OpenLobby.EU
Explore

Concawe

Concawe

Concawe was established in 1963 by a small group of leading oil companies to carry out research on environmental issues relevant to the oil industry.

Lobbying Activity

Meeting with Florina-Andreea Pantazi (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and FuelsEurope and International Association of Oil Gas Producers Europe

22 Jan 2026 · REACH Universal PFAS Restriction

Meeting with Beatrice Coda (Head of Unit Research and Innovation) and FuelsEurope

16 May 2025 · Transition of Liquid Fuels and Products

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and FuelsEurope

28 Jan 2025 · Renewable energy, renewable fuels, biomass, climate

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

19 Apr 2024 · Lobby Meeting

Meeting with Alexandr Vondra (Member of the European Parliament, Rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

21 Mar 2023 · EURO 7

Response to Amendment of Regulation 440/2008 (TMR) – 9th ATP / or possibly change to listing of references

6 Apr 2022

Concawe appreciates the efforts to clarify permissible test methods to fill information requirements and the encouragement of NAMs. One concern we have is whether information generated using to-be-deleted methods, either from prior testing or from ongoing/ proposed testing, would still be valid for filling information requirements. We would like to avoid any duplicate testing and preserve the utility of reliable existing animal test data.
Read full response

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

Dear Sir/Madame, Please see Concawe (Scientific Division of European Petroleum Refiners Association) feedback in the attached pdf-document. Best regards, Markus Hjort
Read full response

Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

19 Jul 2021

Thank you for the opportunity to comment on the proposed changes to Annexes VI to X. Concawe believes it is important to have a transparent process in which our experts can contribute to increased clarity and consistency of the proposed revisions. We are pleased to see that some of the comments have been taken into consideration in the changes made since the original proposals were first circulated. While some of our original concerns were addressed, we strongly urge the Commission to consider the attached Concawe comments to ensure the workability of the proposed amendments to Annexes VI to X of REACH. These areas of suggested change are of particular concern: • Annex VI 2.3.2: Further clarity is provided by a requirement for naming of “identified” constituents present in concentrations below 10% instead on “known” constituents • Annex VI 2.3.5: The provision of qualitative analytical data for the identification of a substance should be relevant. Spectral data does not discriminate between most UVCB petroleum substances • Annex VII 8.4: The COM modified text proposes for the Ames test (gene mutations in bacterial cells), a follow-up study in section 8.4.2 of Annex VIII which is for cytogenetic effects. This appears to be more than a clarification, rather an additional endpoint that initially appears in Annex VIII and is not consistent with later Annexes • Annex VIII 8.7.1: As a EOGRTS involves considerable investment and animal usage, Concawe suggests that justification for this test should require more than a QSAR • Annex VIII 9.1 & 9.1.3: Further clarification is necessary as to the requirement for short-term toxicity testing • Annex VIII 9.2: The COM proposed modified text duplicates Annex requirements and is ambiguous in its references; Concawe proposes a further clarification • Annex VIII 9.3: There is currently no text in column 2 of section 9.3. under Annex VIII. The amendment proposed therefore goes beyond the aim of this Regulation to provide more clarity on the obligations of registrants regarding the submission of information • Annex IX 9.1: Concawe proposes to clarify by including rules for adaptation for long-term toxicity to fish and invertebrate testing Further detailed comments are summarized in the attached table, which are separated by Annex. We want to emphasise that we are available for any further information and look forward to working together with legislators to shape the revision of these REACH Annexes.
Read full response

Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals

16 Nov 2020

Thank you for the opportunity to comment on the proposed Action 1 changes to several of the REACH Annexes. There are extensive changes proposed to Annexes that are key to the testing (Annexes VII-X) of registered substances as well as the options for adapting these standard requirements (Annex XI). We believe it is important to have a transparent process in which our experts can contribute to increased clarity and consistency of the proposed adaptations. We are pleased to see that some of the comments from various parties have been taken into consideration in the changes made since the original proposals were first circulated. These have gone a long way to addressing some of our original concerns, but we believe there is a need for further improvement, with some of the following areas of suggested change being of particular concern: • As a general concern, we regret that this Commission proposal for the revision of REACH Annexes VII – XI does not take the opportunity to introduce New Approach Methodologies as a way to reduce animal testing. This will be a necessary first step to work towards regulatory acceptance of alternatives to animal tests • Annex VII – X, separation of hazard and risk; text inserted to discuss flexibility of study design states that this “shall ensure that the data generated are adequate for hazard and risk assessment.“ Whilst this would be ideal, it is not always possible to address both hazard identification and risk assessment in the same study • Annex XI section 1.1: data generated before 2008 cannot just be disregarded, if proven relevant and accurate by the registrant. Disregarding historical data goes against the aim of REACH to reduce animal testing as it could lead to registrants having to carry-out new animal tests • Carcinogenicity: Concawe disagrees with the link between mutagenicity and genotox carcinogens, as not all genotoxic agents are a mutagen (although the reverse is correct). Therefore, there may be genoxic carcinogens, not classified as mutagens, which would waive further higher tier testing (again, the proposed change is in contrast with the aim to minimize animal testing as more high animal consuming testing could be required in case the waiver for reprotoxicity does not apply anymore to CAT 1 carcinogens). Further detailed comments are summarized in the attached table, which are separated by Annex VI, Annex VII-X (separate for environmental and health aspects) and Annex XI – a column with comments has been added to each of the four tables. We want to emphasise that we are available for any further information and look forward to working together with legislators to shape the revision of these REACH Annexes. Sincerely, Hans Ketelslegers, REACH Director (on behalf of the Concawe experts)
Read full response

Meeting with Vladimir Sucha (Director-General Joint Research Centre)

5 May 2017 · Introduction of the new Director-General of Concawe, Mr Cooper, and the opportunity of reaffirming the good working relationship between JRC and Concawe and discuss ongoing and potential future research activities

Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas), Robert Schröder (Cabinet of Commissioner Carlos Moedas)

3 Apr 2017 · Research on energy issues