European Chemical Society
EuChemS
EuChemS aisbl – European Chemical Society - is a non-profit making association.
ID: 03492856440-03
Lobbying Activity
Meeting with Annalisa Corrado (Member of the European Parliament)
14 May 2025 · Rare Earth Elements
Response to European Critical Raw Materials Act
26 Jun 2023
In addition to the EuChemS' response to the Public consultation on this topic at the end of last year, the European Chemical Society wants to add the following feedback on the European Critical Raw Materials Act: We recommend adding Phosphorus (P4) and Purified Phosphoric Acid to the Strategic Raw Materials (sub)List, as both are supply-critical and are essential for the designated Strategic industry sectors (renewable energies, batteries, electronics, aerospace). Furthermore, EuChemS proposes to recognise food security as a strategic priority for Europe. We suggest to identify raw materials critical for food production as strategic, however, we recognise that this may be beyond the scope of the current CRM Act proposal.
Read full responseResponse to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
25 Jun 2021
The European Chemical Society (EuChemS), an international organisation comprising 50 member societies from Europe and beyond and having had a representative on the EC’s High Level Expert Group Open Science Policy Platform (OSPP) 2016-2020 welcomes the Commission’s initiative to clarify and harmonise data sharing provisions across the EU and especially B2G data sharing rules, which do remain unclear for part of the scientific research community.
Smooth and safe data sharing and dissemination are essential to scientific advancement, and we strongly believe that a common EU data space for a European Single Data Market would be highly beneficial to future research while reducing administrative burden on researchers.
High compatibility and interoperability also are crucial elements to unhindered scientific data sharing. This is why EuChemS supports the blockchain approach and the possibility “to define essential requirements for smart contracts’ interoperability” which is to be enshrined in the upcoming Data Act, while insisting on the need for specific guidelines providence.
IPR are at the core of fair scientific data transfer and play a significant role under science related EU initiatives such as the European Chemical Strategy for Sustainability or the Pharmaceutical Strategy for Europe.
Therefore, and referring the European Commission’s communication from November 2020 “Making the most of the EU’s innovative potential ....” we do think they require updating and adaptation to the quickly changing digital sector.
We would like to insist on the need for full compliance with related legislations such as the GDPR, the ePrivacy Dir. 2002/58/EC, the Open Data Dir. 2003/98/EC the FAIR data principle, the Rental Dir. 2001/29/EC (which Art 10 provides for limitation on distribution rights and copyrights) as well as the Copyright Duration Dir. 2006/116/EC (which Art 5 provides rules on protection of “critical scientific publications of works which have come into the public domain”). However we are also pointing out the risks of overlapping provisions considering the high number of data-related legislations that are currently into force in the EU.
The 2018 report on the Database Dir. 96/9/EC evaluation highlighted the fact that the legislation had been mostly beneficial to database makers rather than to users. With this in mind, and referring to a recommendation from the report “Towards a European strategy on B2G data sharing for the public interest” by the B2G Data Sharing Expert Group, we would like to encourage the EC towards more awareness raising, individuals’ participation and digital education (with potential EU-wide re-skilling and training).
EuChemS also favours allowance for “data use on altruistic grounds” coming along with the possibility for a European data altruism consent form which is another recommendation from the report. This approach is transcribed in the EC’s proposal for a Data Governance Regulation and was already enshrined in Art 9 of the Database Directive which allowed MS to “extract or re-utilise part of database content if for the purpose of public security or judicial procedure”.
In 2019, EuChemS took part in the OSPP meeting. Besides calling for more EU coordination, compliance with EOSC and FAIR, transparency, reliability, the meeting report provided for a number of general recommendations. Among those, two specific ones particularly relate to the current initiative: The importance to ensure scholarly infrastructure’s interoperability for smooth open data sharing between disciplines and countries as well as the need for the EOSC to implement a robust, transparent and participative governance structure to ensure that it has the trust and confidence of all stakeholder and support the diversity of requirements across all disciplines. At last we would like to emphasise that the newest HE programme must be seen as an opportunity to develop B2G in a sustainable way.We also welcome the will to limit B2G risks
Read full responseMeeting with Thierry Breton (Commissioner) and European Environmental Bureau and
5 May 2021 · Implementation of the chemicals strategy for sustainability
Response to Mercury – review of EU law
1 Apr 2021
The European Chemical Society welcomes the Commission’s initiative to repeal Regulation (EU) 2017/852 of the EP and of the Council, in view of the Minamata Convention complementary ratification and supports its will to implement stricter restrictions if needed.
Limiting our use of hazardous chemicals and decreasing air, soil and water pollution would be highly relevant with the European Green Deal’s objectives on climate, health, water quality and food safety.
Relying on the DG ENV’ estimates on the intensification of chemicals use in the upcoming decade, we do think the Commission’s initiative ties up with the European Chemicals Strategy for Sustainability incentive to strengthen ECHA’s REACH and CLP restrictions as regards to hazardous substances within the EU. This would also comply with the European WFD (2000) which ranks Hg amongst one of the top priority substances requiring careful monitoring measures.
Several European countries’ actions towards a complete phase-out process are setting an example towards such transitions. Besides, considering Hg emissions in the air and water has dropped by around 73 % between 1990 and 2014 and to water by 71 % between 2007 and 2014(DG ENV findings); we can thus be optimistic in taking steps further.
We would also like to emphasise that further restrictions on Hg in the EU would have a dampening effect on the multiplication of artisanal and small-scale gold mines –ASGM-(despite UNIDO’s 2013 action) which workers (recurrently using Hg) and surrounding populations are exposed to hazardous toxicity levels. DG ENV’s In-depth Report-15 “Tackling Hg pollution: Science for Env Policy (2017)” provides that between 10 and 15 million developing countries’ citizens (of which more than 500,000 children) are working as miners in highly toxic environments. Also, 2018 EEA’s “Hg in Europe’s environment” report states that ASGMs are largely unregulated which corroborates the Commission’s In-depth report’s assertions about ASGM miners mainly belonging to poorer and marginalised social groups. The regulation’s contribution to protecting these vulnerable groups would align with several of the UN’s SDGs. At last, UNEP 2011 reports states that ASGMs represent the most significant source of Hg emissions and water and air pollution globally.
Our support is also drawn by the fact that the Regulation is covering Hg’s entire supply chain. If not handled properly Hg can be harmful to humans and wildlife throughout its entire lifecycle. In addition to putting at risk miners and industrial workers’ health, it can also contaminate lands, oceans and seas, as well as its fauna and flora. As a consequence human populations around the world could then potentially be threatened with secondary-poisoning via bioaccumulation.
Nonetheless, EuChemS would like to underline that a complete ban from the EU remains impossible at present, considering current available options. There are fields in which Hg can simply not be replaced for no alternative has proved reliable yet. We would thus recommend maintaining a flexible approach so as to identify these specific activities in which Hg remains essential while carrying out promoting the use of best available techniques (BATs) within the industrial sector for extremely minimised Hg emissions.
At last, while supporting the will to move towards a quasi-complete ban we would also like to highlight the fact that this gradual disposal process should come along with a strong incentive for research in chemistry with the aim to find trustworthy and sustainable alternatives. In that perspective, and as an umbrella organisation working in collaboration with numerous chemists and experts in the field across Europe and beyond, we strongly believe that a stress on international cooperation and knowledge sharing would be highly beneficial to the scientific community worldwide. This would undoubtedly contribute to the implementation of an efficient phasing out process while meeting the 2030 deadline
Read full responseResponse to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination
21 Aug 2018
EuChemS, the European Chemical Society welcomes the proposal for the future Framework Programme 9 – Horizon Europe – put forward by the European Commission. An ambitious research Framework Programme can fundamentally alter the quality, capacity and competitiveness of research and innovation in Europe. A robust and forward-looking Horizon Europe will allow society to take a significant step forward in tackling major environmental, societal, health and economic challenges and will ensure Europe maintains a leading position as a hub of breakthrough research, science and innovation.
In the EuChemS Position Paper with amendments, we outline further proposals and amendments that we perceive as fully enhancing Horizon Europe’s potential. EuChemS wishes to draw attention to: the role of ambition and excellence in a successful Horizon Europe; developing ‘Missions’ in Horizon Europe; Science and borders; Driving innovation from start to finish; Open Science; and Cultural Heritage.
Read full responseMeeting with Blaz Pongracic (Cabinet of Commissioner Violeta Bulc)
15 Jun 2018 · Meeting
Response to Promoting Automatic Mutual Recognition of Diplomas and Study Periods Abroad
15 Apr 2018
EuCheMS, the European Association for Chemical and Molecular sciences, representing chemical societies across Europe, and by extension, some 160,000 chemists, researchers and scientists, strongly supports the automatic mutual recognition of diplomas across Europe. We are glad to see steps being taken by the European Commission in this direction.
EuCheMS and the European Chemistry Thematic Network Association (ECTN) have over the last couple of years developed a system which seeks to have chemistry degrees recognised an a Europe-wide level. Eligible candidates can obtain a EurChem designation which aims to help promote mobility of chemical scientists throughout Europe, based on an agreed set of skills, competencies and training. We would be very happy to present this system to the Commission in order to explore all possible avenues to successfully implementing the automatic recognition of diplomas across Europe.
For more information: http://www.euchems.eu/members-3/european-chemist-designation/
Read full response5 Jul 2017
Acrylamide Mitigation Strategies: EuCheMS position and proposal
RATIONALE
Acrylamide (ACR) in food is a safety concern (EFSA Journal 2015;13(6):4104 [321 pp.] The Maillard Reaction (MR) is the main pathway for ACR formation: important factors are the presence of its precursors in raw materials (free asparagine and reducing sugar such as glucose and fructose) and the magnitude of the heat load applied during food production (time - temperature combination). The results of ACR concentrations in food coming from EFSA monitoring in 2007-2009 showed mean values of 257-265 μg/kg in home cooked potato products, 219-233 μg/kg in crispbread and 128-140 μg/kg in biscuits. This data together with other minor sources led to a calculated exposure of 1 μg/kg BW per day that created serious concerns, particularly for children.
Mitigation strategies and FCD EuCheMS Position
Over the past 10 years several strategies to reduce ACR concentration in processed food were developed. ACR is formed through the same MR pathway, which contributes to the desired color, flavor, and texture attributes of the final product. Most of the proposed mitigation strategies bring about changes in organoleptic properties of food and dramatically affect the final quality of the product and consequently the consumer’s acceptance. The use of asparaginase enzyme, salts and additives as well as the change of time-temperature parameters can dramatically reduce ACR in some foods, as reported in many paper published in literature. Moreover, despite the large availability of methods useful to reduce ACR in foods, in some case (and in some foods) the levels of ACR recovered in 2016 are very similar to those recovered in 2009-2012. Moreover, beside the “high risk” ACR foods (like potato chips or French fries) some foods were poorly investigated in the past (e.g. cocoa and derived products; roasted nuts) and the research could be directed on this in the next future.
EuCheMS supports all the EU Actions finalized to disseminate official rules-guidelines correlated to the mitigation of ACR in foods, particularly for potato-derived foods and foods for children’s. Some specific technical data are reported in the Annex 1, Annex 2, and Annex 3 attached to this Document.
About the authors
EuCheMS, the European Association for Chemical and Molecular Sciences, coordinates the work of 47 Chemical Societies and other chemistry related organisations, representing more than 160,000 chemists. Through the promotion of chemistry and by providing expert and scientific advice, EuCheMS aims to take part in solving today´s major societal challenges.
This feedback was prepared by: Marco Arlorio (Chair of the Division of Food Chemistry, EuCheMS, Food Chemist), in collaboration with Prof. Vincenzo Fogliano (Food quality and design, WUR, Wageningen, The Netherlands), internationally recognized as expert on Maillard Reaction’s and Acrylamide chemistry in foods.
Read full response