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Deutsche Bauchemie e.V.

DBC

Die Deutsche Bauchemie (German Construction Chemicals Industry Association) vertritt die Interessen von rund 140 Mitgliedsunternehmen der bauchemischen Industrie - Rohstoffhersteller und Formulierer.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

The upcoming Circular Economy Act (CEA) aims to put resource efficiency and waste reduction at the centre of sustainable production and consumption across the EU to address the high dependency on imported (critical) raw materials, stagnating circularity rates and single market barriers for recycled materials and recovered waste. To succeed, however, it is essential to recognise the substantial economic, regulatory, and technological obstacles that must be overcome by any legislative framework designed to accelerate the circular transition of the construction sector. Such a framework must safeguard the industry´s competitiveness, economic viability, and strategic autonomy. In this context, the renovation and repair of existing structures using advanced construction chemical products plays a vital role in advancing a circular and sustainable built environment. These technologies significantly extend the service life of buildings and infrastructure, thereby avoiding unnecessary demolition, facilitate material reuse. This not only reduces CDW but also preserves embodied energy and lowers carbon emissions strategically contributing to the circular economywhat need not be torn down, should not be rebuilt. Moreover, construction chemicals support the integration of recycled content, industrial by-products, and secondary raw materials. Against this backdrop, the German Construction Chemicals Industry Association (Deutsche Bauchemie) recognizes the CEA as a major landmark initiative that once implemented - has the potential to reshape the trajectory of Europe´s economy. In support of the CEA, we would like to recommend a number of policy measures focusing on the construction sector which can be found in the attached document.
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Response to European strategy for housing construction

17 Sept 2025

Rising housing costs and elevated construction and renovation expenses increasingly pose financial strain on European citizens, particularly affecting vulnerable households, while at the same time hampering the necessary modernization of Europes infrastructure. Consequently, the construction of affordable and sustainable high-quality housing stock has become a matter of urgency throughout Europe both in urban and rural areas a challenge that cannot be met without efficient and innovative construction solutions. According to housing demand forecasts, by 2030 an annual construction demand for around 320,000 new residential units is expected in Germany. As Europe strives to address the social and environmental dimension of the residential building stock crisis and seeks to close the housing supply-demand gap via initiatives, such as the EU Renovation Wave Strategy under the EU Green Deal, it is crucial to recognize the transformative contribution construction chemicals can make in achieving the targets of a European Strategy for Housing Construction. It should be emphasized that affordable housing construction is not only determined by the functional building elements themselves, but also by the planning of building structures, and by using materials wisely in the appropriate areas of application. In that regard, advanced construction chemicals offer an essential toolkit both for the development of cost-efficient new builds and the renovation of existing residential building inventory. They play a vital role when it comes to accelerating construction times, reducing construction-related costs and resource consumption, optimising energy-efficiency or extending the lifespan of buildings. Overall, the potential construction chemicals have to offer in support of cost-efficient, scalable and sustainable housing construction spans across a vast range of applications, particularly when aligned with stringent health and safety standards. As such, the German Construction Chemicals Industry Association (Deutsche Bauchemie) welcomes the EU Commissions ambitious initiative on an Affordable Housing Plan and a European Strategy for Housing Construction. Given the pivotal role of construction chemicals in tackling the ever-worsening housing shortage, coordinated policy efforts focusing on stabilizing construction costs while accelerating the green transformation of the built environment are essential. It is, however, also imperative to note that any upcoming EU Strategy for Housing Construction must be pragmatic and should be tailored to the respective needs of its end recipients to ensure easy accessibility without imposing additional administrative complexity on both EU citizens and industry. In our attached position paper, we recommend a set of targeted actions to facilitate its implementation while increasing the competitiveness of the construction chemicals sector, allowing stakeholders (i.e. construction companies, manufacturers, planners, installers, etc.) to effectively fulfill their strategic role and contribute to the development of affordable residential infrastructure. Construction chemicals are not just auxiliary materials they are powerful instruments that can accelerate the efficient delivery of affordable, high-quality and energy-performing housing across the EU and therefore purposefully contribute towards achieving the technical, social and environmental goals of the EU Housing Strategy.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

18 Aug 2025

The German Construction Chemicals Industry Association supports the EU Commission´s efforts to establish mass balance (MB) accounting rules by enabling chemical recycling pathways under the draft SUPD IA. However, we would like to draw your attention to the fact that not all industrial branches and value chains can currently benefit from dedicated (segregated) production systems to answer customer demand for products made with alternative feedstocks, which hampers the acceleration of the circular economy in a unilateral way. A striking example is the ongoing debate on the acceptance of MB chain-of-custody (CoC) in the construction chemicals sector, especially the recognition of MB credit method to substitute fossil resources with bio-based or recycled feedstocks in Type III Environmental Product Declarations (EPDs) according to ISO 14025 and in the underlying LCA calculation method based on EN 15804. MB is also relevant to other industries and pertinent to any policy legislating alternative feedstocks or other CoC. Thus, a horizontal recognition of MB methods across sectors shall be the target in Europe and should be equally considered for the construction industry. In this regard, the proposed SUPD IA does not sufficiently consider the full potential of established industry processes and fails to reflect broader applications, which undermines the role of recycled feedstocks in the material route (through co-processing) and its contribution towards recycled content targets. The restrictions related to the recycled content eligibility threaten the economic viability of using waste-derived feedstock and deter MB from being the lever necessary for the chemical industrys transition. A scenario without horizontal recognition of MB credit method, i.e. sector-specific regulations that allow the method in some sectors and restrict or forbid it in others, could ultimately lead to barriers of trade. In such a scenario, the use of alternative feedstocks in some industrial sectors, which allow credit MB, would be advantageous over other ones, where the principle is not recognised. Consequently, circular material flows would be unilaterally carried over artificially to sectors where MB credit method is allowed, while at the same time creating discrepancies between methods or - worse still - getting lost along the material flow route in sectors where it is not recognised. Contrary to the scenario introduced in SUPD IA, establishing a horizontal guideline for MB CoC models would, therefore, facilitate the effective cross-market integration of bio-based and recycled materials, enable optimization through market dynamics and support sustainability objectives such as enhanced circularity and economic efficiency. The MB credit method is a key enabler to process sustainable feedstocks together with fossil ones in existing complex chemical production networks accelerating the transition to a circular economy without compromising end-product quality and performance. The principle of the MB credit method is already established in other sectors like the wood industry applying 3rd party certification schemes, therefore, the acceptance of MB accounting in the proposed SUPD IA could be a starting point for its recognition within construction. Its acceptance could boost the supply of more sustainable construction products while utilizing existing infrastructure, making it a central driver for an immediate and smooth transition to circular models with direct environmental benefits at limited costs for society and, ultimately, contributing to the Green Transition of the construction sector by aligning with the Green Deal ambitions. It is important, however, to point out that, in order to allow downstream users to source and benefit from MB credit method and to foster a fair competitive environment and level playing field, the approach should be accepted horizontally with accounting rules tailored to the respective alternative feedstocks and industries.
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Meeting with Christian Doleschal (Member of the European Parliament, Rapporteur) and DIN Deutsches Institut für Normung e. V. and

7 Dec 2023 · AK Bau

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

16 Nov 2023

Deutsche Bauchemie is the German Industry Association for Construction Chemicals. Regarding DWD, our focus is mainly on cementitious materials admixtures, organic additions, release and curing agents as well as sealants (as part of organic materials) in contact with drinking water. Since the concept of the European positives list for drinking water materials is used for the first time, definitions should be clearly set and be unambiguously. The definitions should be the same in the whole text passages as well as in the Annexes (the same is valid for the guidance documents). Examples: - A concrete definition is missing when a polymer is an organic addition or an admixture. - It is not clear, what is the definition of an additive in document 2.IA, Annexes (Positive List) rsp. interpretation of polymers with listing of monomers? See Annex 1, explanation for table 1 and 2, note 2 (document 2.IA, Annexes). - It is not clear, if the positive list of starting substances for organic materials (2.IA, Annex 1, table 1 and 2) can always be applied for cementitious applications? - How would duplicates be handled? Or how is the procedure if there are different limit values? References can be found in DWD 2020/2184 itself, Annex V, table 1, as well as in the Annexes of 2.IA, Annex 3, explanations for table 1, rsp. table 1, row 5 organic additions - If one substance is authorized for one application, is it also authorized for another application? Or only for this one application? For this, more precise definitions of the whole terminology, differentiations/explanation and examples would be helpful. - Shall NIAS be evaluated on the level of the final product rsp. be listed? For example in the positive lists initiators are listed, but what about the degradation products?
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

Summary: Deutsche Bauchemie is the German Industry Association for Construction Chemicals. Regarding DWD our focus is mainly on cementitious materials admixtures, organic additions, release and curing agents as well as sealants (as part of organic materials) in contact with drinking water. In the field of drinking water materials, our members are mainly downstream users. We welcome the opportunity to comment. We are very concerned that the Directive (EU) 2020/2184 (DWD) and its implementation/delegated acts (IA/DA) do not provide the protection of data, CBI and investment of dossier submitters. That is a point that urgently needs to be changed or added. Otherwise, each subsequent user can benefit from the listing in the positive list at no or low additional cost. Details: While applicants and submitters of dossiers are requested to invest large amount of money and resources in compilation of a dossier, any subsequent user can make use of the resulting positive list for very low costs. This cannot be the intention of DWD (IA/DA). We urgently ask the EU-Commission to ensure that investment and CBI of dossier applications are fully protected. There is concern, that we might be dealing with a shortage of materials for drinking water from 2028 onwards. Since there is no obligation of a REACH registrant to share data for the purpose of DW-positive-listing, any existing data must be purchased from REACH registrants. DWD and IA obliged dossier submitters to provide analytical data on substances and to assess any migrating constituent with toxicological data. Just the analytical data requirement according to suggestions from the guidance document can easily reach costs of > 100.000 . Although there are numerous references to REACH and BPR in various chapters of DWD and IA/DA, the most important part of those regulations - namely the principle of no data no market with obligation to share costs and data, was unfortunately not integrated in DWD and IA/DA. This is not acceptable in todays challenging markets. Nobody will invest half a million for a dossier, if any subsequent user can get the investment for free. We strongly recommend that the Commission ensures that a positive list is only valid for a listed group of dossier applicants (single legal entity or consortium or a co-submitting legal entity), with established cost sharing rules. The listing on the positive list(s) should not be valid for legal entities not being member of this group of dossier submitters. Under REACH it was proven that such provisions can easily be established and REACH registrants have sufficient experience to form consortia and establish data- and cost-sharing agreements.
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Response to Delegated Regulation under the Construction Products Regulation (EU) No 305/2011 (wood panelling)

22 May 2023

Position of Deutsche Bauchemie on Commission Delegated Regulation on the conditions for classification, without testing, of solid wood panelling and cladding with regard to their reaction to fire and amending Decision 2006/213/EC: s. attached file
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

20 Mar 2023

The attached position paper of Deutsche Bauchemie comments on the new requirements for the layout of CLP labels and the application of fold-out labels: The proposed provisions on the layout of the CLP label would lead to an immense burden, considerably restrict the urgently needed flexibility, whereas they are not necessary for a functioning of hazard communication. To promote the free trade of goods in Europe and to maintain the competitiveness of European manufacturers of mixtures, the excessive requirements should be dropped, and the existing regulations should continue to apply unchanged in the future. Regarding fold-out labels, it is essential that the order of the languages on the fold-out label of a product is independent of the Member State in which the product is placed on the market. Otherwise, the advantages of a multilingual fold-out label would be completely nullified. Requirements on the order of languages depending on the Member State would have the same negative consequences as the introduction of separate language versions for each Member State. In order to increase the clarity of the new rules on fold-out labels and to ensure coherence within the Regulation, it would be beneficial to clarify the rules on the application of fold-out labels in this sense and to include additional references to fold-out labels in Articles 17 and 31. For further infomration: DBC position paper - English: https://deutsche-bauchemie.com/positionpapers/mar-2023-position-paper-for-the-revision-of-the-clp-regulation
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Response to Review of the Construction Products Regulation

19 May 2022

The Construction Products Regulation Revision is key: The well-functioning European Single Market for construction products is a major prerequisite to promote affordable construction and renovation activities in order to enable an effective fight against climate change. A European renovation wave can only contribute successfully towards a more climate-neutral building stock if it remains affordable and enables as many Europeans as possible to invest in our future. Please find attached our feedback on the Commission proposal for the CPR revision.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

25 May 2021

Deutsche Bauchemie (DBC) supports the Green Deal goals as well as the transition towards a more sustainable society. Construction chemical products are decisive: Modern concrete admixtures reduce the amount of cement used in concrete and thus contribute to the reduction of CO2-emissions. Sealants ensure the airtightness of buildings and help save energy. Concrete repair systems contribute to the extension of the service life of buildings and structures. The construction chemicals industry is highly regulated in the EU. To ensure that the sector can actively contribute to the Green Deal, the planned changes of the legal framework should be proportionate, targeted, and only made if they are essential to achieve the objectives. The competitiveness of the European economy and European jobs must be kept in mind. Please find attached the statement of DBC on the following proposed amendments to the REACH regulation: 1) Expansion of the "generic approach to risk management" 2) Concept of "essential uses" 3) Introduction of a Mixture Assessment Factor (MAF) 4) Registration requirements for certain polymers DBC statement: https://deutsche-bauchemie.de/fileadmin/user_upload/IIA_REACH-Review_DBC-Position_EN_2021-05-17.pdf
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

Deutsche Bauchemie fully supports the aim to provide consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions. As a sector, we firmly condemn any misleading claims and “greenwashing”. As a basis for achieving these goals, it is useful and necessary to create a consistent evaluation framework. However, the focus on only one single method for all sectors is problematic. When it comes to the construction sector, the assessment regarding the sustainability of alternative solutions can only be meaningfully carried out on building level and not on product level. Within the construction sector, the increasing need for reliable information was met with the development of Environmental Product Declarations according to EN 15804. EPDs according to EN 15804 have been established in the construction sector for years as a scientifically sound standardized method. The EN 15804 was recently revised according to a mandate of the European Commission, whereby the EN 15804 was as far as possible aligned to the PEF methodology. Any remaining differences between the revised EN 15804 and PEF are due to the sector-specific conditions in the construction sector. Therefore, EPDs according EN 15804 should be accepted as the PEF approach for construction products. An EPD provides a credible, product related set of data in a standardised format. This set of data, which is verified by third parties, is then used to perform and assess the life cycle assessment of a building. There is no need to create additional legislation for the environmental information of construction products. BRW 7 of the Construction Products Regulation already addresses these aspects and only needs to be implemented. The upcoming revision of the construction products regulation offers a good opportunity to drive the implementation forward. Deutsche Bauchemie e.V.
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Response to Review of the Construction Products Regulation

9 Jul 2020

The future CPR should: 1) Fully keep up, further develop and optimise the internal market for construction products and its advantages. Irrespective of the complex division of competences between the Member States and the European level, the Construction Products Regulation (CPR) has brought about a single market “light” which benefits manufacturers: Instead of 27 different test methods for one essential characteristic, now one test is sufficient. This avoids unnecessary costs and increases the pan-European product range. The thus created “common European language” forms a central nucleus to which manufacturers, users and national regulators refer. The European single market must not be put at risk or reduced by limiting the scope of the CPR and its fundamental principles. 2) Maintain the strong role of harmonised CEN standardisation and ensure the technical quality of standards through the necessary participation of all interested parties. Harmonised standardisation can work! It brings together the regulatory requirements and the prerequisite technical expertise in an optimal way. Complete standardisation requests that leave no gaps as well as clear-cut guidance and criteria for the development of harmonised standards are essential prerequisites for the smooth functioning of harmonised standardisation. 3) Implement a harmonised method to determine and communicate the environmental impacts (LCA) of construction products, using existing methods that have proven their worth. (EPD according to EN 15804). Voluntary information on environmental impacts of construction products has long been established in the construction sector. An increasing need for regulation arises under the Green Deal and national activities. The CPR review should be used to introduce one harmonised method for determining and communicating the environ¬mental impacts of construction products. In this exercise, it should be resorted to well-proven methods and instruments (e.g. environmental product declaration/EPD according to EN 15804) to avoid unnecessary cost and work. The recent adaptation of EN 15804 to the product environmental footprint (PEF) methodology provides a suitable basis.   In the meantime: it is urgent to find a timely solution to the current problems in harmonised CEN standardisation and make adaptations to technical progress in regular intervals The Green Deal announced a renovation wave which now has a central role in the EU Commission’s COVID-19 recovery plan too. A functioning single market and functioning harmonised standardisation are key for a socially acceptable roll out and for implementing it in due course. Therefore, it is essential to find starting points for solutions under the existing CPR and not to delay this effort to a reviewed regulation in a few years’ time.
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