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European Association of Chemical Distributors

Fecc

The European Association of Chemical Distributors represents 1,600 chemical distribution companies in the European market.

Lobbying Activity

Chemical distributors urge practical circular economy rules for SMEs

8 Sept 2025
Topic — The consultation concerns the Circular Economy Act promoting sustainable production and material recycling.
Message — Fecc requests practical transition periods and recognition of mass balancing for recycled content. They advocate for simplified reporting and avoiding duplication with existing chemical regulations. The group also seeks thorough impact assessments to ensure rules work for SMEs.123
Why — This would minimize compliance costs and administrative burdens for small chemical distributors.45
Impact — Environmental groups lose as mass balancing and delayed requirements could weaken material traceability.67
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Chemical distributors urge cautious expansion of EU carbon levy

21 Aug 2025
Topic — The EU is considering extending its carbon border tax to more manufactured goods.
Message — Fecc requests that the extension of the carbon levy to downstream products be handled with caution. They advocate for thorough impact assessments and sufficient time for companies to adjust to new rules.1
Why — These measures would help small distributors avoid excessive administrative burdens and costs.2
Impact — Global trading partners might face barriers if new anti-circumvention measures penalize legitimate commerce.3
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Chemical distributors urge simpler rules and broader recycling definitions

12 Aug 2025
Topic — Establishing EU rules for calculating and reporting recycled content in beverage bottles.
Message — The association favors a proportional mass balance approach based on batch-level allocation to simplify verification. They also recommend including glycolysis-based chemical recycling and broadening the definition of recycled plastic to include pre-consumer waste.123
Why — Simplified accounting methods would reduce high verification costs and administrative uncertainty for distributors.4
Impact — Environmental goals focused on post-consumer waste may be undermined by including industrial scraps.5
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Chemical distributors seek SME support and export flexibility

5 Aug 2025
Topic — Proposed amendments to rules governing the international trade of hazardous chemicals.
Message — The organization requests transitional measures for new substance listings and a clear distinction between pure substances and mixtures. They also advocate for targeted training for smaller firms and a case-by-case approach to export bans.123
Why — These requests aim to prevent supply chain disruptions and lower compliance burdens for smaller distributors.45
Impact — Developing nations might face continued exposure to chemicals banned in the EU under suggested export flexibilities.67
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Response to Adaptation of ECHA fees to inflation

21 Mar 2025

Fecc acknowledges the consultation on amending Implementing Regulation (EU) No 564/2013 as regards the adaptation of fees to inflation (link) and welcomes the opportunity to provide input. Fecc represents chemical, food, and active pharmaceutical ingredients distributors, most of which are SMEs. In this consultation we would like to raise the following points: Fees impact on companies are function of business size. The amount of work involved in an assessment is driven by the number of uses applied for in one application but the impact on companies cost is link to volume sale and as such the fee applicable to a given application should be adapted to the company business size. The amending regulation impacts these charges, including base charge for submission of any review report and base fee for any application for an authorisation of a substance. In these difficult business time, Fecc recommends looking to reduce the administrative cost of registration. Thanks for taking another stab at this using a public consultation. Fecc really appreciate all the time and effort you will put in. Unfortunately, we think as regards the adaptation of fees to inflation is too hight, not proportional and justified for SMEs.
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Response to Evaluation of the Cosmetic Products Regulation

20 Mar 2025

Fecc acknowledges the consultation on the evaluation of the Cosmetic Products Regulation (CPR) and welcomes the opportunity to provide input. As the leading voice for the European chemical distribution sector, we represent companies that play a vital role in the supply chain of cosmetic ingredients, ensuring compliance with regulatory requirements and maintaining high standards of safety and sustainability. We appreciate the Commissions efforts to assess the fitness and effectiveness of the CPR and its alignment with current scientific, regulatory, and market developments. Our feedback focuses on regulatory consistency, supply chain challenges, administrative burdens, and sustainability considerations. In this consultation we would like to raise the following points: 1. Effectiveness of the Regulation in Ensuring Consumer Safety and Market Functioning 2. Regulatory Coherence and Burden on the Supply Chain 3. Supporting Sustainability and Innovation in the Cosmetics Industry 4. Recommendations and Future Regulatory Improvements Based on our industrys experience, Fecc proposes the following recommendations to enhance the efficiency, clarity, and sustainability of the CPR: 1. Regulatory Predictability: Ensure that future amendments to the CPR provide adequate transition periods for businesses to adapt formulation, labeling, and compliance processes. 2. Risk-Based Ingredient Assessment: Maintain a scientific, exposure-based approach to ingredient restrictions rather than hazard-based bans that may unnecessarily limit formulation options. 3. Harmonized Enforcement: Strengthen cooperation between national market surveillance authorities to ensure uniform enforcement of CPR provisions across EU Member States. 4. Digitalization Strategy: Develop a clear EU-wide framework for digital labeling that integrates with existing market compliance tools, ensuring accessibility for SMEs and importers. 5. Sustainability Alignment: Encourage incentives for green chemistry innovations, and ensure that new sustainability requirements under CPR are feasible and cost-effective for distributors and SMEs. Fecc appreciates the European Commissions commitment to evaluating the effectiveness of the Cosmetic Products Regulation and ensuring its alignment with emerging challenges and sustainability objectives. We emphasize the need for a proportionate, risk-based approach that balances consumer safety, regulatory coherence, and industry innovation. We remain available to engage further in the consultation process and look forward to contributing to a well-informed regulatory framework that supports the competitiveness of the European cosmetics industry.
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Fecc acknowledges the consultation on the EU Start-up and Scale-up Strategy and welcomes the opportunity to provide input. As the representative body for the European chemical distribution sector, Fecc strongly supports policies that foster innovation, economic growth, and regulatory efficiency, particularly for SMEs and start-ups operating in our industry. The chemical distribution sector plays a crucial role in ensuring access to essential materials for various industries, including manufacturing, pharmaceuticals, agriculture, and consumer goods. Many of our members are SMEs that rely on a supportive business environment to drive innovation, sustainability, and competitiveness in Europes Single Market. In this consultation, we would like to raise the points provided in the attachment. Fecc strongly supports the objectives of the EU Start-up and Scale-up Strategy and encourages the European Commission to take a holistic, SME-friendly approach that supports regulatory coherence, financial access, skills development, and market entry for innovation. These measures will benefit all sectors, particularly SMEs, and help build a more competitive and resilient European economy. We remain committed to working with policymakers to support the success of start-ups and scale-ups in Europe.
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Meeting with Paolo Garzotti (Acting Director Trade)

19 Feb 2025 · State of play of the EU-Mercosur Trade Agreement.

Fecc urges streamlined CBAM rules to protect small chemical firms

25 Nov 2024
Topic — Procedures and conditions for the authorization of Carbon Border Adjustment Mechanism declarants.
Message — Fecc calls for a streamlined authorization process and detailed guidelines to help companies comply. They suggest the Commission provide simplified procedures and financial support to assist smaller businesses.12
Why — This would help chemical distributors avoid high administrative costs and maintain competitiveness.34
Impact — Small importers face financial losses and competitive disadvantages due to heavy compliance burdens.56
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Chemical distributors urge minimized administrative burden for CBAM Registry

25 Nov 2024
Topic — This initiative establishes a registry for the EU Carbon Border Adjustment Mechanism.
Message — Fecc requests that reporting requirements be limited to what is necessary to minimise the burden on importers. They ask for more training and guidance materials to help companies use new IT tools. The group also objects to shifting emission calculations to quantity data, which could lead to inaccuracies.123
Why — Lowering reporting obligations would reduce administrative costs and help maintain European market competitiveness.4
Impact — EU consumers may suffer from higher prices as additional costs are added to products.5
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Response to Evaluation of the EU-Japan Economic Partnership Agreement

28 Oct 2024

Fecc acknowledges the consultation on EU-Japan trade agreement evaluation and welcomes the opportunity to provide input. In this consultation we would like to raise the following points: 1. Strengthened Bilateral Cooperation: Fecc endorses the initiative to enhance relations between the EU and Japan, particularly in the areas of trade, investment, and sustainable development. By fostering deeper cooperation in green transitions, renewable energy, and digital innovations, the agreement can create new business opportunities and improve market access for SMEs and family-owned businesses. 2. Market Access and Business Environment: The proposed advanced trade provisions are crucial in improving access for European companies in the Japanese market. Fecc encourages the EU to ensure that these provisions facilitate a more favorable business environment, reducing barriers and promoting smoother trade and investment relations. This will boost the competitiveness of EU-based SMEs and family-owned businesses. 3. Environmental and Safety Standards: Fecc appreciates the EUs focus on promoting sustainable development and safeguarding human rights in the agreement. We urge the EU to ensure that environmental regulations, especially around chemicals, are harmonized with global standards. This will help chemical distributors align with international practices while contributing to sustainability and safety. 4. Reduction of Non-Tariff Trade Barriers: There is still room for improvement, especially in reducing non-tariff trade barriers. For example, the new regulation JAS Standards for organic plants and organic processed foods of plant origin, effective since January 2024 requires the importers name on the JAS label. This is impractical for normal series production, as companies have multiple customers and production occurs in large batches. Some European suppliers have had to establish Japanese companies to process import invoices, incurring unnecessary costs. We advocate for addressing these issues in an amendment to the agreement. 5. Technical Details and Administrative Burdens: The EU-Japan trade agreement, unlike other EU trade agreements, requires the type of rule used to determine preferential origin to be indicated in coded form (e.g., C1 for change in tariff classification or C2 for value-added rule). This requirement is complex and burdensome, especially as multiple EU companies may be involved in the supply chain. Each company must maintain and pass on this coding, necessitating new data fields and system adjustments. We recommend eliminating this specific requirement to reduce unnecessary administrative burdens. Fecc represents chemical, food, and active pharmaceutical ingredients distributors, most of which are SMEs and family-owned businesses. The objectives of this initiative are commendable, and we support efforts to enhance relations between the EU and Japan. Fecc looks forward to continuing its engagement with the Commission to ensure that the agreement benefits both the industry and the broader EU-Japan partnership, promoting economic growth, environmental protection, and a fair regulatory framework.
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Response to Negotiations with Bahrain, Kuwait, Oman, Qatar, Saudi-Arabia and United Arab Emirates

30 Sept 2024

Fecc acknowledges the consultation on EUGulf relations authorising negotiations with Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and United Arab Emirates and welcomes the opportunity to provide input. In this consultation we would like to raise the following points: 1. Strengthened Bilateral Cooperation: Fecc endorses the initiative to enhance relations between the EU and Gulf countries, especially in the areas of trade, investment, and sustainable development. By fostering deeper cooperation in green transitions, renewable energy, and digital innovations, the agreement can create new business opportunities and improve market access. 2. Market Access and Business Environment: The proposed advanced trade provisions are crucial in improving access for European companies in the Gulf region. Fecc encourages the EU to ensure that these provisions facilitate a more favorable business environment, reducing barriers and promoting smoother trade and investment relations, which will boost the competitiveness of EU-based companies. 3. Environmental and Safety Standards: Fecc appreciates the EUs focus on promoting sustainable development and safeguarding human rights in the agreement. We urge the EU to ensure that environmental regulations, especially around chemicals, are harmonized with global standards. This will help chemical distributors align with international practices while contributing to sustainability and safety. Fecc represents chemical, food, and active pharmaceutical ingredients distributors, most of which are SMEs. The objectives of this initiative are commendable, and we support efforts to enhance relations between the EU and Gulf countries. Fecc looks forward to continuing its engagement with the Commission to ensure that the agreement benefits both the industry and the broader EU-Gulf partnership, promoting economic growth, environmental protection, and a fair regulatory framework.
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European Chemical Distributors Support Harmonization but Warn of Disruptions

13 Aug 2024
Topic — The European Commission is updating the list of chemicals subject to international trade rules.
Message — The organization supports aligning EU regulations with international standards to ensure a level playing field. They request transitional support to mitigate supply chain disruptions and financial incentives for compliance and staff training.123
Why — Global harmonization reduces trade barriers and improves the competitiveness of EU chemical distributors.4
Impact — Industries relying on hazardous chemicals could face operational hurdles if regulations do not consider essential uses.5
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Response to Evaluation and revision of the Weights and Dimensions Directive

12 Jul 2024

Please find attached feedback from the European Association of Chemical Distributors (FECC).
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Chemical distributors demand data confidentiality extension alongside biocides review

20 Dec 2023
Topic — EU consultation on extending the review deadline for existing biocidal active substances.
Message — The association demands a legal basis to extend data protection and confidentiality. They argue it is unacceptable for dossier data to become public during evaluations.12
Why — Distributors would protect proprietary information and prevent competitors from accessing their dossiers.3
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Response to Revision of Regulation (EC) 648/2004 on Detergents

26 Jul 2023

Fecc agree with the Commissions assessment (SWD Evaluation of Regulation (EC) No 648/2004) that the aims of the Detergents Regulation are relevant, the rules are consistent and complete, the Regulation has achieved its aims to a large extent. We believe that the sector should continue to be regulated via the Detergents Regulation and not be incorporated into other chemical legislation or moved under the New Legislative Framework. As many detergent products are manufactured by SMEs, the implementation of IT solutions would mean high additional personnel and financial effort for SMEs, which would suffer high impact from such an administrative burden.
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Chemical distributors seek longer transition for green claim rules

21 Jul 2023
Topic — Proposed EU legislation requiring companies to scientifically substantiate their environmental marketing claims.
Message — Fecc requests extending the implementation period to 30 months to avoid administrative delays. They argue that microenterprises should adhere to the same substantiation standards as larger companies. The group also opposes banning green claims for safe products containing hazardous substances.123
Why — This would reduce administrative pressure and maintain market access for many chemical products.4
Impact — Microenterprises would lose the proposed lighter regulatory burden intended to prevent disproportionate impacts.5
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Chemical distributors call for lower reporting burdens under CBAM

6 Jul 2023
Topic — This consultation addresses reporting obligations for importers during the CBAM transitional period.
Message — Fecc requests that reporting requirements are limited to what is necessary to minimize administrative burdens on importers. They advocate for additional training and guidance materials for new IT tools while highlighting the difficulty of switching to quantity-based data.123
Why — Simplifying these requirements would lower compliance costs and protect the market competitiveness of chemical distributors.4
Impact — Third-country exporters and customs authorities face significant costs to overhaul their documentation systems to match EU requirements.5
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Chemical distributors urge simpler sustainability reporting standards

6 Jul 2023
Topic — This consultation defines the technical standards for corporate sustainability reporting.
Message — Fecc requests harmonization between these standards and other EU directives. They call for clearer technical definitions and materiality thresholds. The organization also asks for reporting flexibility for smaller companies.12
Why — Aligning different EU laws would make reporting processes more efficient for companies.3
Impact — Transparency advocates lose out if companies are allowed to use lower audit standards.4
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Chemical distributors support EU ban on hazardous chemical exports

28 Jun 2023
Topic — A proposal prohibiting the production and export of chemicals banned within the European Union.
Message — The association supports the export ban but emphasizes that legislative action must focus on risk assessments rather than just hazard classification. They also call for international harmonization to prevent chemical misuse in developing countries.12
Why — A risk-based approach could allow them to continue exporting substances deemed essential for society.3
Impact — Global health and environment suffer if hazardous chemicals are misused in poorly regulated developing countries.4
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Chemical Distributors Urge Delay and Realism in CLP Revision

30 Mar 2023
Topic — Revision of EU rules on the classification, labelling and packaging of chemical substances.
Message — Fecc requests postponing new hazard classes to ensure global alignment and rejects mandatory formatting rules that hinder multilingual labels. They also advocate for digital labelling and longer transition periods for label changes.123
Why — These changes would prevent high redesign costs and technical hurdles for existing packaging systems.45
Impact — Regulators and emergency responders lose clarity from standardized formatting and immediate hazard updates.67
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Chemical Distributors Urge Practical Approach to High-Risk Substances

8 Jul 2022
Topic — Proposed EU initiative to regulate high-risk chemicals to prevent terrorist misuse.
Message — The association requests that authorities share knowledge on chemical misuse and prioritize the enforcement of existing regulations. They also call for a full impact assessment and cost-benefit analysis before introducing new rules.123
Why — This would prevent regulatory overlaps and ensure new rules are not overly burdensome.45
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Response to Cyber Resilience Act

12 May 2022

Fecc acknowledges the consultation on the Cyber Resilience Act and welcomes the opportunity to provide input. In this context, we would like to raise the following points in this consultation: 1. The synergy between the Cyber Resilience Act and current national initiatives should be put into perspective. Fecc acknowledges that the aim of the proposed act is to enhance and ensure a consistently high level of cybersecurity of digital products and ancillary services. More specifically, a broad range of such products and associated services must be secured throughout their whole lifecycle proportional to the risks. Certain Member States such as Belgium, Estonia, Germany and the Netherlands already have such systems set in-place in various degrees for specific sectors. Fecc calls for the Commission to evaluate the best-practices currently being applied at a Member State level in order to avoid overlapping requirements for digital companies, most of which are start-ups, spin-off or operate at an SME level. 2. Europe’s road to digitalisation and the corresponding cybersecurity that goes along with it, goes hand-in-hand. We have various IT company members that provide regulatory support, in line with competition and compliance rules. Our members go to extreme measures to protect their digital portfolios and client base. The digital boom we have been experiencing in Europe for the past 20 years must also be supported by cyber-attack-resilient innovations at a European level in order to further stimulate such innovations on green and digital transitions. Through this, companies would be ensured that they have the flexibility to provide B2B and B2C services whilst maintaining their long-standing compliance in terms of GDPR, cybersecurity and competition compliance rules. 3. The Commission shall set a system in place that safeguards legal certainty on cybersecurity for servers both within and outside the EU. based on a workshop held by Fecc on the topic of cybersecurity, we request the Commission to integrate the following aspects on the Cyber resilience acts: • Ransomware: Detect systems being sabotaged that are not sufficiently protected • Corporate (CEO) fraud: Support systems put in place that detect manipulation of communication and payment instructions • IoT related risks: Provide guidance on how exploited IoT devices could be better protected by companies As the association that also represents digital companies working with chemical, food and active pharmaceutical ingredients distributors, mainly SMEs, we believe that a cyber-attack-resilient and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Chemical distributors demand reduced reporting and SME protections

12 May 2022
Topic — This consultation seeks to improve EU company law to foster sustainable value creation.
Message — The association requests that the Commission minimize reporting requirements and provide templates or outsourcing options for SMEs. They also call for an impact assessment on how supply chain rules indirectly burden small businesses.123
Why — These measures would lower administrative costs and protect smaller members from indirect regulatory burdens.45
Impact — Non-EU exporters may face stricter border enforcement and surveillance of their sustainability standards.67
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

8 Apr 2022

Fecc acknowledges the consultation for the upcoming initiative on streamlining scientific assessments (link). At the same time, we would like to raise the following points in this consultation: 1. Risk assessment should be maintained at the corresponding level of expertise for each agency. Many of the products assessed are subject to a pre-market authorisation that implies the assessment of their safety for human consumption by the EFSA. Some of these ingredients are also used for non-food purposes and may undergo various streams of safety assessment by other EU agencies like EMA and ECHA. While various EU and national agencies play an integral role to advise and provide input, risk assessment should however remain for food and feed ingredients should remain in the remit of EFSA, owing to the scope and expertise of the authority in oral exposure assessment and guidance documents that consider the specifics of oral ingestion and the related end points etc. 2. Manpower and the financial means of Member States should be consistent. Pursuant to Commission Regulation (EC) No 1881/2006, Member States are requested to examine samples and provide necessary data that could lead to a comprehensive risk assessment. Despite the European scope of the risk assessment, means to support such data collection is still largely maintained at a Member State level, which may lead to national authorities providing data with too much variability. Fecc sees this initiative on streamlining scientific assessments as an opportunity for the Commission to support the integral role that national authorities and European Reference Laboratories do to ensure the conclusions taken from these studies and guidance documents are as robust as possible. 3. The role of the industry in this initiative must be clearly defined and supported. Fecc advocates for a long-term supply chain and business model that is resilient, most especially with the current political atmosphere post-COVID, post-Brexit and supply chain disruptions due to the Russian war in Ukraine. Community support must embrace a broader sector of the industry to ensure that safe and sustainable products are valued. Due to overlapping requirements, the expense to producers and distributors is a major concern for the European wholesale sector. Fecc requests the Commission to consider the effects of these overlaps on the level playing field for industry, for SMEs, with the target to clear them to reduce complexity in line with the Commission's Better Regulation agenda. As the association representing chemical, food and active pharmaceutical ingredients distributors, most of which are SMEs, we believe that product safety and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission to pursue sustainable, future-oriented solutions in this area.
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Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

28 Oct 2021

Fecc acknowledges the consultation for the upcoming initiative on revising the Cosmetics Products Regulation under the Chemical Strategy for Sustainability. At the same time we would like to raise the following points in this consultation: 1. The reattribution of tasks between EU agencies must be accompanied with the proper scientific and regulatory support: In line with the objectives of the Chemical Strategy for Sustainability (CSS), we support the strategy’s objective to further simplify the chemicals legislations across sectors. However, with recent plans to redesignate mandates from Scientific Committee on Consumer Safety (SCCS) to the European Chemicals Agency (ECHA) when it comes to providing opinions on health and safety risks, the Commission must ensure ECHA is well-equipped in terms of the regulatory and scientific expertise. The assessments of cosmetic ingredients remain under cosmetic expertise, and as we expect ECHA to take on more tasks and mandates during this transition period, the appropriate resources for such assessments should be maintained to provide a reasonable time period for the safety evaluation. 2. A clear definition of what constitutes a nanomaterial must be streamlined: In the SCCS report on testing and safety evaluation of cosmetics (SCCS/1628/21), it was concluded that currently there are uncertainties with regard to whether the endpoints identified by the current testing methods will be sufficient to identify and characterise all the hazards that may be associated with a nanomaterial. However, the SCCS has also published a number of scientific opinions in the past few years on the nano-form of different materials, which are (but are not limited to) sunscreen products (ETH50), products containing zinc oxide and colloidal silver. These opinions have been comprehensively prepared by the SCCS, along with data that industry has provided over the years to ensure that the safety assessments on nanomaterials are as robust and data-driven as possible. Should the mandate on nanomaterials be shifted under ECHA’s role and responsibility, we request that ECHA further builds up on these SCCS opinions as much as possible when reviewing the options on the current definition used in the Cosmetic Products Regulation. Given ECHA’s role in REACH and CLP, an alignment with other chemical legislations would be valuable as it would ensure a coherent application across European legislation. 3. The role of the industry in this initiative must be clearly defined and supported. Fecc advocates for a long-term supply chain and business model that is robust and resilient. Regulators should also acknowledge the industry-led initiatives that have been set up when it comes to cosmetics safety assessment and quality control. Fecc for example, has set up a working group to streamline safety, sustainability and quality requirements for cosmetic ingredient distributors through a questionnaire. Fecc requests the Commission to consider these examples of best practices and how it supports companies, especially for SMEs, with the target to reduce administrative burdens and complexity in line with the Commission's Better Regulation agenda. As the association that represents cosmetic ingredient distributors, most of which are SMEs, we believe that cosmetics safety and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to Sustainable food system – setting up an EU framework

21 Oct 2021

Fecc acknowledges the consultation for the upcoming initiative on Sustainable EU Food systems. At the same time we would like to raise the following points in this consultation: 1. Food safety and sustainability must go hand-in-hand: In line with the objectives of the farm to fork strategy, we urge the Commission to put food safety and a science-based approach at the forefront of the sustainable food system initiative. This should be based on the successes and lessons learnt from the general food law's implementation. Food safety should never be jeopardized, and the outstanding progress made in this area thanks to the collaboration of all essential supply chain actors must be preserved. As previously discussed in the Fecc feedback on the TRACES database, for example, national competent authorities must ensure a reasonable time period for the implementation of food safety and sustainability regulations. 2. A clear definition of the roadmap is paramount to ensure optimal implementation: At the moment, the divergences in understanding and consensus on what defines a sustainable food system within and outside the EU results to unaligned views when it comes to regulation implementation. As a result, companies that operate in more than one country within the EU may need various implementation plans to reduce food waste during food production and distribution. Vital information exchanged through Rapid Alert System for Food and Feed (RASFF) have resulted in products being recalled from the market, and rightfully so. A robust system, which has matured over the years, RASFF continues to show its value to ensure food safety in the EU and beyond. However, despite the establishment of the RASFF, the approach on food recalls from third countries differ from each Member State. Some countries carry out direct disposal, while other countries maintain possibilities for a non-food utilisation, or are given the option to bring it back to either the supplier, or third countries with different thresholds. We request the Commission to also consider streamlining the process when it comes to food recalls and ensure that implementation is aligned across all Member States. 3. The role of the industry in this initiative must be clearly defined and supported. Fecc advocates for a long-term supply chain and business model that is robust and resilient. Various incentives are currently being offered by the EU and other national governments for "green initiatives," particularly for academic stakeholders and start-ups. Community support must embrace a broader sector of the industry to ensure that mass-produced sustainable products are valued. The expense to producers and distributors owing to overlapping requirements is a major concern for the European food and feed wholesale sector. Fecc requests the Commission to consider the effects of these overlaps on the level playing field for industry, for SMEs, with the target to clear them to reduce complexity in line with the Commission's Better Regulation agenda. As the association that represents food and food ingredient distributors, most of which are SMEs, we believe that food safety and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to The certificate of inspection and the official controls at the entry into the Union of organic products

7 Jul 2021

Below are the main inputs we provide for the official controls form (Ref. Ares(2021)3871488) • Box 1 - The annex must also be provided in the other official languages of the EU, to accommodate specific concerns from national control authorities • Box 2 - In part 1 of the annex, it should be clarified that sections 2 to 18 are to be filled by the control authority. This information is only available at the end of the document, which may lead to confusion for both the issuing control authority and the importer in question • Box 3 - The information must be in line with implementing regulation (EU) 2019/1715, with respect to the links that are necessary between the Animal Diseases Alert (ADIS) system and TRACES. This is in view of ensuring that relevant data concerning union notifications are automatically exchanged or made available in both systems, and providing relevant information to network members. • Box 14 - As the information of the container number is optional, this must be explicitly written in the form itself, and not only in the annex • Box 15 - As the information of the seal number is optional, this must be explicitly written in the form itself, and not only in the annex • Box 16 - The unit of measurement in gross weight must be explicitly written in the form itself, and not only in the annex
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Chemical distributors urge pragmatic REACH revision to protect SMEs

31 May 2021
Topic — Revision of EU rules on registration, evaluation, authorisation and restriction of chemicals.
Message — The organization requests a realistic transition timeframe, science-based substance identification, and harmonized enforcement across Member States. They specifically advocate for support in streamlining administrative communication procedures for supply chains.123
Why — These measures would reduce administrative burdens and prevent discriminatory national rules that weaken the single market.45
Impact — Non-EU manufacturers and EU importers face higher compliance risks due to monitoring gaps in environmental footprint data.6
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Chemical Distributors Urge EU Alignment with Global Standards

31 May 2021
Topic — A targeted revision of EU rules on classifying, labelling, and packaging chemical substances.
Message — The organization advocates for sticking to the UN Globally Harmonized System rather than creating unique EU criteria. They request simplified reporting to avoid bureaucracy and streamlined rules for online sales and multilingual labels.123
Why — This would lower administrative burdens and prevent costly re-labelling for products exported outside Europe.45
Impact — EU regulators lose the ability to implement stricter, independent hazard criteria ahead of global consensus.67
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Chemical distributors seek easier compliance and longer transition periods

6 Apr 2021
Topic — Updating food supplement rules to align with new EU transparency requirements.
Message — The organization requests better access to submission systems and support for smaller companies to meet transparency obligations. They also call for longer transition periods and earlier notification of data requirements.123
Why — These changes would reduce administrative pressure and ensure market continuity for their products.45
Impact — Regulators and transparency advocates may face slower implementation of safety assessment updates.6
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Response to Instrument to deter and counteract coercive actions by third countries

16 Mar 2021

Fecc acknowledges the roadmap proposed on ‘Trade disputes – mechanism to deter & counteract coercive action by non-EU countries’ and the measures proposed to allow the EU to address practices by non-EU countries that seek to pressure on Member States. In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent. Please see the attached file for the full feedback.
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Response to Digital Levy

10 Feb 2021

While acknowledging the consultation for a fair and competitive digital economy Fecc would like to raise the following points: 1. On the scope and definition of digital activities/transactions or companies subject to the initiative - Fecc welcomes the initiative of the Commission and the national Competent Authorities to further promote digitalisation within the EU, provided that it is in accordance with the following premises of the articles of this regulation: European Council document EUCO 10/20 - In its own conclusion of the European Council meeting on 20 July 2020, expenditures concerning digital services are promoted under the European Strategic Investments Platform to foster the competitiveness of SMEs. In ensuring funding and financial incentives are available for SMEs to further invest in digitalisation, Europe’s digital transformation would be facilitated at a rate that these platforms become the norm rather than the exception. A digital levy for SMEs and start-ups within the EU would defeat the purpose of the European Strategic Investments platform. The 'fairness consideration' clause should remain in the proposal in order to take into account the possible impact on SMEs, particularly on digital companies with less means, which are struggling with the overlapping European and national regulatory frameworks that are in place. 2. On the role of the chemical distribution industry in digitalisation – The proposal for an EU-wide tax levy should be targeted to multinational e-commerce platforms that particularly choose to set their headquarters in countries with favourable national tax regimes, also in terms of creating a global level playing field. Digital platforms in the chemical industry, on the other hand, have zero to minimal digital footprint and are still in their infancy. If an extraordinary levy or tax is applied, the chemical industry could be disincentivized to further digitise the transactions in a moment where such transactions are gaining more market share. 3. On the fair implementation of B2C services in the EU - Fecc believes that the EU should encourage commerce to be conducted in a digital manner. It could be advantageous for any company, especially SMEs, to be encouraged to conduct commerce online. We request the Commission to consider the position of the chemical companies' in this digital transformation and to further stimulate industries with emerging digitalised services through financially incentivizing SMEs to promote digital platforms as stipulated in the EU Digital Strategy. A digital levy would have the opposite effect and would disproportionately impact companies in our sector that have already invested in digital solutions for their customers. As the association that represents chemical distributors, most of which are SMEs, we believe that innovation, digitalisation and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to Revision of EU rules on food contact materials

25 Jan 2021

Fecc acknowledges the consultation on the Revision of EU rules on food contact materials. Fecc would like to raise the following points in this consultation: 1. The harmonisation on EU rules pertaining to food contact materials (FCMs) should be taken into perspective. Although rules at a Member State level exist, the fragmented implementation of these rules results to the reduced production and distribution of FCMs. We agree that systems must be in place to ensure a harmonised implementation of EU-wide rules and the measures should be clear and must bring pragmatism, particularly for SMEs that are in the forefront of producing and distributing these materials. Fecc welcomes the continued approach of the Commission and the national competent authorities to examine data submitted by interested business operators, provided that it is in accordance with the following premises of the articles of Regulation (EC) No 1935/2004: Section 23 – ‘Community and national reference laboratories should be designated to contribute to a high quality and uniformity of analytical results.’ In order to harmonize EU rules on FCMs, the Commission must ensure that community and national reference laboratories are equipped with the proper tools and conduct the same sampling methods and quality controls between Member States. Section 27 – ‘It is necessary for business operators to have sufficient time to adapt to some of the requirements established by this Regulation.’ Through these legislative safeguards, Fecc requests the Commission to provide business operators a reasonable transition period for any substances that may be included in this Inception Impact Assessment (IIA). 2. Safety and circularity checks is paramount and must go hand-in-hand - To ensure business operators are complying with existing regulations, standardised methods of sampling and analysis need to be developed and fully enforced. This prevents the need for multiple testing brought about by overlapping regulations at a national and EU level. This consistency on compliance should be the case for both safety and recyclability requirements on FCMs. The industry supports the innovation opportunities that this IIA may present but in order for this to be met, Fecc requests the Commission to consider the necessary steps to ensure that products are both safe, durable and sustainable via this initiative. 3. Enforcement of existing rules must also be considered in the IIA, including third country operators. - Fecc would like to raise the following point of enhanced monitoring, pursuant to Article 28 of Regulation 2017/625 (the Official Controls Regulation). Fecc calls for the Commission to enhance its monitoring efforts when it comes to FCM monitoring or substance exclusion that may be proposed in this initiative. The consultation note's proposal to pursue a model of a risk-based assessment will not work without comprehensive surveillance of third-country imports and only result in (1) the undermining of EU producers and service-providers, (2) the decrease of the EU market share and (3) unnecessary regulatory roadblocks due to internal bureaucratic delays. As the association that represents food and food ingredient distributors, most of which are SMEs, we believe that food safety and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to Amendment of the IMSOC Regulation as regards the functioning of ADIS, EUROPHYT and TRACES

18 Jan 2021

Fecc acknowledges the consultation to amend Regulation (EU) No 2019/1715 on the integrated management system for official controls (IMSOC). Fecc would like to raise the following points in this consultation: 1. On the Trade Control and Expert System for exchanging data, information and documents (‘TRACES’) - Fecc welcomes the continued approach of the Commission and the national competent authorities to examine data submitted by interested business operators, provided that it is in accordance with the following premises of the articles of this regulation: Article 134 thereof, section 1 - That the national competent authorities will ensure the notification to other member states without undue delay, as stipulated in Article 21 on (Fraud notifications). Operators should also be provided a reasonable time period for data collection and reporting for food products under notification. Article 134 thereof, section 5 – We support the initiative to be included in implementing regulation (EU) 2019/1715, with respect to the links that are necessary between the Animal Diseases Alert (ADIS) system and TRACES. This is in view of ensuring that relevant data concerning union notifications are automatically exchanged or made available in both systems, and providing relevant information to network members 2. On the Animal Diseases Alert (ADIS) system - Fecc supports the Article 29 amendments and we encourage the Commission to take into account the following: Article 29a – We support the 29a amendment that that personal data from union notifications and union reports referred to in Article 29(1) will be stored in ADIS for no more than 10 years, provided that it complies with Article 5(1)(e) of the Directive 95/46/EC (General Data Protection Regulation) Article 29b – With regards to contingency arrangements, we support the amendment that where ADIS is unavailable, the ADIS network contact points shall submit the data and information concerning union notifications and union reports referred to in Article 29(1) via email or by other means specified on the Commission’s website 3. On the issuance of electronic certificates for consignments - Fecc also seeks that the Commission to provide clear recommendations in terms of action points in the event that a third country’s or an international organisation’s electronic certification system is not compatible with that of TRACES, or is not GDPR compliant. As the association that represents food and food ingredient distributors, most of which are SMEs, we believe that food safety and a sound regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to Amending the rules concerning the re-evaluation of approved food additives in view of the “Transparency Regulation”

28 Oct 2020

Fecc acknowledges the consultation to amend Regulation (EU) No 257/2010 in setting up a programme for the re-evaluation of approved food additives. In this consultation we would like to raise the following points: 1. On data submission - Fecc welcomes the continued approach of the Commission and EFSA to examine data submitted by interested business operators, provided that it is in accordance with the following premises of the articles of this regulation: Article 5 - That EFSA will allow a reasonable time period for data collection for food additives under safety re-evaluation, and its reaction and fate in food. Article 6 - That EFSA continues to make the request for additional information well in advance for better alignment between EFSA, business operators, the Commission and other concerned parties 2. On EFSA opinions and pre-submission advice - Fecc supports the Article 7a and 7b amendments and we encourage the Commission to take into account the following: Article 7a – We support the 7a amendment that stakeholders may request EFSA to further collect data in order to complete safety assessment. Article 7b – With regards to pre-submission advice, Fecc supports the 7b amendment that business operators may request that EFSA provides advice on the rules or recommendations. 3. On Commission recommendations post EFSA assessment - Fecc also requests the Commission to provide clear recommendations in terms of action points in the event that the EFSA safety assessment concludes no significant risks due to insufficient data. This is paramount in order to ensure that both safety and regulatory alignment is maintained, should EFSA be unable to confirm the safety of a food additive in its preliminary opinions. 4. On Commission compliance with the Union list of approved food additives - Fecc also requests the Commission, through the information gained from EFSA’s advice, to provide a reasonable transition period for business operators in the event of the following scenarios: - When a food additive must be removed in the Union list of approved food additives. - When a non- food additive substance (enzyme, colourant, carrier) is classified as a food additive under the European Commission MEMO/11/783 definition of the term. - When a food additive is already available on the market prior to an EFSA safety assessment, and provided that the safety assessment concludes no significant risks. As the association that represents food and food ingredient distributors, most of which are SMEs, we believe that food safety and a sound, consistent regulatory framework go hand-in-hand. We would be happy to engage further with the Commission in the pursuit of sustainable, future-oriented solutions in this area.
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Response to Sustainable Products Initiative

28 Oct 2020

Fecc supports Sustainable Products Initiative roadmap and the measures proposed to assess the presence of certain chemicals in products present in the EU market. In this context we would like to raise the following points on behalf of the European chemical distribution sector and in particular the many SMEs we represent: - The synergy between the Sustainable Products Initiative and the Chemical Strategy for Sustainability (CSS) should be put into perspective. When the CSS was published last 14 October 2020, one of the Commission proposals in the strategy was to extend the generic approach to risk management and ensure products do not contain persistent substances. This general approach in the CSS defeats the purpose of the Sustainable Products Initiative in improving the durability of EU products as a number of polymers synthesized are inherently persistent in order for durability to be a key component during its production. The industry supports the innovation opportunities that these strategies present but in order for this to be met, Fecc requests the Commission to consider the necessary steps to ensure that products are both safe, durable and sustainable via this initiative. - Fecc supports both a sustainable supply chain and business model. The EU and other national governments are currently offering various regulatory and financial incentives for “green initiatives”, particularly for academic stakeholders and start-ups. With the EU Green Deal being a game-changer, support from the community must include a wider part of the industry in order to ensure that sustainable products manufactured en-masse are valorised. A main issue for the European chemical wholesale sector is the cost to manufacturers and distributors due to overlapping regulations. Fecc requests the Commission to consider the effects of these overlaps on the level playing field for industry, in particular for SMEs, with the target to clear them to reduce complexity in line with the Commission´s Better Regulation agenda. - EU Sustainability requirements should be further monitored and enforced at external EU borders. The EU expects high-quality and durable products from its local manufacturers and the same should be expected from all third countries that conduct trade with the EU. Fecc calls on the Commission to enhance the monitoring efforts when it comes to EU sustainability requirements that may be proposed in this initiative. Setting up an additional requirement without the comprehensive surveillance of third country imports and consistent enforcement rules results in: (1) the undermining of EU-based producers and service-providers, (2) the decrease of the EU market share and (3) unnecessary regulatory roadblocks due to an uneven level playing field. Fecc acknowledges that the Sustainable Products Initiative, along with the other EU Green Deal strategies, signals a regulatory paradigm shift for the European Chemical industry. Fecc and the distribution sector see this also as an opportunity to further promote safe and sustainable innovation, if it can be implemented in a pragmatic and cost-efficient way without compromising the overall targets. We look forward to further working with the Commission to establish a coherent regulatory framework and ensure that sustainability is not only an option, but rather the norm.
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Response to Pharmaceutical Strategy - Timely patient access to affordable medicines

5 Jul 2020

Fecc acknowledges the new EU pharmaceutical strategy and supports the initiative to ensure safe and affordable medicines within the region. Nonetheless, we would like to raise the following points in this roadmap document on behalf of the European chemical distribution sector and in particular, the many SMEs we represent: • The COVID-19 pandemic has shown how reliant the EU is on third countries when it comes to pharmaceuticals. However, the pandemic has also shown that the Commission can identify processes to simplify or fast-track methodologies for regulations without compromising compliance, most especially when it comes to mitigating medicines shortages and to ensure efficient distribution of medicines within the Member States. In the light of these recent developments, the Commission has already stated their determination to launch an initiative to “repatriate pharmaceuticals”. As such, Fecc acknowledges the steps the Commission has taken so far in order to support the industry and encourages the EU Institutions to move further in this direction. • Fecc looks forward for this support to continue and expand post COVID-19. This would alleviate the regulatory burden significantly, especially for the SMEs which are suffering a lot from regulatory complexity, combined with substantial resource constraints, while not compromising the EU´s health, safety and environmental standards. • Supporting the industry is paramount to ensure medicine affordability, safety, and availability within the region. The EU and other national governments are currently offering a lot of regulatory and financial support for pharmaceutical stakeholders when it comes to research and development. However, support from the sector must include a wider part of the supply chain. A main issue for the European pharmaceutical sector is the cost to the manufacturer due to overlapping regulations. Fecc requests the Commission to consider the effects of these overlaps on the level playing field in the pharmaceutical industry, most especially for the SMEs. • The EU expects high-quality medicines from its local manufacturers and the same should be expected from all third countries that conduct trade with the EU. Fecc calls for the Commission to increase monitoring and stricter enforcement when it comes to trade and imports of pharmaceuticals. Pharmaceutical quality (safety) and quantity (availability) must go hand-in-hand and without these considerations, the Commission may find it challenging to ensure that the EU pharmaceutical industry remains competitive. Through this new EU Pharmaceutical strategy, collaborations between the industry, academia and public bodies could be developed further in support of the EU Pharmaceutical sector and neighbouring value chains. We would be happy to engage further with all regulators in the pursuit of sustainable, future-oriented solutions in this area.
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European Association of Chemical Distributors seeks harmonized rules and recycling

19 Jun 2020
Topic — The European Commission’s strategy to ensure a toxic-free and sustainable chemical environment.
Message — Fecc requests a more harmonized approach between chemical regulations regarding substance identity. They encourage the Commission to explore reusing high-quality second-hand chemicals as resources. Stricter enforcement is also sought to maintain a level playing field for small businesses.123
Why — Standardized identity testing and chemical recycling would reduce costs and enable new business models.45
Impact — Environmental advocates lose if the goal to completely remove toxins is abandoned or generalized.6
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Response to Revision of the Regulation on marketing and use of explosives precursors

13 Jun 2018

The European Association of Chemical Distributors (Fecc) welcomed the opportunity to engage in the consultation phase of the Regulatory Proposal and wishes to submit the following comments (please see file attached) to the Proposal itself.
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Response to Evaluation of legislation on trade in drug precursors

15 Sept 2017

Fecc believes that the current regime with three categories of substances with different and proportionate levels of control is "fit for purpose" for distributors. The number of distributor companies in Europe that sell or use Categories 1 or 2 drug precursors is limited, and the current system works. Fecc requests that DG GROW and DG TAXUD maintain a proportionate and pragmatic approach to this issue, and would be ready to engage in the work to be undertaken (consultations, targeted questionnaires...) to enable the Commission to report by 31 December 2019 on the implementation and functioning of Regulation (EC) No. 273/2004 and Council Regulation (EC) No.111/2005.
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Response to Revision of the Regulation on marketing and use of explosives precursors

26 Jun 2017

Fecc notes the Combined Evaluation Roadmap / Inception Impact Assessment from the Commission and welcomes the opportunity to provide feedback and comment in more detail (please see file attached). Fecc requests that DG HOME maintains a proportionate, pragmatic and sustainable approach to this issue, and undertakes a full Regulatory Impact Assessment and cost-benefit analysis, prior to making any changes to the current regime. Fecc is ready to continue the constructive collaboration with DG Home. Fecc supports further exploration of policy option 2 (please see details in file attached).
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

21 Mar 2017 · Reach evaluation