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EUROPEAN CHEMICAL REGIONS NETWORK

ECRN

The European Chemical Regions Network is an international non-profit association that promotes the European chemical regions.

Lobbying Activity

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

2 Sept 2025 · Follow up Chemical Industry AP

Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

22 Jul 2025

The European Chemical Regions Network (ECRN) welcomes the European Commissions draft Implementing Decision laying down rules for the calculation, verification, and reporting of recycled plastic content in single-use plastic beverage bottles, in line with Directive (EU) 2019/904. This proposal addresses critical gaps in reporting methodology and marks an important step forward in aligning plastic recycling rules with Europes circular economy and climate ambitions. As underlined in the European Chemical Regions Network (ECRN) Position Paper on Advancing Plastic Recycling, effective plastic recycling must be underpinned by clear definitions, consistent reporting, harmonised methodologies, and SME-friendly implementation to ensure both environmental integrity and industrial competitiveness. We strongly support the Commissions decision to integrate mass balance accounting (MBA) as a methodology for chemical recycling outputs. ECRN advocates for a harmonised EU framework for MBA that is transparent and traceable. Clear definitions of eligible material and attributed amounts across all recycling streams should also be defined. ECRN welcomes the acknowledgment that chemical recycling complements, but does not replace, mechanical recycling. We believe the two approaches should be seen not in competition but as parts of a single, integrated recycling system. To make this integration effective, more investment in sorting, pre-treatment, and digital tracking technologies is neededespecially to support the uptake of chemical recycling in small and medium-sized enterprises (SMEs) and regional facilities. We appreciated the inclusion of all beverage bottle componentscaps, lids, labels, and sleevesin the calculation of recycled content. However, to fully support circularity, the role of additives must be addressed. Certain substances can impair recyclability or reduce output quality. We recommend developing EU-level guidelines for safer additives, aligned with design-for-recycling principles and supported by targeted incentives through extended producer responsibility schemes. ECRN supports the reduced burden for SMEs in the verification regime (verification every 3 years instead of annually). We encourage the Commission to further support SMEs through targeted funding, training and technical assistance to ensure compliance and innovation capacity. To prevent fragmentation and increase compliance, ECRN supports the Commissions efforts to establish a harmonised EU framework for data collection, reporting, and verification. In line with the Interoperable Europe Act, this Decision must also ensure full digital traceability and comparability across Member States. ECRN recognizes the importance that the rules for recycled content also account for imports. Traceability and verification of plastic waste treated outside the EU must be subject to the same standards as those applied within the Union. This is necessary to maintain a level playing field and protect the integrity of the internal market for recycled materials.
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Response to Critical Medicines Act

2 Jul 2025

The European Chemical Regions Network (ECRN) strongly supports the objectives of the Critical Medicines Act, recognizing the strategic importance of securing the supply and accessibility of essential medicines across Europe. As an alliance representing diverse chemical regions, we underline the necessity for cohesive, inclusive, and regionally balanced approaches to pharmaceutical and chemical sector resilience. ECRN emphasizes the imperative to bolster Europe's strategic autonomy in pharmaceutical production, aligning closely with our broader agenda of enhancing European chemical sector competitiveness. Current dependencies, particularly on non-EU sources for active pharmaceutical ingredients (APIs) and intermediates, pose significant risks to supply stability and health security. To address these vulnerabilities, we propose: EU-level assessments must be holistic and dynamic, considering the complete vulnerability profile of supply chains rather than solely the severity of medical conditions treated. Incentives for pharmaceutical production and innovation should be strategically inclusive, catering to companies of all sizes, ensuring fair competition among regions and avoiding disparities caused by national fiscal capacities. Current EU state aid constraints need reconsideration. We advocate for regulatory frameworks that enable agile investment responses, allowing for broader and faster deployment of resources such as IPCEI and STEP, while ensuring technological neutrality. The complexity and overlapping requirements in pharmaceutical regulation currently impose significant administrative burdens, increasing costs without corresponding benefits. Specifically, we propose: Leverage existing frameworks such as the European Medicines Verification System (EMVS) rather than imposing new reporting obligations. Move away from fragmented national stockpiling mandates towards coordinated European strategic reserves, reducing logistical inefficiencies and unnecessary financial burdens. ECRN strongly supports a procurement strategy that balances affordability with supply security: Criteria for pharmaceutical procurement must extend beyond pricing to include supplier diversification, reliability, and sustainability. Joint procurement mechanisms should be selectively employed and clearly defined, avoiding market rigidity and preserving the agility needed to respond to regional and local supply contexts. In conclusion, the pharmaceutical sector must integrate sustainability principles without compromising industrial competitiveness. Accordingly, it is necessary to ensure that new environmental regulations, including those on micro-pollutants and substances like PFAS, align realistically with industrial capabilities and strategic autonomy goals.
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Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

16 Jun 2025 · To discuss the future of the chemical industry and ECRN's contribution to future initiatives

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

30 Jan 2023

Ensure that circular business models are incentivized considering their environmental benefits and facilitate a secure and high-quality supply of secondary raw materials by: - Strengthening the role of the chemical sector in the processing of waste and the high-quality use of renewable raw materials. - Creating a stable and balanced tax regime in Europe for landfilling and burning of waste. Landfilling and burning cannot be still cheaper than reusing and recycling. Some exceptions can be accepted e.g., shipment for recovery from landfills if these waste materials are supposed to be used for a certain purpose or creating installations for thermal waste treatment, because thanks to this type of installations, the waste will be processed in an environmentally safe manner. - Taking the appropriate measures that are needed, such as CO2 taxation on a European scale. The introduction of a CO2 tax is urgently requested. Moreover, additional compensation for a recycler who reduces CO2 production is an even greater incentive. So not only a negative impulse for the production of additional CO2 but also a stimulus for the reduction of CO2. - Encouraging the recycling companies with certain that their investments make sense, and they can have access to the standardized quality of waste. - Providing EU financial support for scaling up and further development of research and innovations of chemical waste recycling with a special focus on SMEs as the key players in the market that take the highest risk of the application of new technologies. - Supplementing the appropriate infrastructure for the management of the residual municipal waste streams, such as the thermal waste treatment installations, to reduce the amount of waste sent to landfills. Nevertheless, it is crucial to highlight that these should be seen only as provisional solutions in the transition toward circularity. The priority should be to invest in technologies that can handle all organic waste in a more efficient way. For example, the FUREC project developed by RWE aims to develop a waste-to-hydrogen plant at the Chemelot industrial site in Limburg. The objective is to process waste streams from the region and convert it to circular and green hydrogen, to be applied in the chemical sector. - Increasing the capabilities of Member States and the Commission to reduce illegal shipments of waste. Actions against waste trafficking should be one of the priorities of the EUs overall policy. The estimated benefits linked to better treatment of residual waste in the EU and to avoid shipping this waste to third countries ranges between EUR 266-666 million a year.
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Response to European Critical Raw Materials Act

22 Nov 2022

In the last years, the European Commission undertook multiple initiatives to boost the European industry and make it more competitive globally, such as The New Industry Strategy or The EU Chemical Strategy for Sustainability Towards a Toxic-free Environment. All these actions are supposed to lead us to the green and digital transformation of the European industry and enhance Europes strategic autonomy. The EUs security and defense capabilities are fragmented, which has increased strategic dependencies over the past few years. The COVID-19 crisis has strongly affected the EU economy. Its impact varies across ecosystems and company sizes. The crisis exposed the dependencies of global value chains and demonstrated the crucial role of critical raw materials and offshore supplies. It was especially visible in the chemical and pharmaceutical sector which struggled with access to the components and ingredients. Many companies experienced dramatic exposure to supply chain disruptions during the pandemic and the subsequent lockdowns due to their reliance on offshore supplies. When the market slowly recovered after the pandemic, the war in Ukraine has started. Another aspect that must be taken under consideration is the enormous demand for resources (energy, food, and raw materials) that puts extreme pressure on the planet, accounting for half of greenhouse gas emissions and more than 90% of biodiversity loss and water stress. Scaling up the circular economy will be vital to achieving climate neutrality by 2050 while decoupling economic growth from resource use and keeping resource use within planetary boundaries. The supply of many critical raw materials is highly concentrated. For example, China provides 98 % of the EUs supply of rare earth elements (REE), Turkey provides 98% of the EUs supply of borate, and South Africa provides 71% of the EUs needs for platinum and an even higher share of the platinum group metals iridium, rhodium, and ruthenium. The EU relies on single EU companies for its supply of hafnium and strontium. The risks associated with the concentration of production are in many cases compounded by low substitution and low recycling rates. We need to learn from these lessons and realize that the European industry and the chemical one especially is facing an extraordinary number of challenges now. The European regions that are dealing with the consequences of these crises on the ground want to take the frontrunners' role in supporting the European chemical industry as its strength and autonomy are essential to the well-functioning and integrated markets and to secure the safety of citizens. The ECRN welcomes the establishment of the Raw Material Alliance in 2020 which aims to build resilience and strategic autonomy for Europe's rare earth and magnet value chains. It should identify barriers, opportunities, and investment possibilities in the raw materials value chain, while also addressing sustainability and social impact. However, we can observe the very low level of the Alliances activities recently which is unusual in the current circumstances. Our aim is to significantly contribute to the ongoing EU legislation and bring the regional perspective to the attention of the European Commission. The ECRN welcomes the establishment of the Raw Material Alliance in 2020 which aims to build resilience and strategic autonomy for Europe's rare earth and magnet value chains. It should identify barriers, opportunities, and investment possibilities in the raw materials value chain, while also addressing sustainability and social impact. However, we can observe the very low level of the Alliances activities recently which is unusual in the current circumstances. Our aim is to significantly contribute to the ongoing EU legislation and bring the regional perspective to the attention of the European Commission.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

The European Chemical Regions Network (ECRN) is striving for a circular economy. A fully circular economy starts with smart design and the use of discarded materials for products with an equal or higher value. Waste flows are not limited to regional and national boundaries. That is why the waste policy should be developed and implemented at the European level to guarantee harmonized rules for all stakeholders and to protect the environment and human health against the adverse impacts that could be caused by the improper shipping or management of waste.
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Response to Chemicals strategy for sustainability

19 Jun 2020

The EU chemical industry can be a key contributor to the energy transition, climate change mitigation and to other EU policy objectives, like the circular economy and sustainability. To successfully achieve this transformation, it requires a complete structure, spanning basic chemicals, specialty and fine chemicals as well as consumer chemicals, i.e. entire value chains. However, given the easily tradable nature of many chemical products and the international nature of the sector, this will only be possible if the competitiveness of the EU chemicals sector can be maintained. For these objectives to be realized - and for the EU chemicals sector to maintain its status as a world leader - EU policymakers must put in place a suitable regulatory environment, in which industrial competitiveness is mainstreamed into all other EU policies (including those on energy, climate, innovation and chemicals safety). ECRN welcomes a new Chemicals Strategy for Sustainability that will help better protect people and the environment against hazardous chemicals and encourage innovations in the sector to develop safe and sustainable alternatives. Priority issues and recommendations are attached.
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