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Federation of The European Cookware, Cutlery and Housewares Industries

FEC

FEC aims to identify and address issues of shared concern among its members while advocating for their collective interests.

Lobbying Activity

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

22 Aug 2025

FEC and IVSH generally support the EUs CBAM mechanism but warn that the current CBAM design creates major competitive distortions. Excluding downstream products in our sector (e.g., cookware, cutlery, household goods with >70% metal content) risks carbon leakage, production shifts, and job losses. Key recommendations: Extend CBAM scope to eleven priority customs codes for downstream products in our sector to ensure fairness and impact. Introduce export compensation (e.g., inward processing or full retrocession of CBAM certificates). Implement anti-circumvention measures (to prevent misreporting, customs code manipulation, and resource shuffling). Align timelines for CBAM extension, phase-out of free allowances, and export rules. These steps are essential to ensure fair competition, protect climate objectives, and maintain EU industrial capacity and competitiveness and avoid the beforementioned negative implications. See full details in the attached document.
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Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

13 May 2025

FEC, the European Federation of Manufacturers of Cookware and Cutlery, welcomes the opportunity to comment on the proposed revision of Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation - EUDR). Firstly, we would like to highlight the inconsistency on bamboo, rattan, and other materials of woody nature in the two documents, particularly in recital (3) and paragraph (3) of the Annex. According to the Annex, we understand Regulation (EU) 2023/1115 does not apply to these materials and therefore it does also not apply to relevant products listed under the relevant commodity. We ask to address the contradictory wording in recital (3) accordingly. Additionally, FEC fully supports the feedback provided by IVSH Industrieverband Schneid- und Haushaltwaren. In line with the suggestions provided by IVSH, the EUDR framework requires simplification and a streamlined approach to decrease bureaucratic and financial burdens, especially on small and medium-sized enterprises (SMEs) offering or producing a wide range of products and household goods. Therefore, we suggest to review the EUDR in view of an Omnibus simplification. FEC supports the introduction of a no-risk category for products meeting specific criteria, including a quantity- and origin-based focus. The EUDR should focus on quantities of relevance when looking into product groups and end products, rather than minor quantities that may not warrant the same level of scrutiny. Similarly, products originating from regions with robust deforestation controls, such as wood sourced from within the EU or other countries, should be classified under a new no-risk category. This classification acknowledges the stringent environmental standards and sustainable forestry practices already in place within the EU, reducing unnecessary regulatory burdens on these products. To ensure regulatory clarity and efficiency, we recommend that the EUDR's obligations be applied to first importers and traders. This approach clearly defines compliance responsibilities and prevents redundant efforts along the supply chain. It also allows for targeted enforcement at the critical entry point into the EU market.
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Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and APPLiA (Home Appliance Europe) and

16 Jan 2025 · Possible PFAS restriction in cookware, cutlery and home appliances under the REACH Regulation

Response to Environmental claims based on environmental footprint methods

21 Jul 2023

The Federation of European Manufacturers of Cookware and Cutlery (FEC) and its members fully support the objectives of Green Claim Directive. Too often product labels give vague, misleading, or unfounded information to the customers. The Federation of European Manufacturers of Cookware and Cutlery (FEC) and its members recognise that companies, in this context, play a key role in ensuring that buyers receive transparent, reliable, and verifiable information so that they can make informed and increasingly sustainability-oriented choices by allowing better comparison between products. For such a reason FEC fully supports the proposal's underlying objectives and the commitment established and promoted within the European Green Deal to tackle greenwashing practices. We believe that these objectives require a full harmonization to be efficient, ideally through a Regulation instead of a Directive. Furthermore, we do expect clear and easily applicable measures, to make it applicable by SMEs and understandable by end consumers. Finally, we believe that safe products should benefit from the adoption of Green Claims independently of their use and their composition.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

The Federation of European Manufacturers of Cookware and Cutlery (FEC) supports the Packaging and Packaging Waste Regulation (PPWR) proposal, which aims to ensure the efficient functioning of the internal market for packaged goods while reducing the impact of packaging waste on the environment and human health. FEC, however, has concerns about certain provisions in the proposal that permit EU member states to set specific packaging requirements. FEC believes that harmonized labeling and packaging requirements are essential to creating a true EU circular economy, and it calls for the preservation of a full internal market legal basis that could stop the plethora of divergent requirements across EU member states. Such divergent requirements would breach the Single Market, not ensuring the free movement of goods and their packaging, and pose bigger challenges for SMEs players. FEC also supports the introduction of a QR code system or digital data carrier to provide information on packaging reusability, which will help improve the readability of labels and facilitate their management by economic operators while ensuring the functioning of the internal market. FEC also believes that the targets set by the PPWR should take into account market availability and competitiveness within the European market. To preserve the competitiveness of European manufacturers of products in export markets, it is important that the European packaging industry remains competitive compared to international benchmarks. To fully reach the ambitious targets of the proposal for Regulation, it should be taken into consideration not only post-consumer waste but also post-industrial waste, which poses an important source of material. Ignoring this material could lead to big amounts of material suitable for recycled products being discarded from the circular economy. The proposal introduces the design for recycling criteria, which will allow the achievement of recycling targets by 2030. These new criteria will ensure all packaging is recyclable, and increasing recyclability will contribute to a high-quality secondary raw material market for products. However, FEC is concerned about ensuring compliance for packaging materials from another economic operator with the PPWR requirements and the administrative and economic cost it would have on manufacturers of packaged, especially SMEs. FEC calls for clarity on the responsibility for compliance for the packaging materials.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

28 May 2021

FEC contributed to this public consultation via the position paper attached.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

28 May 2021

FEC contributed to this consultation via the position paper attached.
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