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European Diisocyanate and Polyol Producers Association

ISOPA

ISOPA is the European trade association for producers of diisocyanates and polyols - the main building blocks of polyurethanes.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

ISOPA (The European Trade Association for the Producers of Diisocyanates and Polyols) welcomes the Commission's intention to come forward with a proposal for a Circular Economy Act. Such a measure can play a significant role in advancing Europe's circular transition by creating an enabling and predictable policy framework. For a detailed position and policy recommendations, please find ISOPA's feedback attached.
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Meeting with Nikolaj Villumsen (Member of the European Parliament, Rapporteur)

2 May 2023 · CAD-CMRD Directive

Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

21 Mar 2023

ISOPA and ALIPA welcome the European Commissions proposal to amend the Chemical Agents Directive (CAD) 98/24/EC to establish binding EU Occupational Exposure Limit (OEL) for diisocyanates. Today, EU Member States have different OEL levels for individual diisocyanates across the Union and some even have no limit value at all. Therefore, this proposal establishes a level playing field to ensure a high level of protection for workers across the EU so as to further reduce the number of occupational asthma cases. We support the values and the stepwise approach proposed by the Commission as this reflects a consensus on an EU OEL for diisocyanates reached within its Advisory Committee on Safety and Health at work (ACSH) by its representatives from Member State governments, workers organizations such as the European Trade Union Confederation (ETUC) and employers. We are nevertheless seriously concerned about the lack of reference that diisocyanates are to be measured as NCO (paragraphs 12, 13 and Annex I), which we consider to be an error of omission. Regarding the stepwise approach, sufficient time is needed for downstream users to implement mitigation measures in order to reach the challenging target values, a transition for which the Commission foresees additional costs of EUR 13.5 billion. Importantly, the proposal complements an existing REACH Restriction (Commission Regulation (EU) 2020/1149) on diisocyanates which sets a mandatory training requirement for workers handling these substances. This reflects the Commissions commitment under the EU strategic framework on health and safety at work for 2021-2027 to streamline the interface between OSH and REACH regulation to ensure workers protection. The case of diisocyanates illustrates how these two legal frameworks complement each other to provide more effective worker protection. The proposed OEL for diisocyanates, in combination with the mandatory trainings established in the REACH Restriction, will ensure a framework which fully protects workers. Our full position paper is attached.
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Response to Sustainable Products Initiative

22 Jun 2022

ISOPA, the Association of Diisocyanates and Polyols Producers, shares the vision of a Circular Economy and is committed to the Chemicals Strategy for Sustainability. We welcome the opportunity to provide comments feeding into the upcoming Ecodesign Sustainable Products Regulation (ESPR), formerly known as the Sustainable Products Initiative (SPI). As the ESPR outlines actions to restrict the presence of chemicals in products, ISOPA has prepared general recommendations to policymakers to offer the vision of the diisocyanates industry and to participate in improving the products environmental performance along their life cycle. Disclosure of chemical substances We invite policymakers to take a holistic approach in the development of new legislation. It is important to avoid addressing the same issues with several initiatives and contradictions between existing and upcoming legislation and tools. It is important that legislators work with a clear scope and do not ’reinvent the wheel’. Only chemical substances that are actually included in the finished product and that can affect circular flows should be taken into account and not process chemicals required during manufacture. For example, in the case of polyurethanes manufacturing, diisocyanates are reacting with polyols and are not present in the finished product. Process chemicals and how they are handled fall under other legislation that regulates safety in the workplace. Digital Product Passport We ask policymakers to consider the complexity of value chains and of the sectors when developing the product passports. Although these tools have a large potential to drive circularity, they should be based on existing legislation and schemes and must not become an administrative burden. Product passports should have a pragmatic approach and only provide information that is important and useful for the intended receiver or target operation. It is important to consider making a differentiation between compulsory and voluntary information. Access Rights and Confidential Business Information The creation of a Digital Product Passport raises the issue of access rights and confidential business information. ISOPA believes that it is imperative to define tailor made access rights for the digital product passport. In particular, we support the option of controlled material disclosure over full material disclosure in order to protect confidential business information. Environmental Footprint We support the idea to foster the LCA approach within the ESPR but want to point out that there are enormous difficulties to calculate it due to the lack of availably of data along the value chains. Another problem that the legislators might face concerns the control of LCA data from imports in the EU. As aforementioned, it is important that legislators do not address the same issue twice, as this type of information is already required with the concept of Safe and Sustainable-by-Design. Transition Period We invite policymakers to grant flexibility to the sector’s companies to adapt to new requirements during a reasonable transition period, as well as to find the technical solutions for established policy goals and their own way to contribute to circularity. There is no one-size-fits-all solution. It is important to ensure that no additional and unreasonable administrative burden is placed on the polyurethane industry, which is mainly composed of SMEs and microenterprises. Companies’ sustainability agendas are largely market-driven and not primarily by legislation, therefore legislation should be applied with caution and only in the case of market failures. The desire to operate in a responsible way is a main driver, too.
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Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

21 Mar 2022

ISOPA/ALIPA and its downstream users’ associations welcome the opportunity to provide feedback to the European Commission on the review of the Chemical Agents Directive (98/24/EC) which intends to set Binding Occupational Exposure Limit Values (BOEL) for diisocyanates and lead. We will not comment on the OEL setting intentions regarding lead. We have closely followed the OEL process for diisocyanates and generally welcome the Commission’s efforts to pursue EU harmonisation for occupational safety legislation covering diisocyanates. In summary, we believe that the proposed ACSH OEL values, in combination with the REACH Restriction’s mandatory training for workers, will ensure a framework which fully protects workers, leading to a significant reduction in the number of occupational asthma cases, while taking into account socio-economic and feasibility factors. A more detailed response to the call for evidence can be found in the attachment.
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Response to A new Circular Economy Action Plan

2 Jan 2020

Europe must stop wasting its resources! Improving waste management is a good way to start. For ISOPA, Europe cannot hope to transition towards a circular economy model without an ambitious yet practical waste management policy. As Europe faces unprecedented economic, social, environmental and geopolitical challenges, political leaders seem to agree on one thing: our society must move away from the linear model and transition towards a circular economy. Europe must stop wasting resources! A paradigm change of such dimension requires a holistic approach and commitment from everyone. ISOPA – and the Polyurethanes (PU) industry at large – strongly commits to engage and contribute to the debate. For decades, the PU value chain has been developing resource-efficient solutions benefiting a myriad of sectors that will play a key role in contributing to a circular economy in Europe (construction, transport, appliances, etc.). Plastics are too valuable to waste and must be diverted from landfill. In order to do so, Member States should promote sustainable reuse and recycling solutions as well as high-efficiency waste-to-energy capacities. Europe will move away from landfilling by combined investments in recycling and energy recovery. As data shows in several countries, high recycling rates associated with high waste-to-energy rates have allowed for a progressive phase out of landfilling of plastic waste. Europe will not shift towards a more circular model unless recycling rates increase significantly. It is, however, critical to promote sustainable recycling. Recycling makes sense provided there is waste of sufficiet quantity and quality and that the logistics and processes involved do not impose a higher environmental and economic burden. Mixed or contaminated waste as well as the lack of sustained waste streams could create obstacles: excessive environmental or economic costs, unsafe recycling, etc. Homogenous packaging materials, such as PET, create a good example of sustainable recycling: the flow of waste is constant and the collection and separation schemes are well-established. Alternative and complementary waste management options are also needed. Regulation should also support energy recovery solutions for two very simple reasons: they provide an alternative to recycling when it is not deemed sustainable and help strengthen Europe’s energy independence. In that vein, ISOPA strongly supports proposed waste-to-energy initiatives as they constitute a domestic source of energy and reduce the use of virgin resources. Feedstock recycling is a process by which waste is broken down into its individual chemical components which can be fed back as raw material. Originally introduced by the plastics industry, the concept constitutes an attractive option for plastics that are difficult to mechanically recycle. Processes such as gasification or pyrolysis break down plastic waste into new chemical raw materials; they can then be used in a variety of applications. Past experience in feedstock recycling has shown that while innovation leads to effective and robust new technologies, these technologies can face economic challenges preventing their development and implementation at an industrial scale. Further innovation and funding are therefore needed in order to turn feedstock recycling into an economically viable option and create new opportunities to close the carbon loop.With this in mind, one should consider the following:  Banning disposal of waste is key to guarantee resources are not lost  Sustainable recycling allows society to maximise the value of our resource while avoiding unnecessary environmental or economic costs  Waste-to-energy and feedstock recycling will be essential to managing waste containing hazardous impurities and to extract resources from waste streams that are difficult to collect, separate and recycle  Resource efficiency requires a life cycle approach.
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