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European Federation for Construction Chemicals

EFCC

The European Federation for Construction Chemicals (EFCC) represents construction chemical companies and associations across Europe.

Lobbying Activity

Response to Circular Economy Act

4 Nov 2025

The construction sector, as the EUs second-largest industrial ecosystem, is essential to achieving Europes green and digital transition. To realise this potential, the EU must ensure a coherent and predictable regulatory framework that drives circularity, fosters innovation, and strengthens industrial competitiveness. Fragmented legislation and inconsistent approaches to waste and resource management currently hinder progress and create uncertainty across the single market. EFCC calls on the European Commission to establish harmonised circularity and waste policies that enable the safe and efficient use of secondary raw materials, facilitate cross-border trade, and reinforce Europes supply resilience. Removing regulatory barriers and aligning waste-related legislation will allow the construction chemicals sector to contribute more effectively to decarbonisation and sustainable growth while ensuring a level playing field for all actors in the value chain. At the same time, EFCC urges the Commission to recognise the technical limits of recycling or reusing certain construction chemical products, which are often embedded in building materials and difficult to separate at the end of life. Future EU policies must reflect these material and lifecycle realities to remain both ambitious and achievable. A balanced, innovation-friendly regulatory approach will ensure that Europes construction chemicals industry remains a key enabler of the green transition (for more details see paper attached).
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

The European Federation for Construction Chemicals (EFCC) welcomes the Commissions initiative to improve EU product legislation by increasing harmonisation, reducing regulatory burdens, and promoting the use of digital tools to enhance compliance and safety. The revision of the New Legislative Framework (NLF) offers a decisive opportunity to strengthen the Single Market, ensure greater regulatory coherence, and prepare Europes product legislation for the challenges of the green and digital transitions. EFCC therefore encourages policymakers to build on the proven strengths of the NLF while addressing identified gaps through targeted improvements. To achieve this, EFCC calls on the European Commission to: Establish a single, interoperable Digital Product Passport system that is technology-neutral, simple, and proportionate in scope, to ensure feasibility and wide acceptance by economic operators. Preserve harmonised standards as the main tool for presumption of conformity, accelerate their citation in the Official Journal, and reinforce Europes leadership in international standardisation. Ensure coherence across EU legislation by aligning definitions, obligations, and conformity assessment modules, and by avoiding sector-specific reinvention of key concepts. Maintain the risk-based approach to third-party verification, while strengthening the competence and consistency of Notified Bodies without imposing disproportionate restrictions or costs. By following these principles, the revised NLF can continue to deliver safety, trust, and innovation, while reinforcing the competitiveness of European industry and supporting a truly integrated Single Market. Further details are provided in the attached paper.
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

The European Federation for Construction Chemicals (EFCC) is representing companies and national federations working in the construction chemicals industry in Europe. EFCC appreciates the opportunity to share its comments and concerns related to the establishment of the Europeans positive lists under the DWD. EFCC is concerned that the increased data collection and analytical requirements planned to be required for the positive listing will put a significant burden of the manufactures and downstream users. In addition to this, EFCC considers that neither the DWD nor this implementing act provide sufficient protection for the shared data and confidential business information and as such is not protecting the intellectual property of the European economic operators. As downstream user formulators we fear that the number of applicants for the positive listing will be very limited resulting in a lack of substances available for drinking water materials after 2025. This would lead to a significant reduction of construction products available for drinking water installations which could put the distribution of the drinking water to European consumers via the pipe systems at risk. Please read more details in our attached paper.
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

We support the exclusion of construction products as end-use products under the ESPR as construction products are already covered under the Construction Products Regulation, CPR. We oppose the inclusion of (construction) chemicals under the ESPR, as (i) construction chemicals are well covered under REACH and CLP and (2) as far as construction chemicals are concerned, they are already covered under the Construction Products Regulation, CPR.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

30 Mar 2023

EFCC fully supports the intention of the European Commission to improve identification and classification of hazardous chemicals and welcomes the opportunity to participate in the public consultation on the revised Regulation on CLP. The construction chemicals industry believes that the new formatting rules for the labels are unnecessarily inflexible and specific, and would not lead to significant improvement of the hazard communication. The re-design and re-labelling of packages takes time and costs money, and, if the removed and unused labels have to be disposed, this would have a negative impact on the environment. EFCC welcomes the introduction of digital labelling for some elements of the labels, however, EFCC considers that the benefits of digitalisation were not fully explored in the proposal. EFFC would like to raise concerns regarding the harmonised classification and labelling proposals for a group of similar substances, assuming that such similarity allows for similar classification of all substances in the group. EFCC calls for grouping to be done on the basis of sound scientific principles. Harmonised classifications should be assigned only where this is justified based on a comprehensive review of the weight of scientific evidence. The construction chemicals industry calls for the allocation of sufficient time for implementing the changes of the labelling in accordance with the new CLP.
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Response to Introducing new hazard classes–CLP revision

17 Oct 2022

The European Federation for Construction Chemicals (EFCC) welcomes the opportunity to participate in the public consultation on CLP Delegated Act for new hazard classes. EFCC members consider ensuring the protection of citizens and the environment against hazardous chemicals important, however, believe that any modification of the classification rules or any inclusion of a new hazard class in the CLP should be discussed and agreed by the UN GHS SCE first. Please read the attached paper for more details.
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Response to Standardisation Strategy

4 Aug 2021

The European Federation for Construction Chemicals (EFCC) welcomes the EC initiative on developing a new European strategy for standardisation to handle current issues and to further develop the strengths of the European standardisation system (ESS). European Standardisation is a key instrument for the consolidation of the Single Market and for strengthening the competitiveness of European companies, thereby creating the conditions for economic growth. They reduce unnecessary costs for both suppliers and purchasers of products and services – in the public and private sectors. Standards can be used to improve safety and performance, raise levels of energy efficiency and protect consumers, workers and the environment. They complement European and national policies in these areas and make it easier for companies and other actors to respect relevant legislation. The main challenge for the ESS is lack of harmonisation of some European standards. The current situation of heavily delayed or blocked harmonisation leads European industry to miss many harmonized standards for supporting their conformity assessment activities. This issue remains the key challenge for the ESS, which needs to be solved prior to other strategic issues. In general, EFCC supports European harmonised standards and recommends that new or updated standards are cited and published by the European Commission as soon as possible. Our members’ main concern is non-cited standards and they hope the new standardisation policy will facilitate the citation of European standards in OJEU. Regarding CE marking, in several cases a product certified and CE marked is not enough to be applied in each Member State. This might be related to the fact that construction products are harmonised under CPR but buildings are not, which will result in Member States having their own building codes. The ‘insurance issue’ should also be considered for application of products. Meaning there might be requirements for national codes, other specific national circumstances or legal issues, which in the end will lead to further testing and certification by third parties in addition to the CE mark.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

28 May 2021

The European Federation for Construction Chemicals (EFCC) represents European construction chemicals companies and national member associations, representing raw materials producers and formulators of finished products, including SMEs, across the European Union. EFCC welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for CLP. The construction chemicals industry in Europe continues to be fully supportive of the CLP Regulation in ensuring both a well-functioning single market for chemicals and a high level of protection of human health and of the environment. Incomplete information about hazards to human health and the environment. Where CLP has so far missed the identification of critical hazards to human health and the environment this should be investigated. However, we fail to understand why new hazard classes for Endocrine Disruption would be necessary. Our understanding is that CLP already captures disruptive effects through different existing and UN GHS harmonised classes such as CMR, STOT, chronic effects, etc. Whether these effects were mediated through the endocrine system or not does not change the outcome. And typically there is a threshold level under which safe use can be demonstrated. Introducing a new hazard class will result in a significant deviation from the UN GHS with negative impacts on hazard communication globally, which is acknowledged by the COM. . Hindrance of the free circulation of chemicals in the internal market EFCC welcomes the initiative to allow a impossibility for companies to use multilingual fold-out labels for normally sized packaging. We also welcome the initiative to introduce tailored labelling rules where there is not enough space on packaging. Insufficient public resources and/or risk of inefficient use of them EFCC does not support giving the Commission or ECHA a mandate to initiate classification dossiers. According to Article 37 (5), CLP, the Commission has the task to assess whether a proposed harmonised classification is "appropriate" or not. This obligation gives the Commission a certain margin of discretion, which requires an assessment of appropriateness beyond the fulfilment of the classification criteria as assessed by the RAC. Consequently, if the Commission itself is the submitter of the proposed harmonisation, it would have to assess and evaluate its own proposal. An independent assessment of appropriateness beyond the submitter's intention to harmonise cannot be safely guaranteed in this way. Opportunities of new digital tools We welcome this initiative but wonder why digital labelling is not included. Smart CE marking of construction products could be an opportunity to introduce such a digital tool. For further information please contact Dr. Ing. Johan Breukelaar, Director General EFCC, johan.breukelaar@efcc.be
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

28 May 2021

The European Federation for Construction Chemicals (EFCC) represents European construction chemicals companies and national member associations, representing raw materials producers and formulators of finished products, including SMEs, across the European Union. EFCC welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for REACH. Generic approach to risk management Regulating chemicals on the basis of their hazard only, is overly simplistic and risks removing chemicals from the EU market that have high societal, environmental and economic benefits. Chemicals should be regulated on the basis of sound science reflecting both hazard and exposure (i.e. safe use). A ‘generic risk management’ approach based on hazard should be applied only to substances and/or uses where adequate control of risks has not been demonstrated. EFCC would like to express their concern to extend a generic approach to risk management to products for professional use. Professional use of chemical products by professional (and well-trained) workers that are applying risk management measures, such as personal protective equipment, cannot be equated to the use of chemical products by private users. Specific risk management is required instead of a generic approach. Essential Use EFCC would like to express their concern that what might be recognised as an “essential use” will be of a highly political nature with unavoidable socio-economic consequences. A generic definition-based approach to what is essential, is not a solution that can ensure sufficient clarity and predictability to industry, professional users and consumers. The value chemical substances or products could bring to society should be taken into account. A chemical substance or product when looked at in isolation, might not be considered essential. Combination effects of chemicals and Mixture Assessment Factor (MAF) The concern on possible combination effect of chemicals should focus on unintentional, combined exposures, not on situations where simultaneous exposure is already known, such as when placing on the market of mixtures as well in in an occupational safety context. EFCC is not in favour of the introduction of a generic or fixed MAF, to be applied to all chemicals. A blanket MAF would be arbitrary and not based on sound science, covering largely hypothetical exposures and risks, rather than realistic scenarios and could result in the phasing out of non-hazardous products containing hazardous components at concentrations below both effect or classification levels. A generic application of a MAF would result in unnecessary compliance activities that will ultimately not achieve the regulatory goals. Thus, MAFs, when introduced, should be proportional, targeted, and based on a sound scientific knowledge and, in addition, should allow for specific evidence-based refinement. MAF could be relevant to unintentional mixtures and therefore should only be applied to the calculated Risk Characterisation Ratios (RCRs). Simplifying communication in the supply chains Communication on how chemicals can be used in safely along the supply chain is key to ensure proper risk management by e.g. formulators. EFCC members play a key role as formulators, as on one hand they need to ensure the safe use both of the chemicals (substances and mixtures) they use to manufacture mixtures and other hand ensure the safe use of the formulations they place on the market. EFCC continues to be committed to contribute to Use Maps and input parameters for workers exposure assessment (SWED) files, working closely with ECHA and other downstream users. Please note this is a shortened version, you can find our complete feedback in the attachment. For further information please contact Dr. Ing. Johan Breukelaar, Director General EFCC, johan.breukelaar@efcc.be
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Response to Chemicals strategy for sustainability

18 Jun 2020

Feedback on the Roadmap for the Chemicals Strategy for Sustainability from the European Federation for Construction Chemicals (EFCC) The European Federation for Construction Chemicals, EFCC, calls for a Chemicals Strategy for Sustainability (CSS) that recognises the essential role of construction chemicals to deliver the European Union’s climate ambition, while ensuring a high level of protection of human health, wellbeing and the environment, and integrating the dimensions of the Green Deal: resource efficiency, climate neutrality and materials circularity, to stimulate innovation and the competitiveness of the construction chemicals sector in Europe. The construction sector currently emits around 36% of all GHG emissions in Europe. Construction chemicals in particular, play a key role in delivery of Europe’s climate ambitions as they can extend the lifetime of buildings, and enhance the durability and quality of construction products. EFCC calls for: Recognition of the strategic role played by (construction) chemicals in delivery of its goals regarding protection of human health, wellbeing, climate neutrality and the environment in general. The Roadmap claims that in 2018 hazardous chemicals ‘still represented 74% of the total chemical production in Europe’. Such as statement has no place in the CSS because it is misleading. By their nature, chemicals that are used as raw materials are reactive and therefore often ‘hazardous’ and as such very efficient building blocks to manufacture a final, less hazardous or often non-hazardous, product. We, EFCC, are willing to work with the Commission and other stakeholders on alternative indicators of progress and call on the Commission to come up with a more refined representation of the chemicals sector. Improving REACH, which has been fundamental in demonstrating the safety in use of many existing chemicals. The construction chemicals industry in Europe continues to be fully supportive of REACH as the foundation of the management of risks associated with construction chemicals. Recent reviews and fitness checks have identified opportunities to achieve better consistency and eliminate duplication, solve implementation issues, clarify data requirements to minimise animal testing, and digitalise communication regarding the safe use of chemicals in the supply chain. A chemicals strategy that achieves coherence between chemicals legislation such as REACH and CLP, and specific product legislation, such as for construction chemicals e.g. Environmental Product Declarations, Eco-Design of Buildings and Energy labelling, and the Review of the Construction Products Regulation in particular. Encouraging supply chain partnerships to stimulate innovation to further improve the sustainability of the building and construction sector in Europe such as the durability of buildings, that can only be achieved if the entire sector works in partnership to achieve the goals of the Green Deal, the new Circular Economy Action Plan and the CSS in particular. A proportionate and effective approach to manage the risks associated with chemicals that should start with sound science at the basis of decision making. In case of scientific uncertainty, a stepwise regulatory approach should be taken. For example, by focusing on the main releases and risks based on existing data, followed by reviews at a second stage. Realistic exposure assessments must be at the core of risk assessment and management. An effective approach should also aim to improve risk assessment of complex substances, for example, by refraining from the need to register polymers where they are non-hazardous. EFCC – Transparency Register No. 126293811245-87 17th of June 2020, Brussels
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

30 Jan 2019

EFCC is the European Federation for Construction Chemicals. Based in Brussels since 2005, EFCC represents Construction Chemicals Companies (both raw materials producers for construction chemicals and formulators of construction chemicals) and Associations in Europe. Directly and indirectly EFCC represents more than 120 Companies covering most of the Construction Chemicals Market in Europe. Our membership covers a wide range of Companies, from SMEs to large multinational Groups. We are very concerned about the proposal to classify Titanium dioxide as carcinogen cat.2 by inhalation, as we consider that proposal as scientifically not justified, inappropriate from a legislation point of view and having very negative impact on our Industry, without bringing any added value to the health protection. Titanium dioxide is largely used in the Construction Industry as ingredient on cement, flooring products, mortars, plasters, photocatalyst concrete. We are definitely against the proposal to classify Titanium dioxide as carcinogen category 2 by inhalation for the following reasons : - The identified hazard for Titanium dioxide is not a substance specific effect, is not due to its chemical nature, is not a shape effect : it's a particle effect, it's a dust effect. As recognized by RAC, it is similar to the effect caused by many other solid particles of poor solubility. Classifying Titanium dioxide would then trigger a domino effect, bringing to classification of thousands of similar substances having particles of poor solubility - Such a kind of "dust" effect shouldn't be covered by CLP, which, in this case, is not the appropriate legislative tool - Protection against the inhalation of dust should be achieved via an harmonized EU occupational health legislation (OELs) - Classification as carcinogen 2 by inhalation and related labelling would generate confusion by the users and would deliver a wrong message about the real level of concern, thus jeopardizing the CLP credibility - Classification would also seriously impact on the treatment of huge amount of waste material containing Titanium dioxide and on the circular economy At the end : such a proposal of classification under CLP wouldn't produce any benefit for health protection while it would cause many negative consequences. Therefore we call for a different appropriate treatment of the Titanium dioxide case.
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