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Emerson Electric Co.

Emerson manufactures and sells industrial automation monitoring and control equipment in industries such as power, chemical, pharmaceutical, and many others We want to understand early new legislative approaches. We are interested in the Green Deal and supporting the initiatives associated with meeting the 2030 and 2050 climate goals.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Emerson welcomes the opportunity to provide our feedback on the call for evidence regarding sustainable investment review of the EU taxonomy climate delegated act. Please find our detailed feedback attached.
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Response to Circular Economy Act

6 Nov 2025

Emerson welcomes the opportunity to submit our feedback to the call for evidence on the Circular Economy Act. Please find attached our detailed feedback.
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Response to Evaluation of the Measuring Instruments Directive

9 Oct 2025

Emerson welcomes the opportunity to submit their feedback to the evaluation / fitness check of the Measuring Instruments Directive (2014/32/EU). Please find attached our detailed feedback.
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Response to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

24 Sept 2025

Thank you for the opportunity to provide feedback. Please see the attached document.
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Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

24 Sept 2025

Thank you for the opportunity to provide our feedback. Please see the attached document.
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Meeting with Michael Mcnamara (Member of the European Parliament)

24 Sept 2025 · Digital Simplification

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Rud Pedersen Public Affairs Brussels

24 Sept 2025 · CSRD and sustainability assurance

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

22 Sept 2025 · CBAM

Meeting with Victor Negrescu (Member of the European Parliament)

22 Sept 2025 · Exchange of views with Emerson

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

18 Sept 2025 · Sustainability reporting and due diligence

Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

12 May 2025

Thank you for the opportunity to provide input. Based on our experience with implementing the EUDR compliance program, we recommend introducing an additional interpretative guidance or modifications to the Delegated Regulation that would resolve the issue of distinguishing goods made from natural rubber: The CN classification of rubber products does not allow for distinguishing between products made of natural rubber and those made of synthetic rubber. In the absence of clear guidance from the Commission regarding the documents that would be sufficient to confirm that a rubber item is made of synthetic rubber as opposed to natural rubber, EU member states customs authorities will likely establish inconsistent, varying practices from country to country. This will increase the lead time for import clearance, encourage forum shopping, and increase imports via the member states where the interpretation and practice are more favorable. The issue could be resolved through one of the following measures: (a) Creating a separate commodity classification for items made of synthetic rubber. (b) Defining documents that could be used to confirm that an item is made from synthetic rubber. Such documents may include a manufacturers declaration of conformity or equivalent, description of the goods in contracts and trade documents, and supplier or manufacturer's certification. Thank you for considering this suggestion.
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Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

10 Apr 2025 · Chemicals regulation/PFAS

Meeting with Filip Turek (Member of the European Parliament, Shadow rapporteur)

10 Apr 2025 · The Carbon Border Adjustment Mechanism

Response to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components

6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead in Glass or Ceramic Components for Exemption 7(C) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in glass or ceramic components and recognizes the significance and purpose of this directive in protecting both people and the environment. We also acknowledge the importance of responsibly managing and using lead, particularly in unavoidable cases where its performance and functionality are critical for challenging applications essential to everyday life. Emerson Electric, headquartered in St. Louis, Missouri, USA, is a global leader in automation with extensive operations across Europe, including over 16,500 employees and 51 manufacturing sites spread across 21 Member States. While Emerson fully supports the EUs goals of environmental sustainability and the reduction of hazardous substances, we wish to submit comments on Lead in Glass or Ceramic Components, exemption 7(c)-I and 7(c)-II, for your consideration. In addition to core technologies essential for the performance and reliability of many industrial monitoring and control devices, several commercially available electronic components, such as resistors, diodes, and capacitors, are used that rely on RoHS exemptions 7(c)-I and 7(c)-II. Although suitable replacement materials have been identified in some cases, many applications still lack alternatives that meet the required product specifications, despite thousands of man-hours invested over the past decade. Our comments, underpinned by the critical role of lead as an essential enabling material in specific applications, are summarized below for your consideration: 1. Leveling Timelines Across All RoHS Categories Creates a Disproportionate Workload for Industrial Products Applying uniform rules and timelines across all RoHS categories creates unrealistic expectations for Industrial Monitoring & Control Category 9 products. These products include complex electromechanical devices that measure various parameters such as temperature, humidity, pressure, vibration, corrosion, and density, as well as process control components like valves, actuators, flow measurement devices, and regulators. They are designed for use in harsh industrial environments, such as chemical manufacturing facilities, nuclear power generation, oil and gas operations, and construction sites, where high-performance, high-reliability materials are crucial to preventing failures that could pose risks to both people and the environment. Lead is frequently used in Category 9 products to obtain good bonding, sealing and encapsulation of glass for applications such as: (1) forming pressure sensing elements, (2) glass-to-metal seals, and (3) encapsulation of electronic components such as resistors, diodes and capacitors used in integrated circuits. Its use is dictated by the application parameters and ability to deliver high performance results across an array of properties such as matching thermal expansion, environmental resistance and eutectic melting profile. Replacing lead in a long-life (>10 years) Category 9 Industrial Monitoring & Control product is a complex engineering task that may require 2-3 years of qualification testing and re-certification, which is often mandatory for these types of products. The differences between industrial and consumer products are too significant to apply consumer product material change-out timelines to industrial products. This approach will only be effective if industrial products serve as the foundation for establishing deadline timelines. It is assumed that this outcome is not a viable solution for the EU Commission, which is why we are recommending different expiry dates for specific categories. 2. The Proposed Timelines for Implementing Alternatives are too Short The current timelines for phasing out lead in glass are too short.
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Response to Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper

6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead as an Alloying Element in Copper 6(c) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in high melting solders and recognizes the significance and purpose of this directive in protecting both people and the environment. We also acknowledge the importance of responsibly managing and using lead, particularly in unavoidable cases where its performance and functionality are critical for challenging applications essential to everyday life. Emerson Electric, headquartered in St. Louis, Missouri, is a global leader in automation with extensive operations across Europe, including over 16,500 employees and 51 manufacturing sites spread across 21 Member States. While Emerson fully supports the EUs goals of environmental sustainability and the reduction of hazardous substances, we wish to submit comments on Lead as an Alloying Element in Copper 6(c), for your consideration. Our comments, underpinned by the critical role of lead as an essential enabling material in specific applications, are summarized below for your consideration: 1. Leveling Timelines Across All RoHS Categories Creates a Disproportionate Workload for Industrial Products Applying uniform rules and timelines across all RoHS categories creates unrealistic expectations for Industrial Monitoring & Control Category 9 products. These products include complex electromechanical devices that measure various parameters such as temperature, humidity, pressure, vibration, corrosion, and density, as well as process control components like valves, actuators, flow measurement devices, and regulators. They are designed for harsh industrial environments, withstanding temperatures from -200°C to 260°C and pressures exceeding 1000 bar. These high-performance, reliable products, and the advanced materials that enable them, are essential for applications like chemical processing, semiconductor manufacturing, and hydrogen production and distribution, where preventing failures is critical to protecting both people and the environment. Copper-lead alloys, primarily brass, are used in Category 9 products for components like bearings, valve bodies, and connectors. Due to its low solubility in copper, lead serves as an ideal additive, enhancing machinability without compromising the materials excellent performance across an array of properties such as high thermal and electrical conductivity, enhanced ductility and toughness, and corrosion resistance. Replacing lead in a long-life (>10 years) Category 9 Industrial Monitoring & Control product is a complex engineering task that may require 2-3 years of qualification testing and re-certification, which is often mandatory for these types of products. In contrast, eliminating lead from a short-life (<2-3 years) consumer product or a non-safety-critical component is considerably simpler and typically involves a much shorter qualification testing cycle. The differences between industrial and consumer products are too significant to apply consumer product material change-out timelines to industrial products. This approach will only be effective if industrial products serve as the foundation for establishing deadline timelines. It is assumed that this outcome is not a viable solution for the EU Commission, which is why we are recommending different expiry dates for specific categories. 2. The Proposed Timelines for Implementing Alternatives are too Short The proposed timelines for phasing out copper-lead alloys are too short, as viable alternatives are not yet readily available for all applications. Potential lead-free substitutes include elements such as bismuth, silicon, and phosphorus. The suitability of these alternatives should be evaluated on a case-by-case basis, considering specific application requirements. Key factors influencing material selection include ease of manufacturing
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Response to Exemptions under RoHS for lead in high melting temperature type solders

6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead in High Melting Temperature Solders 7(a) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in high melting solders and recognizes the significance and purpose of this directive in protecting both people and the environment. We also acknowledge the importance of responsibly managing and using lead, particularly in unavoidable cases where its performance and functionality are critical for challenging applications essential to everyday life. Emerson Electric, headquartered in St. Louis, Missouri, is a global leader in automation with extensive operations across Europe, including over 16,500 employees and 51 manufacturing sites spread across 21 Member States. While Emerson fully supports the EUs goals of environmental sustainability and the reduction of hazardous substances, we wish to submit comments on Lead in High Melting Temperature Solders, exemption 7(a), for your consideration. Our comments, underpinned by the critical role of lead as an essential enabling material in specific applications, are summarized below for your consideration: 1. Leveling Timelines Across All RoHS Categories Creates a Disproportionate Workload for Industrial Products Applying uniform rules and timelines across all RoHS categories creates unrealistic expectations for Industrial Monitoring & Control Category 9 products. These products include complex electromechanical devices that measure various parameters such as temperature, humidity, pressure, vibration, corrosion, and density, as well as process control components like valves, actuators, flow measurement devices, and regulators. They are designed for harsh industrial environments, withstanding temperatures from -200°C to 260°C and pressures exceeding 1000 bar. These high-performance, reliable products, and the advanced materials that enable them, are essential for applications like chemical processing, semiconductor manufacturing, and hydrogen production and distribution, where preventing failures is critical to protecting both people and the environment. High melting temperature lead based solders are frequently used in Category 9 products for attaching electronic components and in the assembly and attachment of some passive devices. Their use is dictated by the application parameters and ability to deliver high performance results across an array of properties such as corrosion resistance, high ductility, high thermal shock reliability, high fatigue resistance and eutectic melting profile. Replacing a lead-based solder in a long-life (>10 years) Category 9 Industrial Monitoring & Control product is a complex engineering task that may require 2-3 years of qualification testing and re-certification, which is often mandatory for these types of products. In contrast, eliminating lead-based solders from a short-life (<2-3 years) consumer product or a non-safety-critical component is considerably simpler and typically involves a much shorter qualification testing cycle. The differences between industrial and consumer products are too significant to apply consumer product material change-out timelines to industrial products. This approach will only be effective if industrial products serve as the foundation for establishing deadline timelines. It is assumed that this outcome is not a viable solution for the EU Commission, which is why we are recommending different expiry dates for specific categories. 2. The Proposed Timelines for Implementing Alternative Solutions for Industrial Products are too Short The proposed timelines for phasing out high temperature lead solders are too short, as viable alternatives are not yet readily available for all applications. Potential lead-free substitutes include solder alloys composed of Au, Zn, Bi, and Ag. The suitability of these alternatives should be evaluated on a case-by-case basis, considering
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Meeting with András Gyürk (Member of the European Parliament)

4 Oct 2024 · Overview of upcoming hydrogen and PFAS regulation