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Dow Europe GmbH

Dow

Dow is one of the world's leading materials science companies, serving customers in packaging, infrastructure, mobility and consumer applications.

Lobbying Activity

Meeting with Léon Delvaux (Director Trade)

16 Jan 2026 · Global and European situation of chemical industries

Meeting with Florina-Andreea Pantazi (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 Nov 2025 · REACH Revision

Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and

6 Nov 2025 · Challenges and needs across the value chain for advancing safer and more sustainable chemistry

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union)

4 Nov 2025 · Meeting with Dow

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

8 Oct 2025 · To discuss ongoing simplification files on the agenda, including the Environment Omnibus and REACH

Dow demands mechanism to delay EU 2040 climate targets

15 Sept 2025
Topic — The initiative amends the European Climate Law to include a new 2040 climate target.
Message — Dow requests a binding mechanism to postpone the 2040 target unless competitive energy and infrastructure are guaranteed. They also seek to protect free emission allowances and expand compensation for indirect costs.123
Why — Reducing carbon costs would improve Dow's global competitiveness and prevent the closure of European plants.45
Impact — Postponing climate targets could undermine the EU's goal of achieving climate neutrality by 2050.6
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Meeting with Jens Geier (Member of the European Parliament)

2 Sept 2025 · Exchange on the Chemicals Action Plan

Meeting with Ditte Juul-Joergensen (Director-General Energy)

18 Jul 2025 · Competitiveness, chemicals industry

Meeting with Auke Zijlstra (Member of the European Parliament)

17 Jul 2025 · Industrial development

Meeting with Letizia Moratti (Member of the European Parliament) and Johnson Johnson

16 Jul 2025 · Industrial Policy

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

2 Jul 2025 · Chemical industry

Meeting with Manuela Ripa (Member of the European Parliament) and Johnson Johnson and

26 Jun 2025 · REACH Reform

Meeting with Pietro Fiocchi (Member of the European Parliament)

26 Jun 2025 · tematiche ambientali

Meeting with Ana Vasconcelos (Member of the European Parliament)

12 Jun 2025 · Renewable Fuels of Non-Biological Origin

Meeting with Paulo Cunha (Member of the European Parliament)

12 Jun 2025 · RED III Transposition

Meeting with Stefan Leiner (Head of Unit Environment)

23 May 2025 · Exchange of views on challenges in permitting, development of BREFs, applicability of BAT conclusions and hydrogen combustion

Meeting with Ursula von der Leyen (President)

21 May 2025 · Exchange of views on the chemical sector in Europe and globally

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

20 May 2025 · Chemicals regulation

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

15 May 2025 · Chemicals

Meeting with Pietro Moretto (Head of Unit Joint Research Centre)

9 Apr 2025 · Carbon accounting methodologies

Meeting with Oliver Schenk (Member of the European Parliament)

26 Mar 2025 · Chemische Industrie in Europa

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

24 Mar 2025 · Exchange of view about the implementation of the Industrial Emissions Directive (IED), Single-Use Plastic Directive, Eco-Design for Sustainable Products Regulation (ESPR) and End-of-Waste Criteria.

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

20 Mar 2025 · on decarbonization

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

19 Mar 2025 · Chemicals Industry Package, revision of the REACH regulation, chemicals regulation

Meeting with Dimitris Tsiodras (Member of the European Parliament)

19 Mar 2025 · Discussion on REACH

Meeting with Martin Hojsík (Member of the European Parliament) and Kemira Oyj and

13 Mar 2025 · Chemical policies, REACH

Meeting with Kurt Vandenberghe (Director-General Climate Action)

7 Mar 2025 · Industrial decarbonization in Europe

Meeting with Mariateresa Vivaldini (Member of the European Parliament)

6 Mar 2025 · Meeting conoscitivo

Meeting with Oliver Schenk (Member of the European Parliament) and CEMEX, S.A.B. de C.V. and Fels-Werke

3 Mar 2025 · Chemical industry in the EU

Response to List of net-zero technology final products and their main specific components

19 Feb 2025

Dow is a material science company with a significant industrial production footprint in Europe, manufacturing materials for the building & construction, automotive, packaging and multiple other sectors. Dow provides solutions to enhance the performance, durability, and efficiency of infrastructures including net-zero technologies in scope of the Net-Zero Industry Act (renewable energies, energy storage, wires and cables): https://www.dow.com/en-us/market/mkt-power-telecom.html Looking at the proposed annex, we suggest adding PV encapsulants and PV adhesives and sealants for Solar photovoltaic (PV) systems: - PV Encapsulant films are formulated for photovoltaic module encapsulant applications. They provide transparency and protection for the solar cells. They are designed for this specific application. To the best of our knowledge, they are rarely used in other applications. - PV Sealants and adhesives deliver durability against environmental conditions for frame sealing, rail bonding, junction box bonding and building integrated photovoltaics installation materials. PV sealants are labeled as PV sealants, get a specific certification, and get locked in production processes once qualified. To the best of our knowledge, they are never used in other applications. Our international experience shows the contrasting impact regulation can have on business when certain components are excluded (e.g. PV encapsulants and adhesives and sealants from the US IRA) or included (e.g. Turkey).
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

Dow is a material science company with a significant industrial production footprint in Europe, manufacturing materials for the building & construction, automotive, packaging and multiple other sectors. Dow provides solutions to enhance the performance, durability, and efficiency of infrastructures including net-zero technologies in scope of the Net-Zero Industry Act (renewable energies, energy storage, wires and cables): https://www.dow.com/en-us/market/mkt-power-telecom.html Looking at the proposed annex, we welcome the inclusion of PV encapsulants for PV technologies but are concerned that PV adhesives and sealants are not included in the list. We have noted other components both small in value and weight that are included so it would make sense to extend the list. Our international experience shows the contrasting impact regulation can have on business when certain components are excluded (e.g. PV encapsulants and adhesives and sealants from the US IRA) or included (e.g. Turkey). PV Sealants and adhesives deliver durability against environmental conditions for frame sealing, rail bonding, junction box bonding and building integrated photovoltaics installation materials. PV sealants are labeled as PV sealants, get a specific certification, and get locked in production processes once qualified. Similarly, we suggest adding Protective Coatings (used in: Digester/Tanks of Biogas); Cable Protection and Buoyancy Modules (used in Electricity Grids); Waste Heat Recovery Units and Organic Rankine Cycles (ORC units) (under Energy system-related energy efficiency technologies). More generally, Dow strongly supports an upstream vertical integration of the manufacturing materials and intermediates of the components and final products listed in the draft annex. The eligibility of local production would help mitigate the risk of importing from third countries and reinforce the whole value chain in Europe. We would like to highlight the following examples from the materials we manufacture for our customers: Lubricants into Gearboxes of Wind Turbines; Heat Transfer Fluids into Heat Pumps, CSP Line Receivers, Heat Exchanger Units of Biomass Boilers and Geothermal systems; Amine Based Solvents in Sustainable biogas and biomethane technologies, Sustainable bio-methane technologies, Sustainable biomethane plants; Amines and Solvents in Carbon Capture technologies. If you go further upstream, chlorine for instance is ultimately required to make allyl chloride which is needed for epoxy resins to manufacture wind turbine components; the new extraction process for battery grade lithium will require vast quantities of caustic soda; polyethylene goes into cable isolation. For reference see the thorough answer from Cefic about materials and components to be included.
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Meeting with Radan Kanev (Member of the European Parliament) and Orgalim – Europe's Technology Industries and

28 Jan 2025 · European Forum for Manufacturing Dinner- Decarbonisation through a technology neutral approach

Meeting with Dan Jørgensen (Commissioner) and

23 Jan 2025 · Dialogue to address the competitive landscape of clean electrons and how power systems evolve to accommodate growing demand (closed session)

Meeting with Paul Speight (Head of Unit Environment)

21 Jan 2025 · REACH revision, chemicals regulation

Meeting with Christian Ehler (Member of the European Parliament) and Deutsche Industrie- und Handelskammer

14 Jan 2025 · European Industrial Policy

Meeting with Oliver Schenk (Member of the European Parliament)

14 Jan 2025 · Chemical industry in the EU

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

18 Dec 2024 · Physical meeting - Exchange of views on CBAM

Meeting with Bernd Lange (Member of the European Parliament, Committee chair)

26 Aug 2024 · General Exchange of View

Meeting with Maroš Šefčovič (Executive Vice-President) and BASF SE and

21 Apr 2024 · Exchange of views on the Global Plastics Treaty

Meeting with Peter Liese (Member of the European Parliament) and Verband der Chemischen Industrie e.V. and EVONIK INDUSTRIES AG

16 Apr 2024 · Various

Dow Europe calls for flexibility in EU emissions rules

22 Dec 2023
Topic — The Commission is revising free allocation rules for the EU emissions trading system.
Message — Dow supports a de-minimis rule to prevent small units from triggering site-wide penalties. They request flexibility for milestones depending on factors not under the operators' control.12
Why — These adjustments prevent Dow from losing free allowances due to external infrastructure or energy constraints.3
Impact — Public transparency is reduced if company emission forecasts and climate strategies remain strictly confidential.4
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

12 Sept 2023 · Dow sharing their concerns regarding silicone intermediates

Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič), Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and

11 Sept 2023 · Restriction proposal on silicon

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Sept 2023 · REACH, Stockholm Convention

Dow Europe warns hydrogen CBAM rules stall decarbonization plans

11 Jul 2023
Topic — The consultation addresses reporting requirements for the EU's new Carbon Border Adjustment Mechanism.
Message — Dow requests excluding hydrogen produced from industrial residual gases from the new carbon border rules. They want the regulation to mirror existing exemptions for hydrogen used to replace specific industrial gases.12
Why — Exempting circular hydrogen would restore the financial viability of Dow's major European decarbonization projects.34
Impact — European climate targets may suffer if industrial players shift their green investments outside Europe.5
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

26 Jun 2023 · Physical meeting - Exchange on the CBAM

Meeting with Thierry Breton (Commissioner) and

26 Jun 2023 · Overview of chemicals industry situation, transition pathway for chemicals industry, REACH revision

Dow Urges EU to Include Chemicals in Decarbonization Funding

23 Jun 2023
Topic — This consultation addresses the proposed Net Zero Industry Act for clean technology manufacturing.
Message — Dow requests extending the scope of the act to include upstream chemicals and carbon capture technologies. They advocate for supporting industrial decarbonization and streamlining permitting processes for large-scale manufacturing projects.123
Why — The changes would make their European decarbonization investments more competitive against projects receiving US subsidies.45
Impact — European industry risks strategic dependence on foreign imports for critical clean technology components.6
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

22 Jun 2023 · will follow

Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis), Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis) and

5 Jun 2023 · Trade & Technology Council, Global Steel and Aluminum Arrangement, Critical Minerals Agreement

Meeting with Danuta Maria Hübner (Member of the European Parliament)

5 Jun 2023 · EU-US trade relations

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur) and 3M and

21 Apr 2023 · Classification, Labelling and Packaging Regulation

Meeting with Mohammed Chahim (Member of the European Parliament, Rapporteur)

30 Mar 2023 · Hydrogen and CBAM

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

14 Mar 2023 · Decarbonisation

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Danone and

10 Mar 2023 · PPWR

Meeting with Deirdre O’Hea (Cabinet of Commissioner Mairead Mcguinness)

1 Mar 2023 · Financial education for women

Meeting with Martin Hojsík (Member of the European Parliament) and Nestlé S.A. and

7 Feb 2023 · Chemical recycling

Meeting with Martin Hojsík (Member of the European Parliament)

24 Jan 2023 · Chemical policy, REACH, CLP

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

8 Dec 2022 · Exchange on various carbon pricing schemes and CBAM

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Nov 2022 · Carbon Border Adjustment Mechanism (CBAM), Emissions Trading System (ETS)

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

27 Sept 2022 · US Climate policy and carbon pricing

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

27 Sept 2022 · Physical meeting - Exchange on US and EU strategies for carbon pricing

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

13 Jul 2022 · To exchange views on the Chemicals Strategy for Sustainability (CSS)

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and Unilever and

12 Jul 2022 · Packaging and Packaging Waste Directive

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 May 2022 · - State of play on Carbon Border Adjustment Mechanism - Transition Pathway Initiative on chemicals - Future of hydrogen market in Europe

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

21 Apr 2022 · Hydrogen Strategy

Meeting with Ditte Juul-Joergensen (Director-General Energy) and ExxonMobil Petroleum Chemical and

20 Apr 2022 · US-EU Task Force Convening: Security of Supply. Sempra, Venture Global, Glenfarne and Freeport also participated.

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

8 Feb 2022 · Decarbonisation of the chemical sector

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

You will find in the enclosed file the detailed feedback from Dow. Dow is an American multinational chemical company, among the three largest chemical producers in the world. Dow manufactures plastics, industrial intermediates, coatings and silicones to deliver products and solutions for its customers in various market segments, such as packaging, infrastructure, mobility and consumer care. Our key messages for the RED III proposal are the following: - A binding 50% target of RFNBOs for industrial hydrogen use by 2030 is not realistic and would threaten Dow’s decarbonization plans (e.g., over 40% emission reduction already in Dow’s Terneuzen site (NL) by 2030). - Hydrogen is also a by-product of industrial processes like steam cracking. This hydrogen cannot be replaced by delivering renewable hydrogen as it is an intrinsic by-product of the process. Therefore, hydrogen produced directly or indirectly as by-product from such process should be excluded from the calculation of the share of RFNBOs in hydrogen use. - Access to abundant and affordable renewable electricity and renewable hydrogen will be central to the EU’s net zero objectives, and that includes the chemical sector and Dow. The priority instead should be on enabling that deployment by focusing on the increase in renewable electricity capacity e.g., streamlining permitting and on bottlenecks for hydrogen production e.g., infrastructure, investment support.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

15 Nov 2021 · Fit for 55 Package

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

4 May 2021 · EU innovation funds

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

23 Mar 2021 · European Green Deal

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

9 Mar 2021 · European Green Deal and ETS

Meeting with Thierry Breton (Commissioner) and

11 May 2020 · Discussion on the impact of COVID-19

Meeting with Dominique Ristori (Director-General Energy)

10 Apr 2019 · long term decarbonisation and the increasing role of electricity

Meeting with Michael Hager (Cabinet of Vice-President Günther Oettinger)

15 Mar 2019 · industrial policy

Meeting with Frans Timmermans (First Vice-President) and BASF SE and

26 Oct 2018 · Discussion about Plastics Strategy, Circular economy

Meeting with Phil Hogan (Commissioner)

22 May 2018 · Agri Issues

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

8 May 2018 · Latest developments in EU trade and industrial policy

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

8 May 2018 · Horizon Europe

Meeting with Vytenis Andriukaitis (Commissioner) and

2 May 2018 · Review of General Food Law

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

24 Apr 2018 · Industrial Policy

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen), Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and FIPRA International SRL

18 Apr 2018 · Industrial policy in Europe

Meeting with Vytenis Andriukaitis (Commissioner) and

27 Feb 2018 · EU regulation of plant protection products

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council

7 Feb 2018 · industrial strategy communication

Meeting with Xavier Coget (Cabinet of Vice-President Jyrki Katainen)

24 Oct 2017 · Transatlantic economic and trade relations

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

13 Oct 2017 · Plastic

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

13 Oct 2017 · EU Plastics Strategy

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and FIPRA International SRL

28 Sept 2017 · EU industrial policy strategy

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

27 Sept 2017 · Discussion on the Future of Europe

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger)

13 Sept 2017 · EU industrial policy framework

Meeting with Daniel Calleja Crespo (Director-General Environment) and FIPRA International SRL

5 Sept 2017 · EU industrial policy and Circular Economy

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

5 Sept 2017 · future framework programme

Meeting with Michael Hager (Cabinet of Vice-President Günther Oettinger)

27 Apr 2017 · EU policies

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

7 Feb 2017 · Innovation, regulation and competition case concerning DOW mergers

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

7 Feb 2017 · Trade in general; the possibility of launching a case in the WTO

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

31 Jan 2017 · Avian Influenza and Marketing Status for Freee Range Eggs

Meeting with Karmenu Vella (Commissioner) and

30 Jan 2017 · Innovation and chemicals

Meeting with Thibaut Kleiner (Cabinet of Vice-President Günther Oettinger)

30 Jan 2017 · EU regulation

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2017 · Pesticides; competition

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

26 Jan 2017 · Agroscience

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

25 Jan 2017 · DSM general, innovation

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and WACKER CHEMIE AG and Momentive Performance Materials GmbH

19 Jan 2017 · D4

Meeting with Kyriacos Charalambous (Cabinet of Vice-President Johannes Hahn)

21 Dec 2016 · Discussed business and investment climate in Europe and in particular Western Balkans and Neighbourhood.

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Dec 2016 · Chemicals Industry

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

12 Dec 2016 · Dow’s research

Meeting with Jyrki Katainen (Vice-President)

12 Dec 2016 · Competitiveness of Europe's Chemical Industry

Dow Europe wants microbial products included in low-risk criteria

1 Dec 2016
Topic — The European Commission is revising criteria for identifying low-risk active pesticide substances.
Message — Dow suggests products obtained from micro-organisms through naturally-based processes should be considered low-risk. They propose amending the regulation to include active substances produced naturally by micro-organisms.12
Why — This would simplify the approval process for Dow's biological and sustainable agricultural products.34
Impact — Consumers may lose protections if modified substances bypass rigorous testing through low-risk classification.5
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Response to Criteria to identify endocrine disruptors for biocidal products

28 Jul 2016

The Dow Chemical Company (Dow) welcomes the Commission’s inclusion of valuable elements for ED criteria in its proposal. We agree with applying the WHO IPCS definition and a weight-of-evidence approach when evaluating ED potential. However, Option 2 is insufficient for regulatory purposes as it fails to differentiate substances of high concern from those that pose no threat to people and the environment. Option 2 lacks critical elements of hazard characterization, including potency and scientific determination of thresholds. Potency determines the ability of a substance to cause an adverse effect, a key criterion in the definition of EDs and a fundamental principle of toxicology. It allows regulators to distinguish the hazards posed by EDs like diethylstilbestrol from endocrine-active compounds like soy, which poses no hazard to humans under normal conditions. Potency is also used in the hazard-based CLP legislation. Under Option 2, low potency endocrine-active substances could be banned even if exposures are substantially lower than doses causing endocrine activity. Such restrictions can cause undue harm to industry and consumers without demonstrably improving public health. While plant protection products with unacceptable risk profiles should not be used, unnecessarily limiting the use of products which don’t pose risks can have severe impacts on farmers’ ability to maximize crop yield, an important factor with climate change. Banning of pesticides and biocides (i.e., preservatives) can result in food instability and increase foodborne diseases due to mold or fungal contamination, affecting both health outcomes and global trade (see WorldBank http://bit.ly/2ayZ3NL and FAO http://bit.ly/2aiOFYC). Removing biocides from everyday products can have devastating effects due to bacterial contamination (e.g., babies who died when a hospital switched to a baby shampoo without preservatives; Madani et al., J. Hospital Infection, 78, 16-21; 2011). Chemicals provide many benefits to human health and their continued development is important in solving global health issues, e.g. microbial resistance and disease vector control. Impractical regulatory policies will limit the use and development of such beneficial chemistries. Dow views Option 4 as the most relevant regulatory approach to protect public health while considering critical hazard elements such as potency. For globally operating companies it provides the most harmonized approach to ED regulation as it is most consistent with the US EPA’s Endocrine Disruptor Screening Program which is based on ED screening and test methods that were validated in partnership with the OECD. Option 3 is not useful as categories will confuse the public as to which substances pose concern over health effects. Endocrine-active substances include a broad spectrum of both natural and synthetic substances that may pose no threat to human health (e.g., isoflavones in foods containing soy), even to the most sensitive sub-populations (e.g., soy-based infant formula). The clear designation of EDs is important, whereas a category approach promotes a blurred continuum between endocrine active and ED, and will erode regulatory confidence of stakeholders and lead to marketplace de-selection of harmless and useful products. Dow urges the Commission to re-evaluate the criteria for ED regulation and select Option 4 instead of Option 2 which does not provide scientific criteria suitable for regulation. Conversely, Option 4 is critical to allow for full hazard characterization, including an assessment of potency, and will help move towards a predictable, science-based framework and global harmonization to the benefit of farmers, consumers, industry and society. We further urge the Commission to continue rejection of a category approach for ED regulation as this does not offer any advantages in the protection of health and the environment.
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Dow Europe urges EU to adopt potency-based endocrine disruptor criteria

28 Jul 2016
Topic — The European Commission is setting scientific criteria to identify endocrine disruptors in pesticides.
Message — Dow recommends adopting Option 4 to include potency and hazard characterization in the criteria. They argue Option 2 is insufficient because it fails to distinguish harmful substances from harmless ones. They also reject a categorical approach that could confuse the public about health risks.123
Why — This would provide a predictable regulatory framework that aligns with existing international standards.45
Impact — Farmers and consumers face lower crop yields and higher risks of foodborne diseases.67
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Meeting with Dominique Ristori (Director-General Energy) and Chamber of Commerce of the United States of America and

14 Jul 2016 · Transatlantic energy developments

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

13 Jul 2016 · Product Approval Processes

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

12 Jul 2016 · EU GMO import approval process; Nitrogen stabilising technologies

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

6 Jul 2016 · Innovative technologies supporting policy objectives

Meeting with Daniel Calleja Crespo (Director-General Environment)

17 Mar 2016 · Plastic packaging in the Circular Economy Package

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

17 Mar 2016 · Circular Economy; EU Industrial Policy, including the ETS system

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

16 Mar 2016 · Industrial Symbiosis

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

23 Feb 2016 · 2nd EU Energy Summit - breakfast roundtable

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Jyrki Katainen (Vice-President) and

17 Nov 2015 · Roll-out of Investment Plan

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and American Chamber of Commerce to the European Union and

3 Jun 2015 · New College and Better Regulation

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

19 May 2015 · Chemical sector and trade agenda

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

18 Mar 2015 · Presentation of a reserach project in the area of CNG

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and BASF SE and

12 Feb 2015 · Digital Single Market, Innovation

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

11 Feb 2015 · Smart Delta Regio/CNG

Meeting with Polykarpos Adamidis (Cabinet of Commissioner Dimitris Avramopoulos)

11 Dec 2014 · Exchange of views on Competitiveness / industrial re launching in Greece