Federation of European Producers of Abrasives
FEPA
The objective of FEPA is to represent the interests of the European abrasives industry at a European level.
ID: 884099437411-41
Lobbying Activity
Response to Protection of workers from risks related to exposure to carcinogens at work
7 Oct 2025
The Federation of European Producers of Abrasives (FEPA) represents over 90% of EU production, with more than 130 plants and 16,500 employees. Cobalt is a critical input in high-performance grinding tools indispensable to European manufacturing. FEPA supports the Commissions goal of protecting workers from harmful exposures and agrees that cobalt requires careful regulation. However, the proposed Occupational Exposure Limit (OEL) of 10 µg Co/m³ (inhalable) and 2.5 µg Co/m³ (respirable), even with a six-year transition, would have severe unintended consequences for European industry, jobs, and competitiveness. A pragmatic limit of 20 µg Co/m³ (inhalable) with 4.2 µg Co/m³ (respirable) would ensure both worker protection and industrial viability. Cobalt in the Abrasive Sector For the European abrasive industry, made up of 85% SMEs, cobalt is an important raw material with specific properties required for producing high-quality and precision abrasives. These abrasives are essential for multiple European industries such as construction, photovoltaic cutting, glass, ceramics, and stone processing. Abrasive suppliers enable these sectors to develop new technologies that save energy and raw materials. Overly strict OELs would jeopardise the sectors competitiveness against global competitors, eroding Europes industrial base and weakening downstream industries that depend on precision machining, renewable energy components, and transport. Germany as a case scenario Germany illustrates the impact of an excessively low OEL. Under TRGS 910, the tolerance concentration of 5 µg/m³ and the acceptance concentration of 0.5 µg/m³ have imposed heavy burdens on SMEs. Companies with annual turnovers below 10 million have been forced to invest over 1 million in facility upgrades to comply. For many family-owned firms, these costs are unsustainable, forcing them to close or sell their plants to larger corporationsoften headquartered outside the EU. Larger enterprises handling greater volumes of cobalt have had to shift from manual to automated production processes to meet requirements, yet full compliance remains extremely difficult. Cobalt substitution and sustainability Cobalt is extremely difficult to replace due to its inherent engineering performance. While some reductions in use have been achievedsuch as in the diamond industry where consumption has declinedsubstitution has proven far from ideal. Tools such as polishing wheels that traditionally rely on 100% cobalt deliver lower performance and shorter lifespans when alternative materials are used, ultimately undermining product sustainability and increasing the environmental footprint. Contribution to deindustrialisation A third-party socio-economic study shows that a 10 µg OEL would result in 1,550 site closures, 110,000 job losses, and the loss of 71% of battery precursor manufacturing, 32% of cobalt recycling, and 21% of metallurgical alloy production. In contrast, a 20 µg OEL, while demanding, remains feasible, preserving most European facilities and safeguarding critical value chains. Europes strategic autonomy Cobalt is indispensable for Europes energy transition, digitalisation, and defence sectors. It is vital for batteries, aerospace superalloys, magnets, and defence technologies. Demand is expected to rise by 350% by 2050, while Europe already lags behind its Critical Raw Materials Act benchmarks for domestic supply and recycling. A too-low OEL would weaken resilience, as one non-EU country controls 75% of cobalt processing, and the Democratic Republic of Congo, the main source of mined cobalt, has imposed export quotas tightening global supply. Conclusion There is no evidence that lowering the OEL below 20 µg Co/m³ improves health outcomes. A 10 µg OEL would instead accelerate production shifts outside the EU and increase reliance on imports from regions with weaker protectionsthe opposite of Europes environmental and social goals.
Read full responseResponse to EU rules on industrial emissions - revision
22 Jun 2022
The Federation of European Producers of Abrasives (FEPA) represents the European abrasive industry since its inception in 1955, encompassing four product segments, bonded and coated abrasives, superabrasives and (conventional) grains. It represents over 19000 European jobs and more than 250 companies from 23 countries and 7 national associations.
FEPA has been part of the Art. 13 forum since 2019. As an organisation, we therefore appreciate and welcome having the opportunity to provide additional comments on the IED proposal published on 5 April.
Under the current economic conditions, the European abrasive industry faces existential production difficulties because of a shrinking energy supply and its rising costs as well as supply chain disruption with the increasing scarcity of raw materials. In addition, the European abrasive industry is a horizontal market indirectly affected by the ups and downs of bigger economic sectors such as the automobile and aeronautic industries. With the compound effects of the pandemic, the supply chain disruptions and the energy crisis, the European abrasive industry has been struggling these past few years to find an operational pace with a predictable financial forecast.
Following its strategy set out by the Green Deal which FEPA welcomed in 2019, the European Commission is currently launching a large number of revisions of various directives and regulations in a condensed timeframe. While FEPA finds environmental changes crucial, the current overwhelming pace of policy development and the potential impact of these revisions on European abrasive manufacturers are creating a level of unbearable uncertainties among our small and medium-sized enterprises, which represents 95% of our membership.
Against this background, FEPA would like for European authorities to consider the options proposed in the attached statement regarding the IED revision and the amendment in Annex I, point 3.5.
Read full responseResponse to Review of the general product safety directive
4 Oct 2021
The Federation of European Producers of Abrasives (FEPA) welcomes the opportunity to comment on the Commission’s legislative proposal of 30 June 2021 on General Product Safety.
FEPA welcomes the strong focus of the proposal on the market surveillance, as the problem of unsafe products being put on the market should be addressed through more efficient implementation, closer cooperation of competent Member States’ authorities and better enforcement. This should be achieved without putting additional administrative burdens on compliant businesses. Particular focus should on market surveillance activities aimed at ensuring that products imported from third countries are compliant with EU rules. Market surveillance authorities should conduct effective and focused surveillance, with particular attention on products and market players that have previously circumvented the rules. In case of safety breaches, there should be a clear and coherent product recall framework.
The Regulation on general product safety should ensure that the information about product safety is clear and easily accessible. Art 8(7) should be amended and manufactures should be given the possibility to add either a website, electronic address at which they can be contacted or QR code on the product or the packaging. FEPA does not see any need for manufacturers to add the postal address, as this would only clutter the information displayed on the products or the packaging.
With regard to the requirement in Art 8(8) stating that “manufacturers shall ensure that their product is accompanied by instructions and safety information”, it should be possible to provide such information electronically. Manufacturers’ responsibility in this regard should be to provide instructions and safety information, but they cannot be required to “ensure” that the end-user receives the information as most often this pertains to authorised representatives, importers, distributors, and other economic operators. FEPA’s recommendation would be to stipulate that the manufacturers need to “provide” the relevant information.
Overall, FEPA would like to emphasize that the use of digital information channels would allow better penetration of safety-related information to the consumer compared to a printed document. Attractive digital, multimedia, multilingual and targeted information enhances consumer visibility and perception of the relevant safety advice. A digital solution also contributes to climate and resource protection by preventing waste.
FEPA would like to highlight that the legislative proposal contains several measures that would need more specific definition. In particular, Article 8(3) mentions the obligation of the manufacturer to inform “distributors, importers and online marketplaces in the concerned supply chain” in case of any safety issues. It is not clear how ‘supply chain’ is defined in this context. Furthermore, the scope should be limited to relevant safety issues.
FEPA calls to extend the transition period which, according to the Art 47 of the proposed Regulation, 6 months after entry into force. 6 months period is very short time span in view of the need to comply with the new labelling and documentation requirements. The transition period should be extended to at least one year.
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