European Advanced Carbon and Graphite Materials Association

ECGA

The European Advanced Carbon and Graphite Materials Association represents industries using and producing carbon and graphite products.

Lobbying Activity

Graphite industry urges demand-side policies in Advanced Materials Act

13 Jan 2026
Message — The association proposes a "Critical Advanced Materials" list to secure fast-track permitting. They urge the Commission to implement demand-side policies like mandatory recycled-content targets. Finally, they call for assertive trade defense measures to protect the EU market.123
Why — These measures would create a stable market and price advantage for European producers.4
Impact — Non-EU suppliers of cheaper, high-carbon materials would face exclusion via trade barriers.5

Meeting with Charlotte Grevfors Ernoult (Head of Unit Employment, Social Affairs and Inclusion)

25 Nov 2025 · Exchange of views related to the proposed occupational exposure limit for Polycyclic Aromatic Hydrocarbons (PAHs).

Carbon industry urges mandatory recycled content targets by 2030

5 Nov 2025
Message — The association wants graphite included in mandatory battery recycling targets by 2030. They propose redefining waste status to simplify manufacturer take-back schemes. They also advocate mandating recycled carbon fiber usage in industrial sectors.123
Why — These mandates and tax rebates would guarantee market demand for European graphite.45
Impact — Importers and non-compliant manufacturers would face penalties and reduced market access.67

Carbon industry warns stricter exposure limits threaten European autonomy

21 Oct 2025
Message — The association proposes a limit of 700 ng/m³ for harmful chemicals known as PAHs. They argue that proposed lower values are not economically viable and lack proper socio-economic assessment. The industry requests that all synthetic graphite production be treated equally under the rules.123
Why — This allows the European synthetic graphite industry to remain operational and competitive.4
Impact — Downstream users in strategic sectors face supply chain disruptions and lower reliability.5

Carbon and graphite producers demand industrial role in energy security

13 Oct 2025
Message — The group requests a formal role for industry in energy planning and crisis management. They seek compensation for regional cost disparities and support for long-term fixed-price contracts.123
Why — This would reduce their exposure to price volatility and protect their European investments.45

ECGA backs 70% recyclability target for wind turbine blades

9 Oct 2025
Message — The group supports the 70% recyclability requirement but requests a clear implementation timeline. They also seek increased EU funding and domestic content rules to support local producers.123
Why — Mandating recyclability ensures carbon fibre remains indispensable while unlocking significant industrial subsidies.45
Impact — Non-European manufacturers face market exclusion due to proposed domestic content and resilience criteria.6

Carbon and graphite industry demands affordable power in Electrification Plan

6 Oct 2025
Message — ECGA requests fairer electricity pricing by removing taxes and non-energy charges from industrial bills. They also advocate for long-term fixed-price contracts and expanded cross-border grid capacity.12
Why — This would provide the cost predictability needed to invest in long-term decarbonisation projects.3
Impact — Global competitors would lose their price advantage if European energy costs become more competitive.4

Graphite industry urges lifecycle carbon standards for EU vehicles

2 Oct 2025
Message — The organization advocates shifting from tailpipe-only metrics to comprehensive lifecycle assessments including battery production. They propose a flexibility mechanism to incentivize the European sourcing of critical raw materials.12
Why — This would create market conditions that resolve scale-up challenges for European battery material producers.3
Impact — Foreign competitors with high-carbon energy grids or poor labor practices would face competitive disadvantages.4

Graphite producers demand strict rules for foreign carbon pricing

25 Sept 2025
Message — The association demands recognition of third-country pricing only if it is credible and equivalent. They also insist that electricity-related emissions be integrated into the methodology.12
Why — Stringent verification prevents foreign firms from using weak carbon schemes to undercut EU prices.3
Impact — Non-EU exporters lose their cost advantage gained from cheaper, carbon-intensive energy sources.4

ECGA demands continued free allowances until CBAM is proven

25 Sept 2025
Message — Free allocation must remain until the border mechanism is proven to safeguard competitiveness. The system must include Scope 2 electricity emissions in its methodology.12
Why — Maintaining free allowances prevents carbon leakage and protects profit margins for European producers.3
Impact — EU importers will be penalised if they source from producers using clean energy abroad.45

Carbon industry demands electricity emissions inclusion in CBAM rules

25 Sept 2025
Message — The organization argues that the methodology must include electricity-related emissions to ensure a fair comparison for energy-intensive sectors like synthetic graphite. They also call for maintaining free emission allowances until the system effectively prevents carbon leakage.12
Why — Including indirect emissions helps European producers offset high domestic electricity costs against cheaper, carbon-intensive foreign competition.34
Impact — Exporters from countries with high-carbon energy lose the competitive edge provided by cheap, polluting electricity.56

Graphite industry urges inclusion in EU housing construction strategy

18 Sept 2025
Message — ECGA requests that the Commission explicitly support graphite electrodes as critical inputs for housing. They urge for stronger trade defenses and tariffs against subsidized imports.12
Why — These measures would protect EU producers from unfair competition and reduce their structural cost disadvantages.34
Impact — Foreign exporters would face restricted market access through higher tariffs and stringent import quotas.56

ECGA urges expansion of EU carbon cost compensation

5 Sept 2025
Message — ECGA requests adding synthetic graphite to the list of sectors eligible for compensation. They also want mandatory implementation across the EU and updated technical parameters.12
Why — Including these materials would lower costs and protect the industry from relocation.3
Impact — Already-eligible industrial sectors lose their relative cost advantage over the graphite industry.4

ECGA urges public funding for carbon capture infrastructure

4 Sept 2025
Message — The association demands that transport infrastructure costs are not the responsibility of private emitters. They call for targeted financing and revenue stabilisation to manage high capture costs.123
Why — Shifting these massive costs to the public sector prevents industrial relocation abroad.4
Impact — Renewable energy sectors lose if public funds are diverted to carbon infrastructure.5

Graphite industry urges stricter scrutiny for strategic foreign acquisitions

1 Sept 2025
Message — The association requests mandatory notification for acquisitions in strategic sectors regardless of turnover. They also demand investigations into subsidized materials imported through third-party countries.12
Why — Lower thresholds would shield European graphite manufacturers from predatory, state-subsidized foreign takeovers.3
Impact — State-subsidized foreign firms would find it harder to acquire strategic European assets.4

ECGA urges strict steel safeguards to protect graphite electrode producers

18 Aug 2025
Message — The association proposes setting import quotas at half of 2024 levels and applying them universally. They also demand a full block on low-carbon steel imports to boost domestic electrode production.123
Why — Stronger steel protections would stabilize domestic demand for the association's graphite products.4
Impact — Exporters of low-carbon steel lose all access to European markets under the proposed block.5

Graphite industry group opposes listing coal tar pitch as hazardous

8 Aug 2025
Message — The association objects to listing coal tar pitch in the regulation's annexes. They argue it would increase bureaucracy for a material essential to graphite production.12
Why — This would prevent unnecessary administrative burdens and safeguard the competitiveness of European graphite production.3

Graphite industry urges EU to prioritize industrial grid access

4 Aug 2025
Message — ECGA requests that industrial hubs be integrated as priority nodes in grid planning. They advocate for faster permitting and expanded guarantee schemes to stabilize high electricity prices.12
Why — These changes would reduce operational costs and resolve lengthy energy connection delays.3
Impact — Grid operators would be forced to meet strict transparency and permitting deadlines.45

ECGA urges domestic content rules for recycled battery graphite

24 Jul 2025
Message — The association proposes a domestic content requirement for batteries to mandate European recycled materials. They also request adding wind turbine blades and car bodies to the recovery list. Additionally, they seek funding to help firms certify recycled graphite against manufacturer standards.123
Why — These regulations would protect European producers from competition and secure guaranteed market demand.45
Impact — Battery manufacturers and consumers would face higher prices for sustainable raw materials.67

ECGA Demands Continued Free Allowances for EU Graphite Sector

8 Jul 2025
Message — The association requests the continuation of free carbon permits for the graphite sector. They want synthetic graphite included in the electricity cost compensation list. The group also opposes adding small installations to the trading system.123
Why — This would significantly lower production costs and protect their position in global markets.456
Impact — The EU's climate innovation budget loses funding when emissions permits are not auctioned.7

Response to Industrial Decarbonisation Accelerator Act

7 Jul 2025

General and detailed comments on various sections of EU policies impacting on the compatibility of decarbonisation strategies and the competitiveness of the European advanced carbon and graphite materials sector are included in the attached document.
Read full response

Graphite industry urges EU support for bio-based transition

23 Jun 2025
Message — The association requests the inclusion of carbon and graphite in all bioeconomy policy plans. They seek funding for research to develop synthetic bio-based precursors with tailored properties. They also suggest adapting existing furnace infrastructure to handle bio-based inputs.123
Why — This would help the industry reduce environmental impacts while improving the financial outlook for producers.45
Impact — The biofuel sector faces increased competition for limited biomass if material uses gain priority.6

Meeting with Heiko Kunst (Head of Unit Climate Action), Mette Koefoed Quinn (Head of Unit Climate Action)

11 Jun 2025 · ECGA outlined the economic situation faced by European producers of graphite, including global over-supply and the strategic importance of graphite as a battery component.

Response to Connecting Europe through high-speed rail

8 May 2025

Our feedback can be found in the attached position paper. Thanks for this opportunity to comment.
Read full response

Meeting with Lukasz Kolinski (Director Energy)

25 Apr 2025 · Situation of the carbon and graphite industry as an energy-intensive industry and contribution to the Steel and Metal Action Plan and the Automotive Action plan

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

5 Feb 2025 · Physical meeting - Exchange of views on the Carbon Border Adjustment Mechanism (CBAM), its scope extension and its potential implications for the European graphite industry

Graphite industry urges EU to harmonize energy and regulations

31 Jan 2025
Message — The association calls for harmonized energy prices and uniform waste rules across all Member States. They urge the Commission to streamline regulations and enforce rules to ensure fairness.123
Why — Harmonization would reduce administrative burdens and allow companies to operate more efficiently.45
Impact — National authorities would lose the power to set independent waste-to-product standards.6

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Service providers will be subjected to intense competition and will have to answer the requests of demanding customers. They will have to ensure a very high level of security for confidential business data. They will need to guarantee swift and transparent interoperability with their competitors. And finally they will not be able to monetise the wealth of high-value data that they will be handling. The European carbon and graphite industry is worried that these tensions might result in low quality of service and/or monopolisation if the Commission does not set minimal quality standards and enforce a fair competition right from the outset. Please see attached for more details.
Read full response

ECGA urges mandatory graphite reporting in battery recycling rules

18 Oct 2024
Message — ECGA requests making graphite reporting compulsory in recycling efficiency calculations. They want carbon included in input mass to ensure market transparency.12
Why — Mandatory reporting would attract essential private investment and encourage innovative new ventures.3
Impact — Advanced recyclers lose funding if competitors mask inefficiency by omitting graphite data.4

ECGA Urges Graphite Inclusion in Battery Carbon Footprint Rules

27 May 2024
Message — The association requests adding graphite to the list of recycling outputs for consistency. They also propose strict data aggregation rules to protect proprietary company information.12
Why — This would protect confidential production data while legitimizing graphite recovery as a green process.34
Impact — Large conglomerates lose the ability to harvest proprietary data from competitors through their subsidiaries.5

Response to Revision of Combined Transport Directive

29 Jan 2024

Please see the attached position paper.
Read full response

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

10 Nov 2023 · Graphite supply chains, trade policy

Carbon and graphite industry demands shared EU carbon infrastructure

29 Aug 2023
Message — ECGA calls for a technology-neutral strategy including shared infrastructure and risk-sharing mechanisms. They request the inclusion of solid carbon from methane pyrolysis in the initiative.123
Why — Shared infrastructure and subsidies would mitigate massive increases in operational and energy costs.45
Impact — Public funds are at risk due to demands for early-stage financial support and guarantees.67

Response to Ecodesign for Sustainable Products - Product priorities

25 Apr 2023

The European Carbon and Graphite Association is pleased to submit its contribution to the consultation on product priorities under the new ESPR. Our full analysis can be found in the attached position paper.
Read full response

Response to European Critical Raw Materials Act

9 Nov 2022

The European Carbon and Graphite Association welcomes the ECRMA and calls upon Commission and Member States to actively foster the use of European resources. Details are provided in the attached paper.
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

ECGA, the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology acknowledges the publication of the Fit for 55 Package as the largest and probably the most significant cluster of measures the EU has ever published at the same time, towards the same goal, namely, the EU carbon neutrality by 2050. With regards to the Energy Efficiency Directive, the European Carbon and Graphite industry is convinced that an energy efficient economy is key to reaching the ambitious EU 2030 and 2050 climate targets, while ensuring growth and prosperity in Europe and this can only be achieved via a comprehensive and systemic approach that allows us to reap unexploited potential for energy savings across the entire economy, while decarbonising the energy consumed. However, even though great progress has been achieved through the revised proposal, we believe that the main objective of the energy efficiency directive should be to ensure an integrated approach to consistency, stability, and predictability along the whole value chain by taking into consideration the following suggestions: Introducing an absolute value-cap on energy consumption should be avoided. Future needs considering the potential trade-offs between decarbonisation and energy consumption should be considered instead. Innovative technologies needed by the sector to keep contributing to the decarbonization objectives are, most of them, highly energy intensive. The electro-intensity of our companies is based upon only electricity consumption for the production feedstock and shows that values range from less than 1MWh/t to nearly 12 MWh/t. The weighted average electro-intensity of our companies for 2014 to 2016 was around 4.65 MWh/t, while the unweighted average intensity is 2.85 MWh/t. Therefore, decarbonizing the European carbon and graphite sector will require an overall increase in energy consumption. This means that setting a simple cap on energy consumption risks limiting the potential for industrial decarbonization. At the same time, such a cap would also limit the potential for industrial growth, at a time when massive investments are required to adhere to the goals of the Green Deal. The scope and application of the “Energy efficiency first” principle should be clarified and always taken into consideration when applied to energy intense sectors, such as the carbon and graphite one. Ensure that energy savings are both technically and economically feasible when raising the annual energy savings obligation to be applied on Member States between 2024 – 2030, from 0.8% to 1.5%. Several products a decrease in energy consumption is only possible up to a certain point after which their chemical and physical characteristics would be negatively affected leading to a decrease in the product quality or even safety. For example, process emissions are generated through chemical reactions among raw materials used in the production process. These emissions, strictly correlated to the production level by a multiplication factor are unavoidable. The Energy Efficiency should avoid overlapping with other EU Fit for 55 Package elements, such as ETS, CBAM or ETD. The level of GHG reduction requested through the ETS directive (-61% between 2005 and 2030) combined with the continuous increase in carbon prices (~60€/t in 2021) are already adding huge costs to the industry. For more information, please see the attached Public Position.
Read full response

Response to Revision of the Energy Tax Directive

18 Nov 2021

The European Carbon and Graphite Association (ECGA) acknowledges the publication of the Fit for 55 Package as the largest and probably the most significant cluster of measures the EU has ever published at the same time, towards the same goal, namely, the EU carbon neutrality by 2050. Nevertheless, with regards to the Energy Taxation Directive, we are concerned that the amendment of Article 3(1) of the Energy Taxation Directive proposal which now includes mineralogical processes in its scope will only lead to additional costs. Mineralogical processes are subject to thermodynamic energy requirements that cannot be reduced. Even more, energy costs, primarily due to electricity consumption, represent an important part our sector’s operating cost and thus, increasing them by adding the energy tax would slow down the investments ensuring the transition to a low carbon economy and implicitly lead to an investment leakage, fewer jobs, less production, and less innovation. In this context, we would like to suggest amending Article 3(1) of the current proposal to its previous form, as follows: ”This Directive shall not apply to the following… …dual use of energy products. An energy product has a dual use when it is used both as heating fuel and for purposes other than as motor fuel and heating fuel. The use of energy products for chemical reduction and in electrolytic processes, mineralogical processes and metallurgical processes, when energy products are used directly in or to provide a direct energy input to the process, or their consumption is connected to the process, shall be regarded as dual use.” Our above-mentioned request is supported by the following reasons: • The Energy Taxation Directive should avoid overlapping with other EU measures such as ETS or CBAM while ensuring the legal certainty, long-term goals as well as the international competitiveness of the industry • Including mineralogical processes in the scope of the Directive would lead to a severe cost burden for the industry. Increasing the cost burden on selected industrial sectors will hinder not only the capital-intensive investments into new low-carbon technologies but also the achievement of the Fit for 55 Package main objectives. • Including mineralogical process in the scope of the Directive will distort the level playing field in the single market. • The criteria and methodology based on which the mineralogical processes have been excluded from the exemption list are missing from both the revised directive as well as from the Impact Assessment accompanying it. For more information, please see the attached Position Paper.
Read full response

Response to Updating the EU Emissions Trading System

7 Nov 2021

The Emissions Trading System (2021 – 2030) should remain the main market instrument for Europe’s industries to cost-effectively reduce their emissions. Carbon and graphite products are commodities that are traded worldwide. This leads to high trade intensity and a globally competitive market. Major producers outside of Europe are headquartered in China, Japan, and the USA and, while companies in the EU face both direct and indirect carbon costs, such costs are not faced by their other major international competitors. This situation means that European companies must absorb costs or lose competitiveness, neither of which the companies are positioned to do. Carbon emissions related to the sector’s production process occur both on-site from the combustion of fuels (direct emissions) and through electricity use due to the use of carbon-bearing raw material at the location of electricity production (indirect emissions). For example, feedstock production requires heating up to 3,000°C during the high temperature graphitisation process step – much of which is done by electrical heating. Graphite production therefore is highly energy-intensive, but also inherently an electricity-intensive production process. The fact that electricity accounts for the largest share of the energy mix to produce artificial graphite has also been noted by the Commission in earlier correspondence with the sector. Currently all carbon and graphite activities falling under NACE code 23.99 have been considered eligible for CL-support from 2021 onwards; however, as the status before and after 2030 remains uncertain, ECGA would like to underline several elements we believe are essential to achieving the ETS as well as the Fit for 55 Package objectives, as follows: * Free allocation should continue to be the key tool for sectors exposed to carbon leakage alongside financial compensation for CO2 costs and electricity prices (electricity represents a substantial share of the carbon and graphite industry operating expenses); * Article 3 of the draft Revised ETS should include a clear definition of the „decarbonisation“ concept that ensures its coherent use across legislation (The Climate Law, ETS, Energy Efficiency, The European Industrial Strategy); * The process emissions allocation factor should be kept at 97%, without distortions; * When defining carbon leakage protection, the sectors’ ability to pass-on costs into product prices should be taken into consideration; * Given the latest trade and competition policy developments, the other Union policies and legislation currently being revised (CBAM, EED, State Aid for environment and energy, etc.), the international commitments and material market developments, as well as the ETS State Aid Guidelines should also be updated to maintain a level playing field. For more information, please see the attached ECGA Position on updating the EU ETS.
Read full response

Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology. Graphite and carbon materials are an integral part of the EU’s strategy for decarbonisation, performing as reliable and safe materials for applications in the automotive sector, including batteries and electric motors. ECGA welcomes the opportunity to submit its views on the revision of the End-of-life vehicles Directive (ELV Directive). Please see attached our position statement.
Read full response

Response to Modernising the EU’s batteries legislation

8 Jul 2020

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology. Batteries and their associated technologies are pivotal in achieving carbon neutrality by 2050, in line with the objectives of the EU Green Deal and Circular Economy. Graphite materials, natural and synthetic, are an integral part of the EU’s strategy for decarbonisation, performing as a reliable and safe material able to provide sufficient energy density for many applications, including batteries in electric vehicles. Please see ECGA's attached input.
Read full response

Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology. Please see the attached ECGA statement.
Read full response

Response to Chemicals strategy for sustainability

19 Jun 2020

The European Carbon and Graphite Association (ECGA) represents 100% of the EU based graphite electrode producers going into Europe's steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety specialty graphite going into hundreds of applications from electric motors to modern battery technology. ECGA welcomes the opportunity to submit its views on the envisaged Chemicals Strategy for Sustainability, which aims to better protect the environment and human health against hazardous substances as well as support the sustainable transformation of the chemical industry and the creation of a green and sustainable manufacturing capacity in Europe. Please see the attached ECGA contribution.
Read full response