hand or measuring toolsfrom domestic sources. This mandate ensures that these items and their raw materials are entirely grown, reprocessed, reused, or produced within the United States, thereby securing the national supply chain. Implementing a similar framework within the EU would safeguard European industries and reduce reliance on non-EU suppliers. The current directives should also place greater legal emphasis on environmental sustainability and social responsibility in public procurement. In the textile sector, the procurement of low-quality, unsustainable products, disadvantages European manufacturers that prioritize sustainability, high-quality production, and fair labour conditions, often resulting in procurement decisions driven primarily by cost considerations rather than long-term value creation. To address this issue, the directives should introduce legally binding provisions requiring contracting authorities to procure goods that comply with EU environmental and social standards. We appreciate the Commissions efforts in reviewing the Public Procurement Directives and urge the inclusion of these recommendations to ensure a more sustainable, secure, and strategically autonomous procurement framework for the EU.
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

CIRFS, the association representing Europes 12.3 billion man-made fibres (MMF) industry, welcomes the opportunity to provide feedback on the Net Zero Industry Act (NZIA). As the voice of a sector that produces 4.3 million tonnes of MMF annually, covering 70% of Europes output and providing 20,000 jobs across 250 plants, we strongly advocate for the inclusion of MMF in the delegated and implementing acts under the NZIA. MMF: A critical processed material for Net-Zero Technologies Man-made fibres are essential to multiple net-zero technologies and applications, meeting the legislative criteria set in Regulation 2024/1735, Article 3, and further detailed in the Staff Working Document accompanying the delegated act. MMF are: Specific: Developed for specialized applications in key renewable energy and sustainable technologies. Commercially Available: Widely produced in Europe with well-established supply chains. Primarily Used and Essential: Foundational to the performance and sustainability of various net-zero technologies. Despite the critical role of processed materials, their recognition in the Commissions assessments remains limited. CIRFS urges the European Commission to expand its focus on processed materials and ensure MMF are properly classified under the primarily used components category in the delegated and implementing acts. Applications of MMF in Net-Zero Technologies (not exhaustive) Man-made fibres are indispensable across multiple renewable and clean energy applications, including: Floating Offshore Wind Energy: MMF-based mooring ropes secure floating offshore wind farms, enabling deployment in deep waters. Wind and Hydro Turbines: MMF serve as the basis for carbon fibres, which are integral to lightweight, high-performance turbine components. High-Temperature Insulation: MMF materials contribute to energy savings in industrial and energy applications. Submarine Power Cables: Used in deep-water energy transmission, supporting offshore wind and interconnectors. Hydrogen Infrastructure: MMF-based pipes are crucial for safe hydrogen transportation. Energy Storage and EVs: MMF is the basis for electrical separators in lithium-ion batteries, supercapacitors, and electrolytic condensers, playing vital role in electric vehicles (EVs) and other energy storage technologies. EV Components: MMF are found in tyres, hoses, and various structural components in electric vehicles, improving efficiency and durability. Addressing Europes strategic dependence One single non-European country now accounts for around 70% of global MMF production, creating critical dependencies for European value chains. This market dominance: Threatens Europes industrial resilience, making the continent vulnerable to supply chain disruptions. Distorts global competition, as massive overcapacities from this non-European country put European manufacturers under intense economic pressure. Jeopardizes EU sustainability goals, as reliance on external suppliers undermines the security of supply for essential materials in wind energy, hydrogen, EVs, and energy storage. A value chain approach is essential to strengthen EU resilience, ensuring that Europe remains competitive and self-sufficient in strategic net-zero technologies. CIRFS calls on the European Commission to take action CIRFS urges the European Commission services to: 1. Recognize MMF as a critical processed material that meets NZIA criteria and underpins key net-zero technologies. 2. Revise the delegated and implementing acts to explicitly include MMF in the annexes listing primarily used components. 3. Address the significant supply chain risk posed by a single non-European countrys dominance, reinforcing EU industrial autonomy. By incorporating MMF into the NZIA framework, the EU can ensure a sustainable, resilient, and competitive industrial ecosystem that fully supports the transition to net-zero while protecting European producers from market distortions.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

CIRFS, the association representing Europes 12.3 billion man-made fibres (MMF) industry, welcomes the opportunity to provide feedback on the Net Zero Industry Act (NZIA). As the voice of a sector that produces 4.3 million tonnes of MMF annually, covering 70% of Europes output and providing 20,000 jobs across 250 plants, we strongly advocate for the inclusion of MMF in the delegated and implementing acts under the NZIA. MMF: A critical processed material for Net-Zero Technologies Man-made fibres are essential to multiple net-zero technologies and applications, meeting the legislative criteria set in Regulation 2024/1735, Article 3, and further detailed in the Staff Working Document accompanying the delegated act. MMF are: Specific: Developed for specialized applications in key renewable energy and sustainable technologies. Commercially Available: Widely produced in Europe with well-established supply chains. Primarily Used and Essential: Foundational to the performance and sustainability of various net-zero technologies. Despite the critical role of processed materials, their recognition in the Commissions assessments remains limited. CIRFS urges the European Commission to expand its focus on processed materials and ensure MMF are properly classified under the primarily used components category in the delegated and implementing acts. Applications of MMF in Net-Zero Technologies (not exhaustive) Man-made fibres are indispensable across multiple renewable and clean energy applications, including: Floating Offshore Wind Energy: MMF-based mooring ropes secure floating offshore wind farms, enabling deployment in deep waters. Wind and Hydro Turbines: MMF serve as the basis for carbon fibres, which are integral to lightweight, high-performance turbine components. High-Temperature Insulation: MMF materials contribute to energy savings in industrial and energy applications. Submarine Power Cables: Used in deep-water energy transmission, supporting offshore wind and interconnectors. Hydrogen Infrastructure: MMF-based pipes are crucial for safe hydrogen transportation. Energy Storage and EVs: MMF is the basis for electrical separators in lithium-ion batteries, supercapacitors, and electrolytic condensers, playing vital role in electric vehicles (EVs) and other energy storage technologies. EV Components: MMF are found in tyres, hoses, and various structural components in electric vehicles, improving efficiency and durability. Addressing Europes strategic dependence One single non-European country now accounts for around 70% of global MMF production, creating critical dependencies for European value chains. This market dominance: Threatens Europes industrial resilience, making the continent vulnerable to supply chain disruptions. Distorts global competition, as massive overcapacities from this non-European country put European manufacturers under intense economic pressure. Jeopardizes EU sustainability goals, as reliance on external suppliers undermines the security of supply for essential materials in wind energy, hydrogen, EVs, and energy storage. A value chain approach is essential to strengthen EU resilience, ensuring that Europe remains competitive and self-sufficient in strategic net-zero technologies. CIRFS calls on the European Commission to take action CIRFS urges the European Commission services to: 1. Recognize MMF as a critical processed material that meets NZIA criteria and underpins key net-zero technologies. 2. Revise the delegated and implementing acts to explicitly include MMF in the annexes listing primarily used components. 3. Address the significant supply chain risk posed by a single non-European countrys dominance, reinforcing EU industrial autonomy. By incorporating MMF into the NZIA framework, the EU can ensure a sustainable, resilient, and competitive industrial ecosystem that fully supports the transition to net-zero while protecting European producers from market distortions.
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Response to Single Market Strategy 2025

31 Jan 2025

CIRFS is the association for Europes 12.3 billion man-made fibres industry. We welcome the upcoming strategy aimed at strengthening the single market. As members of Euratex, we support their contribution to this consultation but would like to highlight two key barriers that we see as particularly problematic for the single market: BARRIER: Harmonization of requirements across Green Deal EU legislations A key challenge is the lack of alignment between EU legal frameworks under the Green Deal, such as the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The absence of clear links between these regulations is leading to duplicative efforts for businesses. Companies emphasize the urgent need for harmonization in several areas to streamline compliance efforts: Standardizing reporting formats and data requirements to ensure consistency and reduce administrative burdens. Aligning how sustainability information is communicated along the B2B value chain, including defining minimum data requirements necessary for legal compliance. Harmonizing audit processes, which currently vary significantly, to reduce the proliferation of redundant reports and audits. Addressing these issues will enhance regulatory clarity, improve efficiency, and facilitate smoother implementation of Green Deal obligations across industries. BARRIER: Waste Shipment Regulation Achieving a circular economy requires the creation of a single market for secondary materials. However, the current Waste Shipment Regulation (WSR) is hindering this transition due to various technical barriers. Simplify the notification process Streamline documentation requirements for waste shipment notifications, including through clear and consistent EU-wide guidance. Adopt a risk-based approach to notification requirements, differentiating between waste destined for disposal and waste that can be recovered and treated as a marketable raw material. Accelerate digitalization by developing an EU-wide digital system for exchanging waste shipment documents. Harmonize financial guarantees and avoid cost duplication Standardize financial guarantee requirements at the EU level to ensure consistency across member states. Develop a harmonized calculation method for financial guarantees that is proportional and risk-based. The method should reflect the actual environmental risks associated with different types of waste. For example, solid plastic waste poses significantly lower environmental risks than liquid plastic waste, and this should be reflected in financial requirements. Allow alternatives to financial guarantees, such as insurance options, to provide flexibility for businesses. Eliminate duplicate financial guarantees, particularly in cases where waste is shipped from an interim to a final recovery facility within the same legal entity. This unnecessary financial burden increases costs without improving environmental protection. Unlock the potential of waste imports into the EU Harmonize contamination thresholds under B3011/EU3011 to facilitate waste imports both from within and outside the EU. The contamination threshold for waste imported from third countries should be aligned with the 6% threshold currently applied within the EU. Enshrine contamination thresholds into EU law to ensure uniform application across member states and prevent disparities resulting from voluntary implementation. Simplify Intra-EU Shipments Broader simplifications are needed to reduce excessive notification requirements, particularly for frequent or routine shipments. Introduce mechanisms similar to export control general authorizations, allowing multiple shipments under a single notification process. By addressing these challenges, the EU can remove unnecessary regulatory barriers, promote the efficient movement of secondary raw materials, and accelerate the transition to a circular economy.
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Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

Response to Environmental claims based on environmental footprint methods

20 Jul 2023

CIRFS is the association for Europes 12 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2022 of ca. 4.4 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality. Concerning the statements on PET bottle-to-fibre recycling in recital 19 of the proposal, CIRFS would like to comment specifically as follows: Although textile-to-textile recycling is the future (alongside bottle-to-bottle recycling), techniques to reach this goal are at an early stage. There are cases where PET bottle-to-bottle recycling is not possible, mainly for reasons of material purity and where PET bottle-to-fibre recycling is a valuable alternative to incineration or landfilling. The sustainability benefits of polyester fibres originating from PET bottles are well documented and measurable (e.g. less energy use than bottle-to-bottle, longer life in textiles than in bottles) and are therefore not misleading. Other recycled materials are being used in a number of industries without being considered downcycling (e.g. waste aluminium cans in cars, glass bottles for non-food uses). Besides, in several Asian countries bottle-to-bottle recycling is not even allowed for food grade end-uses and recycling into fibres provides the necessary outlet for packaging waste. PET bottle-to-fibre should remain an accepted option in this transition phase.
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Response to Net Zero Industry Act

27 Jun 2023

CIRFS welcomes the opportunity to provide feedback on the Net Zero Industry Act (NZIA). Please refer to the attachment for our response. CIRFS is the association for Europes 12 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2022 of ca. 4.4 million tonnes, is the worlds second largest in terms of output and one of the global leaders in terms of innovation and quality.
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Response to Revision of the Union Customs Code

19 Sept 2022

CIRFS believes that non-compliant imports are today more than ever an imminent threat to EU-industry. Unfair competition arises for our industry not only from non-compliant man-made fibres that are directly delivered into the EU but also from all non-compliant products along the downstream value chains, such as automotives or textile, that are manufactured from/with third country fibres and brought into the EU thereafter (e.g. yarns, fabrics, clothes, furniture, airbags, tires, tents etc.). 92% of chemicals that are non-compliant with REACH in consumer products come from outside the EU/European Economic Area (EEA). This is the key finding of Cefic’s analysis of data reported through the EU’s rapid alert system (RAPEX) ‘Safety Gate’. In 2021 the ECHA’s Enforcement Forum found that most inspected products sold online were non-compliant. CIRFS encourages customs and border control officers to take on a proactive role in protecting the environment to ensure safe and fair trade for all. It is necessary to establish an efficient cooperation framework that guarantees compliance of imported goods with environmental and social sustainability rules and enables effective controls (at the border, behind the border and in third countries). CIRFS recommends to also cooperate with EU-Industry and to appoint an external agency that supports authorities concerning the surveillance of non-compliant goods entering the EU (e.g. data collection). Policy measures to be included in a reform of the Customs Union are: Achieve end-to-end supply chain transparency (e.g. digital product passport) to strengthen customs’ ability to root out violative actors, supporting sustainable production methods and leveling the playing field, while allowing legitimate goods to move swiftly and securely across the border. Provide more enforcement flexibility and streamline processes. It is essential to strengthen the provisions on inward processing to avoid circumvention of EU trade defence measures defence measures through re-export. The inward processing regime needs to be improved in terms of transparency. CIRFS believes that customs must prioritize enforcement of environmental laws and controls in conjunction with partner government agencies, enhance supply chain visibility to illuminate environmental risk factors and bolster information sharing with stakeholders to promote coordinated enforcement. Customs authorities should not only assess whether an imported good complies with EU standards, but also support that EU rules equally apply to manufacturing processes in the originating countries.
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

CIRFS welcomes the move towards "One Substance - One Assessment" and supports close cooperation between EU agencies and scientific institutions. A fit-for-purpose "One Substance - One Assessment" approach should lead to the following outcomes. - Increased efficiency and predictability; - Improved consistency of assessments and their results using the same data set; - Improved robustness of assessments; - Involvement of the right expertise in the right place at the right time; - Provision of tailored assessments within the context of specific legislation, where relevant; - Optimal use of resources. Achieving this goal requires action at multiple levels, including: - Close coordination of assessments between the different DGs upstream, scientific committees (including scientific panels), and agencies at the European level; this includes greater coordination of Member States' regulatory initiatives; - Data sharing between committees and agencies; - Application of a single hazard assessment; - Centralizing exposure assessment tools and methodologies on a common platform; - Ensuring tailored risk management; - Increasing transparency of decisions and processes. As CIRFS, we believe that both industry and regulators will benefit from the "one substance, one assessment" approach if it is implemented well. The clarity of the process will increase predictability and help streamline resources on both sides. We support the position paper submitted by Cefic for this consultation.
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Response to Measures to reduce microplastic pollution

17 Jan 2022

CIRFS: European Man-made Fibres Association as member of the Cross Industry Agreement signatories have been working with the European Commission on this topic since 2018. Collectively, their associated memberships, and the community of research organisations and stakeholders that it has created are committed to tackling emissions of microplastics throughout the life cycle of products. As responsible sectors and organisations we welcome any effort that is science and risk-based, realistic, enforceable and proven to provide effective impact. The signatories of the CIA welcome the opportunity to provide feedback on the impact assessment on the proposed measures to reduce the impact of microplastics pollution on the environment (see detailed Joint statement from Cross Industry Agreement Signatories attached). The submission focuses on questions and assumptions that - if not resolved - could potentially render the proposed measures useless or in some cases counterproductive. Common position from signatories of the CIA: The signatories of the Cross Industry Agreement support both policy and legislative measures to reduce the environmental presence and associated risks of unintentionally released microplastics from textiles. However, we emphasise the existence of the knowledge gap that is acknowledged by the European Commission in the call for evidence. For policy measures to be effective we need more data and to build upon the outputs of the work that has occurred to date with the development and certification of a test method. We call on the European Commission to respect the time and effort that has been spent on the development and standardisation of the method within a reasonable timeframe. The existence of this critical first step now puts the industry in a good position, and with appropriate support from the European Commission, able to bridge the knowledge gap and rapidly scale the data required to create meaningful policy measures. As such, we call on the EU: • To support the industry to bridge the research and innovation gap as a priority through the allocation of targeted funding that is cross disciplinary, multi-regional, and multi-sector. • For policy or legislative measures to be based on detailed risk and impact assessments. • For any eventual ecodesign measures to be well-developed and address the challenge in a scientific manner. • For a harmonised approach that does not allow fragmentation at a member state level. • For alignment between policy and legislative initiatives (SPI, CEAP, PEF) that use a common assessment framework where possible.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

IVC and CIRFS welcomes the Commission’s initiative to prepare a Communication on a Policy Framework for BBPs and BDCPs. Given the increasing relevance of biobased plastics (BBP) and biodegradable and compostable plastics (BDCP), the development of standards and criteria concerning sourcing, labelling and use of BBP and BDCP, as well as the definition of terms like 'biobased content' and others, is needed. Considering the potential ecological and economic impacts of the framework, the scope of the corresponding EU Policy Framework should be set clearly and carefully. Besides the two obvious key questions regarding the terms 'biobased' and 'biodegradable', the definition of the term 'plastics' will be crucial. Concerning the latter, we suggest considering and revising the interpretation in the guidelines for the Single-Use Plastics Directive (SUPD). In the SUPD [1], the term 'not chemically modified', as defined in the REACH regulation [2], is used for the definition of the scope of the directive. The SUPD guidelines [3] interpret 'not chemically modified' as follows: "the decision whether a polymer has been chemically modified in its production or not should take into account only the difference between the ingoing and the resulting polymer, disregarding any modifications which might have taken place during production processes [...]". As the objective of the SUPD is to minimize the environmental impact of single-use products, the biodegradability of a material should at least be introduced as a co-criterion. Without its inclusion, biodegradable products made of marginally chemically modified polymers or containing minute amounts of modified polymers, would be classified as plastic and thus be affected by the SUPD and the upcoming policy framework. Furthermore, a threshold in the sense of a de minimis rule for ‘not chemically modified’ polymers should be introduced. A material consisting of a natural ‘not chemically modified’ polymer, by e.g. more than 99%, should not be considered as plastic. In particular, if the material meets all requirements concerning biodegradability in the respective terrestrial or marine environment, the classification of such a product as plastic would not be in line with the SUPD’s objective. Otherwise, products such as bleached cotton or toilet paper, which are containing traces of chemically modified polymers, would also be classified as chemically modified and thus as plastic, although they have been proven environmentally sound. Appropriate requirements and definitions for biodegradability are particularly important in this context. Biodegradability should not be defined in such a way that even a large proportion of natural organic materials (e.g. wool, wood, nutshells, seeds) cannot meet the requirements. Such a restrictive approach will exclude a wide range of potential innovative material solutions and development directions from the beginning. Practically this means, that a man-made material that takes 120 days to degrade by more than 90% in a biodegradation test in the determining environmental compartment is still a very good alternative to materials that take 120 weeks, months or even years. In order to avoid confusion and to ensure a proper framework development process, the question concerning the definition of the term 'plastics' and its interpretation as well as appropriate requirements and definitions for biodegradability should be addressed at an early stage of discussions. As the most coherent approach would be to follow the SUPD, the associated guidelines should first undergo a corresponding revision earlier than planned in 2027, in order to align the definitions with the directive’s objective. Finally, we want to emphasize that the biodegradability is a decisive environmental property. Only when the aforementioned crucial fundamentals are clarified, then one can proceed successfully on the development of a policy framework on BBP and BDCP.
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

3 Mar 2021 · - presentation of the EU-industry of man-made fibres - overcapacities - impact of the EU's Green Deal on the industry

Response to A new Circular Economy Action Plan

16 Jan 2020

The MMF industry has been active on circularity for many years and is not only a frontrunner in this sector worldwide but also inside the textile value chain. CIRFS believes that in order to reach a full circular economy in fibres and textiles the following items have to be highlighted: • Eco-design in view of recycling, allowing to identify the components of the textile will be of the utmost importance, including the necessary standards. • An efficient waste collection and handling system, including the necessary transparency and traceability will be needed. The waste status should be clarified and secondary raw materials that can be used should remain in Europe. • Technology for separating and recycling fibres has to be further developed. Ecological and economic aspects of recycling need to be considered when deciding about the best end-ofwaste option. • The responsibility must be shared by all related stakeholders, globally. Supporting measures from regulating authorities will be important. EPR schemes should be encouraged. • The issue of imported textiles should be addressed so as to determine who owns the endof- life material and who processes it as the secondary material. • The benefits of biodegradable MMFs in the biological cycle of circular economy should be part of the considerations. • A smooth interface with REACH will be essential. Historic waste will need to be dealt with. • Standardization and harmonization of definitions, amongst other of definitions is an indispensable pre-condition of circular economy. • Mutual collaboration, encouragement and support of all stakeholders will be essential elements. • Public and private funding should be envisaged for R&D on all items leading to circular economy.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

5 Feb 2019

European Man-made Fibres Association (CIRFS) welcomes this public consultation under the Better Regulation initiative. CIRFS is the representative of major man-made fibres manufacturers in Europe. For our industry titanium dioxide is the essential pigment and is used as one of the most important delustering agent additives in man-made fibre production. Different amounts of TiO2 are used to gain various characteristics on synthetic fibres in industrial applications. Titanium dioxide is embedded in the polymer matrix and thus not freely available. The proposal for classification and labelling of titanium dioxide is inappropriate from the toxicological and epidemiological perspective. The criteria for classification are not met. Consequently titanium dioxide should not be included in the 14. ATP as it has been proposed by the Germany/the German authorities. The hazard described for titanium dioxide (“general particle effects”) is not specific to the substance itself, but applies to all substances in powder form known as “Poorly Soluble particles with Low Toxicity” (PSLTs). Therefore, any decision taken on titanium dioxide sets a precedent for this entire group of substances. Germany has made the alternative proposal to harmonise the different general dust limits which are currently applied in Europe. This approach addresses effectively and proportionately the potential effects of PSLT substances like titanium dioxide. In addition, such harmonisation would be a great step for European workers health and safety standards. In contrast, the proposed classification of titanium dioxide under CLP would have no direct beneficial effect on the health and safety of workers. In addition, it is highly questionable if the CLP regulation legally allows a classification based on non-substance specific effects. Also, a classification of titanium dioxide would have far-reaching and significant unwanted consequences: For example, every waste with a titanium dioxide content of 1% or more would have to be treated as "hazardous waste”. This would apply to a variety of waste streams, such as plastic waste, construction waste such as old window frames, wallpaper and paint residues, high quality papers, furniture, ceramics, medicines etc. For such waste streams a classification would drastically reduce the options for recycling and increase costs to the economy and consumers. Such classification would also have significant negative effects on food contact materials and toys for example. Conclusion A classification would not contribute to improving the protection of health and environment, while it would have serious and disproportionately problematic effects in almost all legal fields. Consequently it is essential not to include titanium dioxide in the 14. ATP. Instead, initially an overall concept should be developed for the safe handling of PSLT dust. Moreover, a classification under the CLP Regulation would contravene the principle of proportionality enshrined in European law, as such a classification is neither suitable and necessary nor appropriate and thus uncalled for according to Article 37(5) of the CLP Regulation. The alternative proposal to harmonise the different general dust limits currently applied in Europe gives the right answer to the issue at stake and would be a big step for European occupational safety standards. The proposed warning label for liquid and solid mixtures (in Annex II CLP regulation) is misleading, disproportionate and therefore also rejected. For more information, please read the attached uploaded document.
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Response to Restriction of CMR substances in textile articles and clothing for consumer use under REACH

7 Mar 2018

CIRFS European Man-made Fibres Association Feedback on: Restriction of CMR substances in textile articles and clothing for consumer use under REACH CIRFS European Man-made Fibres Association welcome the objectives of the intention for protection of the consumers and environment and appreciates having the chance of comments with this consultation and the earlier chance in Year 2016. CIRFS members continuously support all risk based efforts to improve protection of environment and consumers. Considerable studies and action is taken by members to monitor and improve their products and substances used in their products on these lines of efforts. The improvements and accomplishments in the restriction process since the beginning of the process is acknowledged. Besides feedback given in the previous stages, we have the following points to highlight for clarification or improvement where applicable. Please see the attached file for further support and details on these items. 1. A Clarification is needed on the interpretation of the “homogeneous material” mentioned in the Annex, Appendix 12. The proposed restriction does not define that term. Also within REACH there is no such definition. 2. About the analytical method(s), there is a need to clarify a prescribed method(s) and if the new DIN be referenced. 3. The aprotic solvents NMP, DMAc, DMF are currently under consideration in SVHC list with a limit 1000 ppm under REACH. There is also a limit, hence should not be dealt with twice. 1000 ppm seems more suitable in terms of compliance with SVHC list under REACH. 4. The Commission clarification is needed on how to provide supplier responses to next users in the production chain. Industry is anticipating numerous customer questions about this matter and would like to be in a position to give informed responses. 5. On the drafted Commission Regulation, page 3, item (8) it is mentioned that “Personal protective equipment within the scope of Regulation (EU) 2016/425… should be exempted from the new restriction because of the need for such equipment to fullfil specific requirements in terms of safety and functionality”. The scope of Regulation (EU) 2016/425 applies to PPE (Personal Protective Equipment ), article 2 Scope 1 , but not on PPE , article 2 scope 2 (a)-(e), specifically designed for use by armed forces or in maintenance of law and order, …”. It is important to include all PPE in the Commission Regulation under this item. 6. Protective apparel are used by consumers in a very small scale. Heat and cut resistant fibres are used 99% for professional uses like fire fighters, military and police, law and order employees and some bodyguards. The discussion on DMAc content in final product has been open and intense since DMAc became a SVHC. The reaction in the market place had been very strong. 7. Applying the definition as in “textiles other than clothing which, under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing” could be challenging and open to diverging interpretations. For example, a backpack could potentially fall under this category, or not, depending on the interpretation. 8. The timing proposed for implementation is challenging. Based on the experiences (with NMP and DMAc), it is very hard to believe that reliable testing for all substances will be made available in such short time. Measuring 1 ppm may be easy but the difficulty is in the extracting of the substance or the mixture into a test bed for proper measurement and calculation of content. The difficulty and experienced by industry is that bad testing typically gives lower values leading to non-detect or below threshold though the substance is present and above.
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Response to Carbon Leakage List 2021 - 2030

13 Nov 2017

The feedback is given in the attached file.
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