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European Fastener Distributor Association

EFDA

(1) The objectives of the Association are: - to represent the common professional and “trade interests” of its members at a European level in particular in dealings with European departments and authorities and with manufacturers and their national and European amalgamations, - to represent to the legislature and other public bodies the views and interests of European fastener distributors; to promote, support, or oppose legislative and other measures affecting their interests and to take all such steps as may seem expedient for altering and improving any existing laws, customs or usages affecting such interests. - to establish contacts and to foster an exchange of views between the national distributor associations worldwide. (2) It is not the aim of the Association to pursue profit making objectives.

Lobbying Activity

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

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

7 May 2025 · Physical meeting - Fasteners under CBAM

Response to The reporting obligations during the transitional period of the carbon border adjustment mechanism.

11 Jul 2023

(1) The European Fastener Distributor Association (EFDA) the goals of the EU to reduce the CO2 emissions caused by the production of steel products. It is understandable that the legislator is trying to counteract disadvantages suffered by domestic manufacturers due to high CO2 costs by also imposing a comparable CO2 price on imports to the EU. However, the system boundaries for determining CO2 emissions in the CBAM are significantly broader for the import of iron and steel products, which include fasteners, than for the ETS. For the import of fasteners, the CBAM declarant must provide information on direct embedded emissions in accordance with Article 3(2)(c) of the draft Implementing Regulation in conjunction with Annex II, point 2.16, which goes beyond the requirements set for domestic producers of fasteners under the ETS. This unequal treatment must be eliminated before the Implementing Regulation applies. (2) Fasteners under CN code 7318 were only included in Annex I during the trilogue negotiations on the CBAM Regulation. Before the beginning of the trilogue none of the three EU institutions involved in these negotiations had called for the application of the CBAM to fasteners. Also, CBAM was originally designed for base materials and not for finished products as fasteners. We consider this procedure to be a violation of the principles of transparency, the rule of law, integrity, accountability, and stakeholder participation, which the EU is committed to and promotes worldwide. We urge the Commission not to apply the CBAM to fasteners or, if this is not possible, to postpone the implementation for these products. (3) It will not be possible for importers to provide concrete emission values, which is why fastener distributors will essentially have to rely on the Commission's default values. Especially in the very fragmented fastener industry with countless articles, suppliers and manufacturers, the determination of the data will be so time-consuming for the companies, even with clear specifications, that they will not be able to report the data by the end of January 2024. For these reasons, importers must not be held liable if they cannot provide the necessary data despite all their efforts. (4) It is still not clear, in which cases default values can be used. For example, the relationship between the provisions in Article 5 of the draft Implementing Regulation and in point A.2 (2) of Annex III is not clear. In order to be able to fulfil the reporting obligations from 1 October 2023, the Commission urgently and immediately needs to publish default values for all products that can be used by companies. As fasteners, unlike other steel products, do not participate in the ETS and therefore there are no default values yet, the Commission must take special care in setting the values for fasteners to avoid inaccuracies. (5) The specifications proposed in the draft Implementing Regulation are not comprehensible in themselves and thus compliance with the legal requirements is not possible. If the Commission does not specify the rules in the Implementing Regulation itself, it must urgently provide guidelines or other tools to provide legal certainty for the applicants of the provisions. (6) The time remaining for companies to implement the obligations is far too tight. If the Implementing Regulation enters into force in July, EU importers and suppliers in third countries will have just over two months until the start of the transitional period on 1 October 2023 to start gathering data and preparing their respective suppliers for CBAM. Since there is no compelling reason for the rapid introduction of the CBAM, it is not evident why postponing the mechanism by one year should not be possible. This would lead to a more satisfactory implementation of the mechanism with better results for the EU and all other stakeholders. (7) Find more facts in our attached response to the Commissions call for feedback.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

17 Nov 2016 · Prior surveillance of steel products / problems with implementation