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Federazione Nazionale dell'Industria Chimica italiana

FEDERCHIMICA

Federchimica represents Italy's chemical industry, promoting collaboration among member companies and defending their interests in economic, social, labor, and cultural matters at national and international levels.

Lobbying Activity

Meeting with Paolo Inselvini (Member of the European Parliament)

21 Oct 2025 · Il ruolo dei PFAS per un futuro sostenibile, tra sfide e soluzioni

Federchimica urges faster EU approval for innovative biocontrol products

14 Oct 2025
Topic — EU initiative to simplify marketing authorizations for food, feed, and plant protection products.
Message — Federchimica calls for harmonized biocontrol definitions and streamlined 'single-zone' authorization procedures. They also request allowing drone-based pesticide application to improve precision and efficiency.123
Why — Streamlined authorization would reduce administrative costs and free up resources for product innovation.4
Impact — Environmental and health advocates lose protections established by current bans on aerial pesticide application.5
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Meeting with Elisabetta Gualmini (Member of the European Parliament) and European Ceramic Industry Association

8 Oct 2025 · ITRE committee

Meeting with Alessandra Moretti (Member of the European Parliament)

8 Oct 2025 · EU legislation update

Italian chemical industry seeks simpler medical gas rules

1 Oct 2025
Topic — The European Commission is reviewing rules to simplify medical device and diagnostic regulations.
Message — The association requests uniform classification across Europe and simplified rules for well-established technologies. They argue that complex design procedures and clinical evaluations are not necessary for these devices. Finally, they suggest reducing audit frequency and certification costs.123
Why — This would significantly lower administrative burdens and costs for medical gas producers.4
Impact — Notified Bodies would face reduced income due to lower audit frequencies and simplified processes.5
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Meeting with Giorgio Gori (Member of the European Parliament) and BASF SE

23 Sept 2025 · Upcoming REACH revision

Italian chemical industry urges updates to EU fertilising rules

18 Sept 2025
Topic — The Commission is evaluating the relevance and effectiveness of the Fertilising Products Regulation.
Message — The organization requests including missing materials like microorganisms and animal by-products in the regulation. They suggest that technical evaluations of new materials be handled by specialized experts. They also stress that national authorities must respect the optional nature of the EU rules.123
Why — Broadening the regulation would allow manufacturers to market more innovative products under the prestigious CE label.4
Impact — The European agricultural sector loses competitiveness if technical barriers continue to block innovative fertilizer products.5
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Assogastecnici calls for expanded ETS aid for gas industry

4 Sept 2025
Topic — Technical updates to EU guidelines allowing state aid for electricity-intensive industrial sectors.
Message — The organization requests including the entire industrial gases sector in the compensation scheme. They specifically want oxygen, nitrogen, and argon production to be recognized as eligible. This expansion would reflect the increased risk from rising carbon prices.12
Why — The expansion would reduce electricity costs and ensure fairness against self-producing competitors.3
Impact — Downstream manufacturing sectors face higher input costs if aid is not granted.4
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Meeting with Carlo Fidanza (Member of the European Parliament)

17 Jul 2025 · legislative updates

Meeting with Carlo Fidanza (Member of the European Parliament)

5 Jun 2025 · Event's invitation

Meeting with Valentina Palmisano (Member of the European Parliament)

15 May 2025 · incontro conoscitivo

Federchimica demands technical corrections to deforestation product list

13 May 2025
Topic — This consultation amends the list of products subject to EU deforestation regulations.
Message — The federation requests technical fixes for stearic acid and industrial fatty acids entries. They also urge a broader review of the Annex to prevent supply chain disruptions.12
Why — These adjustments would protect chemical producers from supply shocks and ensure fair competition.34
Impact — European consumers might lose access to essential goods due to potential supply disruptions.5
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Meeting with Carlo Fidanza (Member of the European Parliament) and TotalEnergies SE and

6 May 2025 · legislative updates

Meeting with Giorgio Gori (Member of the European Parliament) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

6 May 2025 · Ethanol classification

Meeting with Giorgio Gori (Member of the European Parliament)

2 Apr 2025 · Strategic dialogue on the future of the chemicals industry in Europe

Response to Amendment of conformity assessment procedures for EU fertilising products

27 Mar 2025

Il Regolamento UE 2019/1009 contiene specifiche disposizioni atte a garantire la conformità dei prodotti fertilizzanti secondo elevati standard di qualità e di sicurezza. In particolare, al fine di ottenere il marchio CE il Fabbricante di fertilizzanti è tenuto ad effettuare delle valutazioni di conformità secondo le procedure applicabili ai sensi dellarticolo 15. A seconda della Categoria Funzionale del Prodotto (PFC) o della Categoria di Materiale Costituente (CMC) del fertilizzante dovranno essere applicate le procedure (o moduli) presenti allinterno dellallegato IV. Alcuni moduli prevedono lintervento di un Organismo Notificato accreditato presso la Commissione europea, abilitato a valutare la documentazione tecnica predisposta dal Fabbricante in cui sono presenti numerose informazioni, tra cui descrizione del prodotto e delle materie prime, descrizione del processo di produzione, fac-simile delletichetta, norme armonizzate, verbali di prova. Attraverso tale documentazione tecnica si potrà dimostrare la conformità del prodotto fertilizzante dellUE alle prescrizioni del Regolamento europeo ai fini dellottenimento del marchio CE secondo i principi stabiliti nel Reg. CE 765/2008. Assofertilizzanti vorrebbe in tale contesto condividere alcune considerazioni in merito alla proposta di modifica di alcune prescrizioni inerenti ai moduli A1 e D1 affinché il Regolamento possa garantire lapplicazione di procedure uniformi utili a consentire limmissione in commercio di prodotti fertilizzanti dellUE. Per maggiori dettagli si rinvia alla lettura del documento in allegato.
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Meeting with Flavio Tosi (Member of the European Parliament, Rapporteur)

7 Feb 2025 · CTD

Federchimica Urges Four-Year Delay for New Pesticide Label Rules

30 Jan 2025
Topic — A proposal to modernize labeling requirements and risk communication for plant protection products.
Message — The group suggests a four-year transitional period to ensure a smooth transition toward digital labels. They argue that hazard-based color coding should not be included on labels already crowded with information. They request flexibility regarding which elements appear on the physical front page versus digital labels.123
Why — A longer transition allows companies to avoid immediate costs while adapting to digital labels.45
Impact — Farmers lose the simplified visual cues intended to help them identify lower-risk pesticide options.67
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Meeting with Massimiliano Salini (Member of the European Parliament)

28 Jan 2025 · Alternative fuels

Meeting with Massimiliano Salini (Member of the European Parliament)

14 Jan 2025 · REACH

Meeting with Massimiliano Salini (Member of the European Parliament)

4 Dec 2024 · REACH

Meeting with Elisabetta Gualmini (Member of the European Parliament) and Assicurazioni Generali S.p.A

17 Oct 2024 · ITRE Committee

Meeting with Irene Tinagli (Member of the European Parliament)

8 Oct 2024 · Meeting on chemical issues

Meeting with Paolo Inselvini (Member of the European Parliament)

25 Sept 2024 · Presentation of the association

Meeting with Stefano Cavedagna (Member of the European Parliament)

18 Jul 2024 · Introductory meeting

Italian fertilizer industry urges EU certification for recovered nitrogen

17 May 2024
Topic — Proposed updates to rules on using recovered nitrogen fertilizers in agriculture.
Message — The association supports using recovered nitrogen above current limits if strict technical criteria are met. They also advocate for a new EU certification system to ensure safety.12
Why — The proposal creates market opportunities for chemical companies processing manure into fertilizers.3
Impact — Producers of non-compliant fertilizers lose access to Nitrate Vulnerable Zone markets.4
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Federchimica demands resources for ECHA and expert committee preservation

27 Mar 2024
Topic — This consultation streamlines chemical safety assessments by consolidating tasks within European Union agencies.
Message — Federchimica requests that ECHA receives sufficient organizational and budget resources to manage its workload. They also urge for the preservation of expertise from existing scientific committees.12
Why — Continuity of expertise ensures that regulatory decisions remain predictable and technically sound for companies.3
Impact — Regulatory efficiency could decline if ECHA becomes overwhelmed by its significantly increased workload.4
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Federchimica Urges Trade Secret Protection for Chemical Data

27 Mar 2024
Topic — A regulation establishing a common data platform for chemical safety and transparency.
Message — Federchimica requests high security for confidential information to protect industrial competitiveness. They demand that study notifications be limited to those with clear regulatory utility.12
Why — This would reduce administrative costs and prevent the relocation of research activities outside Europe.3
Impact — Public authorities could lose early visibility into preliminary chemical screenings and innovative research methods.4
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

Federchimica (Federazione Nazionale Industria Chimica) sostiene gli obiettivi generali della Direttiva 2020/2184 ed è lieta di poter commentare gli atti derivanti dall'articolo 11. Tuttavia ritiene che gli atti siano complessivamente di difficile lettura visti i numerosi rimandi, la ripetitività delle definizioni e la mancanza di un quadro generale che permetta di ben comprendere la ricaduta generale sull'industria chimica. In allegato è possibile trovare alcuni commenti dettagliati alla Decisione di Implementazione della Commissione per l'articolo 11, paragrafo 2, lettera (b) della DWD (rif. Ares(2023)7108744).
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

Federchimica (Federazione Nazionale Industria Chimica) sostiene gli obiettivi generali della Direttiva 2020/2184 ed è lieta di poter commentare gli atti derivanti dallarticolo 11. Tuttavia ritiene che gli atti siano complessivamente di difficile lettura visti i numerosi rimandi, la ripetitività delle definizioni e la mancanza di un quadro generale che permetta di ben comprendere la ricaduta generale sullindustria chimica. In allegato è possibile trovare alcuni commenti dettagliati al regolamento delegato della Commissione per l'articolo 11, paragrafo 5, della DWD (rif. Ares(2023)7004776).
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Italian fertilizer industry urges risk-based soil health index

3 Nov 2023
Topic — EU consultation on a law for monitoring, managing, and restoring healthy soil.
Message — The organization requests aligning soil definitions with international standards and adding nutrient deficiency indicators. They propose replacing the strict one-out-all-out principle with a comprehensive Soil Health Index. They also seek to avoid administrative burdens from overlapping environmental regulations.1234
Why — A risk-based approach prevents unnecessary production limits and reduces administrative compliance costs.56
Impact — Environmentalists lose a strict safeguard where failing one metric labels soil unhealthy.7
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Response to Processed manure as component material in EU fertilising products

30 Oct 2023

La determinazione dellend-point per talune tipologie di prodotti fertilizzanti a base di sottoprodotti di origine animale (SOA) è un elemento di assoluta priorità per i fabbricanti di fertilizzanti. Lindustria di settore applica da anni le più recenti tecnologie e procedure per conformarsi al quadro normativo europeo in materia sanitaria (Regolamento CE 1069/2009 e Regolamento UE 142/2011) e, in tale contesto, apprezza la proposta di Atto delegato che andrà a modificare il Regolamento UE 2019/1009 inserendo nella Categoria di Materiali Costituenti (CMC) 10 Prodotti derivati ai sensi del Regolamento (CE) N. 1069/2009 lo stallatico trasformato. In tale contesto Assofertilizzanti desidera condividere alcune considerazioni di carattere tecnico auspicando possano essere di supporto alle Istituzioni prima delladozione dellAtto in parola. Per maggiori dettagli si rinvia alla lettura del documento in allegato.
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Meeting with Pina Picierno (Member of the European Parliament)

19 Sept 2023 · General discussion on European policies

Meeting with Nicola Danti (Member of the European Parliament) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

12 Sept 2023 · Posizione AISE e Federchimica su CLP

Federchimica urges risk assessment over blanket chemical export bans

28 Jul 2023
Topic — EU consultation on prohibiting the production and export of hazardous chemicals banned within Europe.
Message — Federchimica requests a socio-economic impact assessment to understand the implications for European industries. They argue that restrictions should be based on risk assessments rather than simple hazard classifications. The organization suggests improving global safety regulations instead of banning production.123
Why — This prevents loss of turnover and protects jobs within European chemical companies.4
Impact — People in non-EU countries remain exposed to chemicals deemed hazardous within Europe.5
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Response to Revision of Regulation (EC) 648/2004 on Detergents

27 Jul 2023

Federchimica, the Italian Federation of chemical industry, representing Aispec, the Italian Association of fine chemicals and specialised sectors, more specifically for two sector Groups operating in both raw materials for detergents and cosmetic products, and Assocasa, the Italian Association of Detergents and Specialties for industry and home care, is in favour of the simplification and innovation objectives of the proposed revision of the Detergents Regulation. Meanwhile, it is essential to underline the following critical issues: 1. Unique and clear definition of surfactant 2. Extension of the proposal to surfactants 3. Microbial-based cleaning products 4. Digital Passport & additional information requirements 5. Label requirements listed in Annex V 6. Biodegradability 7. Transition period 8. Digital labelling 9. CE marking 10. Roles and responsibilities Federchimicas concerns are more detailed in the attached document.
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Federchimica urges realistic timelines for EU green claim rules

21 Jul 2023
Topic — The EU initiative requires companies to prove environmental claims using specific footprinting methods.
Message — They suggest a 36-month transition and updated rules for bio-based materials. They also argue against banning green claims for items containing hazardous substances.123
Why — Streamlined verification would reduce administrative burdens and protect the industry's market competitiveness.4
Impact — Environmental organizations lose if the ban on hazardous substance claims is delayed.5
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

29 May 2023

Assofertilizzanti, Associazione nazionale produttori di fertilizzanti, che fa parte di Federchimica-Confindustria, raggruppa i principali operatori italiani del settore dei fertilizzanti, con un fatturato complessivo di circa un miliardo di euro, pari a oltre il 90% del mercato italiano. L'Associazione accoglie favorevolmente la proposta della Commissione Europea sul Regolamento per letichettatura digitale dei prodotti fertilizzanti dellUE, in quanto fondata su un approccio pragmatico nella gestione di etichette innovative. Tale pragmatismo è essenziale se si considera che, con lentrata in applicazione del Regolamento UE 2019/1009, sarà necessario gestire prescrizioni di etichettatura ancora più dettagliate e soggette a vari e frequenti aggiornamenti, specialmente per i prodotti ad elevato tasso di innovazione. Letichettatura digitale, dunque, è uno strumento essenziale che consentirà a tutti gli operatori del settore di poter veicolare e gestire le informazioni più rilevanti, in modo agile ed efficiente. Inoltre, tale digitalizzazione volontaria permetterà di allinearsi anche verso gli altri obiettivi in materia di sostenibilità ed economia circolare evitando costi superflui e riducendo i rifiuti da imballaggio. Tuttavia, se si vuole garantire una diffusione capillare di questo importante strumento, l'auspicio è che tale proposta normativa possa fungere da catalizzatore per i necessari interventi di abbattimento dei limiti infrastrutturali delle aree non servite da alcun servizio o servite con tecnologie non adeguate di limitata capacità di connessione. Per maggiori approfondimenti si rinvia alla lettura del documento allegato, che riassume alcune osservazioni di natura tecnica relative al testo della proposta.
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Federchimica defends Italian recycling model against strict reuse mandates

21 Apr 2023
Topic — The EU is revising packaging rules to promote circularity and reduce environmental waste.
Message — Federchimica requests flexibility for member states to choose effective waste management technologies. They also request immediate legal certainty for chemical recycling methods.123
Why — This would preserve Italy's cost-effective waste system and protect existing industrial investments.45
Impact — Consumers and international traders may suffer from trade barriers and health risks.67
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Italian chemical federation warns of CLP revision's industry impact

29 Mar 2023
Topic — A revision of EU rules for classifying and labelling chemical substances and mixtures.
Message — Federchimica requests revisions to the rules for multi-constituent substances, digital labelling, and label formatting. They highlight that the proposed amendments will have a huge impact on industry formulators and SMEs.12
Why — Adjusting the proposal would help small Italian chemical firms avoid excessive compliance costs.3
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Meeting with Patrizia Toia (Member of the European Parliament)

29 Mar 2023 · Industrial emissions Directive (meeting held by the APA responsible)

Federchimica urges risk-based approach for EU water pollutant lists

13 Mar 2023
Topic — The EU is updating rules on chemical pollutants in surface and groundwaters.
Message — Federchimica requests that the prioritization of pollutants be based on risk assessments rather than just chemical properties. They argue that lists should only include substances of EU-wide relevance and that controversial proposed limits for Bisphenol A should be withdrawn.123
Why — The chemical industry would avoid the compliance costs and legal risks associated with monitoring exceedances of substances they deem harmless.4
Impact — Local ecosystems and public health may receive less protection if certain substances are excluded from EU-wide monitoring lists.5
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Italian chemical lobby urges EU to scrap restrictive fertilizer rules

21 Oct 2022
Topic — Legislation defining when animal by-products in fertilizers are safe for the market.
Message — The association requests the removal of packaging limits and mixing bans for animal-based fertilizers. They also want more manufacturing methods recognized as safe for protein-based products.12
Why — Removing these restrictions would protect industry operations and avoid unsustainable waste disposal costs.34
Impact — Organic farmers lose access to essential materials for maintaining healthy soil fertility.5
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Italian Chemical Industry Urges UN Alignment on Hazard Classes

18 Oct 2022
Topic — Proposed updates to chemical classification rules introducing new hazard categories in the EU.
Message — The federation requests that new hazard classes be adopted internationally before implementation in the EU. They also call for clear technical guidance and longer transition periods for testing and software updates.123
Why — Global alignment would prevent the administrative burden of repeatedly updating product labels and safety documents.45
Impact — Downstream sectors and consumers may lose access to products due to a regulatory ripple effect.67
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Italian chemical industry warns EU pesticide cuts threaten agricultural competitiveness

19 Sept 2022
Topic — EU regulation on sustainable use of plant protection products and pesticide reduction targets.
Message — The organization requests that reduction targets be proportionate and realistic, based on thorough impact assessment. They argue targets should account for national specificities, cultivation variety, and climate conditions rather than imposing uniform cuts across member states.123
Why — This would protect their member companies' competitiveness and research investments in innovative products.45
Impact — Farmers lose access to crop protection tools, facing production drops exceeding 80% in some areas.67
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Italian Chemical Industry Warns Against Stricter EU Emissions Rules

22 Jun 2022
Topic — Revision of EU Industrial Emissions Directive to reduce pollution from industrial facilities.
Message — The federation requests flexibility in setting emission limits, clarification that new requirements apply only to new installations, and transition periods when standards change. They oppose mandatory environmental performance levels without clear prioritization and want existing management systems to suffice.1234
Why — This would protect their existing permits and avoid costly retrofits of recently installed equipment.5
Impact — Communities near industrial facilities lose stronger protections from pollution and health risks.6
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Response to Sustainable Products Initiative

22 Jun 2022

Federchimica recognises the overall objectives of the European Commission proposal on the Ecodesign for Sustainable Products Regulation (ESPR) and believes that the Regulation will have a significant impact on its members as producers of chemicals (substances and mixtures). To achieve the ambitious targets of the ESPR it is necessary to involve the chemical industry, which is well positioned to contribute to sustainability through its products and technologies. Federchimica has analysed the proposal focusing on the implementability, workability and clarity of this proposed regulation, and on how this legislation interacts with existing legislations that regulate sustainability requirements of products. Federchimica points out the complexity of this regulatory framework going into a significant level of details regarding requirements for products, components, intermediate products and substances and the many interfaces with existing legislations. Federchimica’s comments aim at the improvement of the ESPR proposal, assuring simultaneously its workability and the competitivity of European companies. Key Messages: • Avoidance of duplication of existing legislations, specifically chemical regulation for substances, and a clear interface between the different legislative frameworks are fundamental topics to be addressed. • Digital Product Passport: the information requirements relating to chemical substances should be workable. • Sustainability requirements should be comparable, enforceable, and limited to the most relevant criteria and substances in the final product. • Allow additional methods to assess environmental impact (e.g. Life Cycle Approach, ISO 14025 and ISO 14040 series) and amend the PEF methodology to assess the benefits of all circular feedstocks. • Full EU wide harmonisation; rules for specific product parameters should be the same in all European countries. Clarify that Member States should not have the possibility to set specific product parameters. • No disadvantages for Europeans producers vs. non-EU competitors. • Strong incentives to bring at scale the market of sustainable products and a phased implementation timeline.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Chemicals are everywhere in our daily lives and the role of the chemical industry in the EU green transformation is of paramount importance. REACH is the most comprehensive regulatory framework securing safe use of chemicals and the last evaluation of REACH (in 2018) has brought the European Commission to say that REACH Regulation is effective, fit for purpose and delivering on its objectives. Federchimica is aware that there are opportunities for further improvement, simplification and burden reduction and this should be the starting point for the discussion. In more than ten years of application, the European chemical industry has tried to make REACH workable and has done significant efforts in improving its implementation, also trough cooperation with the Authorities and the stakeholders. Moreover, the industry has requested to work continuously on areas that require improvements (dossier quality, improve communication along the supply chain, etc.). In light of the above, the companies members of Federchimica believe that it would be more appropriate at this time to consider a targeted reopening of REACH that improves the existing processes with the aim to truly protect human health and environment through a strong and coordinated enforcement across Member States. Instead we have seen in the Inception Impact Assessment that the REACH 2022 revision would open to many new provisions, changes, duties and so on. We think that, in this moment, the priority should be to seek to streamline where possible to achieve more consistency, eliminate duplication and improve existing processes. For instance to propose to expand the concept of very high concern to other groups of substances like those with the characteristics of persistency and mobility (PMT or vPvM) would comport a significant workload for all the stakeholders and should be avoided without to have clear definition and criteria to define these substances or to have performed an accurate impact assessment. Only in this way it will be assured stability for investment that may bring also to search potential new substances with improved societal benefits. We fear that the revision will bring to more bureaucracy and further complications for companies and that these additional burdens will further weaken competitiveness of EU companies against non-EU competitors. In addition, the fact that Commission is willing to allow a number of jobs to be lost, with the hope that a future growth will compensate for the current loss, represents a critical issue. In fact, there is no certainty that the expected growth will take place, especially if companies will move their activities outside Europe. Federchimica wishes to provide preliminary considerations on the following topics (see the attached document): - Revision of registration requirements - Revision of the provisions for dossier and substance evaluation (compliance of registration dossiers) - MAF - Simplifying communication in the supply chain - Reforming authorisation and restriction processes - Revision of provisions for control and enforcement
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Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

Agrofarma and Assofertilizzanti are two associations of Federchimica (the National Federation of Chemical Industry) which represent, respectively, the companies of the agropharmaceutical sector (products for the protection of crops from animal and vegetable parasites) and the productive reality of the fertilizer sector. We would like to thank the European Commission for the opportunity of commenting on its draft proposal specifying which substances can be used as inputs in Organic Farming in Europe. First of all, the sector supports and favours the co-existence of different farming systems, highlighting the importance of recognizing and enhancing all types of agriculture in an inclusive and non-conflicting logic. Therefore, we believe it is essential to stimulate sustainability, focusing on farm performance and biodiversity improvement rather than on the farming model. We welcome a more open and transparent approach when revising the list of authorized plant protection products (PPP) and fertilizers for use in organic agriculture. However PPP and fertilizers products in Europe have undergone the most rigorous assessments globally, it remains unclear how so few solutions end up on this list. Although the EU rightly sets very stringent limits, we would like to point out that to ensure sustainable production, organic farmers need effective solutions to control the natural risk of encounter crop diseases and/or a lack of nutrition. A more transparent process and clarity on the scientific criteria used are needed, this is to satisfy consumer demand for trustworthy organic products while providing a fair marketplace for consumers, producers, distributors and marketers. With Industry research and development the Organic farming can benefit from new solutions, like the nutrients recycling/recovery and innovative and safer substances for crop protection should be more widely implemented and supported by the Institutions. This lack could damage Organic Farming in Europe and prevent the Farm-to-Fork target of at least 25% of the EU’s agricultural land under organic farming by 2030. Study of complex matrices are also necessaries in order to identify the analytical methods and treatment of the samples in order to characterize, separate and purify the chemical species they contain. We also would like to ask the European Commission to make a check with Member states in order to evaluate further implementations and addition of new products/substances to the lists of the Annex I and II of this Regulation.New products with enhanced profiles keep being developed and placed on the EU market. Having a clear mechanism allowing continuous evaluation and update of these lists to incorporate new tools would be contribute to the EU objectives regarding the development of areas under organic agriculture.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Federchimica (Italian Federation of the chemical industry) believes that the Chemicals Strategy for Sustainability (CSS) should ensure an high level of human health and environmental protection, by integrating the several dimension of the Green Deal in an holistic approach – climate neutrality, materials circularity and efficiency of resources – and by promoting at the same time social development, competitiveness and innovation, ensuring in this way the European industrial production and consequently Europe’s strategic interests. We believe the strategy should: 1) Enable the development of sustainable and competitive European solutions Recognizing that the chemical industry is an essential sector for the transition towards a sustainable and circular economy and his role to build a modern society, we think that the CSS should consider incentives and digital technologies to boost innovation towards safe and sustainable products that are needed for climate neutrality. More specifically, we need: - a widely accepted framework and a reference methodology(ies) for product sustainability performance assessment - a central place compiling all sustainability information (chemical dataspace) - tools to accelerate chemical safety testing while minimising animal testing - practical solutions to address ‘legacy substances’ and enable the production of high-quality recycled materials , for instance by supporting new recycling technologies such as chemical recylcing and biobased chemistry. In this context we agree with the necessity to bring back to the EU, the production of chemical substances in strategic supply chains, such as active pharmaceuticals ingredients and disinfectants. 2) Consolidate and promote the solid foundation already built via improvement, better implementation and enforcement Federchimica considers that CSS objectives should be pursued in the current legislative framework –REACH and other specific sectorial regulations (ex. Food contact materials, biocidal products) – also regarding to safety and workers health. These regulations are based on the chemicals risk assessment principle and not on the intrinsic hazard of chemicals. Through these regulations, the chemical industry and the European Union ensure that chemical substances are produced, managed and used in a safe way, throughout the whole supply chain. The CSS should work on the improvement needs identified in the recent Reviews and Fitness Checks of REACH: streamlining if possible to achieve more consistency and eliminate duplication, stepping up enforcement (on imported products), ensuring enforceability of regulatory measures, and solving some implementation issues: improving registration dossiers where needed, clarifying some of the most complex data requirements towards minimising animal testing, effective and digitised safe use communication in the supply chains, enhancing the Risk Management Options Analysis tool, and communicating more positively about the role of chemicals. 3) Adopt a proportionate and robust approach for managing scientifically complex issues The CSS should be based on a proportionate and robust approach to manage these scientifically complex issues such as endocrine disruptors, combination effects of chemicals, chemicals that may build up in the environment. Science needs to remain at the heart of decision-making. Where there is scientific uncertainty, a stepwise regulatory approach should be taken: for instance, first step should be limited to a defined scope with a focus on main releases and risks and based on existing data, followed by reviews in a second stage. By all means, realistic exposure assessments have to be at the core of risk assessment and management.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

29 Apr 2020

Response from Federchimica – AISPEC: Chemistry from Biomass Industry Sector, to the Consultation on the development of post-Euro 6/VI emission standards for cars, vans, lorries and buses COMBINED EVALUATION ROADMAP / INCEPTION IMPACT ASSESSMENT - 29th April 2020 Increasing the efficiency of the Internal Combustion Engine (ICE) has been a key driver of passenger transport emissions reduction of to date. Average tailpipe CO2 emissions from petrol-fueled vehicles dropped by over 30% in the period 2000 to 2016, mostly because of higher engines thermodynamic performance. Quality of fuel used played an fundamental role in enabling cleaner cars. It is of paramount importance that such a virtuous trend continues, especially taking into account Europe’s expected few more decades of usage of internal combustion engines, and the proven significant further technological improvement potential. We trust the European Commission to help further reduction of CO2 emissions from petrol passenger cars by enabling and facilitating the advent of new significantly higher-octane fuel specification within post-Euro-6 regulation. Our “Chemistry from Biomass” industrial sector, part of AISPEC (Federchimica), strongly advises to include this extremely valuable option into the aim and purposes of the impact assessment. Upgrading the EU petrol’s Research Octane Number (RON), from current RON 95 to RON 102, combined with market deployment of higher efficiency engines (higher compression ratio, downsized, turbo-charged) would enable a significantly higher cars’ energy efficiency and relevantly contribute to CO2 and air pollutants emission reduction. Fuel ethers are a unique opportunity and solution to achieve such important EU objectives. Higher quality/octane petrol, when used in higher-compression ratio engines, grants an average efficiency improvement of about 7% (typically 1% per each 1 RON point increase) and, once fully implemented, it would entail a CO2 emissions reduction up to 20 million T/Y, in addition to any advanced renewable fuels roll-out. Noticeably, also existing “conventional” car fleet would non-negligibly benefit from a shift to RON 102, allowing vehicles electronics to better optimized energy management during the combustion cycle. An higher efficiency ICE would, contextually and additionally also enable more efficient hybrid electrical petrol-vehicles to get cleaner: extremely relevant when considering that hybrid vehicles currently represent 97% of all kilometers driven out of all types of EVs. In supporting the development of hybrid powertrains, higher efficiency fuels/ICE engines will foster the development and success of transport electrification. The here depicted fuel improvement doesn’t need any new or special infrastructure and it would deliver immediate benefits, which would add-up to those of electrical mobility. Higher octane fuels would benefit multiple societal stake-holders, ensuring added value to the environment, consumers, vehicle manufacturers and refiners: • Environment: Reducing both green-house gases and toxic regulated emissions and ensure better air quality • Consumers: Reducing fuel consumption, allowing longer distance travel on the same fuel volume used, thanks to higher combustion efficiency. • Automotive industry: Offering additional option to achieve very ambitious emissions-saving EU targets. • Refiners: Enabling them to prove relevance of their industry to actively and effectively contribute to the target of needed transport sector’s carbon efficiency improvement.
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Response to Farm to Fork Strategy

16 Mar 2020

Please find attached Federchimica's contribution.
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Response to Revision of the Regulation on marketing and use of explosives precursors

31 Jul 2018

Federchimica welcomes this new proposal and the possibility to contribute with additional comments. Anyway we observe that the shift of sulphuric acid from Annex II to Annex I, with a concentration of 15% / 40% will make impossible its use to solve the most difficult cases of clogged tubes. In fact this kind of products are ineffective when the concentration of sulphuric acid is below 90-95%. The Italian market of drain pipe cleaners with sulphuric acid is about 2.000.000 bottles per year. The amount of Sulphuric acid for the production of drain pipe cleaners is about 3.300 tons per year. This means that an eventual use restriction will have a consistent impact on the Italian market. Attached the results of a test conducted by a member company to support above indications.
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Federchimica warns early data disclosure threatens chemical industry innovation

25 Jun 2018
Topic — The Commission is proposing reforms to enhance transparency in food chain risk assessments.
Message — Federchimica urges the Commission to release supporting data only after the authorization process is finalized to protect technical know-how. They also advocate for a review mechanism regarding confidentiality decisions and better alignment with pharmaceutical assessment standards.12
Why — Delaying disclosure allows companies to protect their research investments and maintain market competitiveness.3
Impact — Rival firms lose the advantage of accessing trade secrets before new products launch.45
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Response to Amendments following Article 15 of the cosmetic Regulation 1223/2009

24 Jul 2017

Cosmetica Italia, the personal care Italian association, welcomes the opportunity to comment on the CMR Omnibus proposal by the Commission and fully supports the Commission’s general proposal to list in Annex II of the Cosmetic Products Regulation CMR substances that are not authorized for use in cosmetic products. As there appears to be no use by industry, all CMR substances that are not listed in COSING and the EU Inventory can be moved to Annex II of the Cosmetics Regulation (+/- 180 substances). Transition periods are necessary to allow industry to adapt to a new legal requirement and are a corner stone of good regulatory practice. In this particular case, however, there is no past or present use by Cosmetica Italia members and the substances can be listed in Annex II with immediate effect. Furthermore, the following CMR substances are not used anymore by Cosmetica Italia members as cosmetic ingredients. Transition periods are usually necessary to allow industry to adapt to a new legal requirement and are a corner stone of good regulatory practice. In this particular case, however, the substances can be listed in Annex II with immediate effect. Chloroacetamide, Methylene chloride ,Imidazole, 2-ethylhexyl-2-ethylhexanoate, N-methyl-2-pyrrolidone, 4-tert-butylbenzoic acid, N-ethyl-2-pyrrolidone, Vinyl acetate, Styrene, Acetaldehyde, Ketoconazole, Boric acid and salts that are classified as CMR, Quaternium 15. Cosmetica Italia would like to share comments on some specific substance entries: • Hydroquinone is already correctly regulated under entries annex II/1339 and annex III/14. The use of hydroquinone in artificial nail systems has been assessed as safe by the SCCS and the proposed entry 1385 is therefore not necessary. • Musk xylene has also been evaluated as safe by the SCCS and is currently listed in annex III. This substance is also listed as vPvB under Annex XIV (entry No.1) of REACH and cannot be used in cosmetic products without an authorization under REACH. From a procedural perspective a ban under the CMR omnibus has no legal basis. • Cosmetica Italia disagrees with the ban of formaldehyde in nail hardening products as all criteria to get an exemption under Art. 15 of Cosmetics Regulation were fulfilled i.e the SCCS confirmed the safety of the use of formaldehyde in nail hardening products, the criteria of compliance with food law is fulfilled and data demonstrating the absence of suitable alternatives have been provided by industry. • For Furfural, TPO and PHMB, an exemption procedure is ongoing and they should be regulated accordingly – where applicable with an adequate transition period. The industry should be allowed a reasonable period of time to make the necessary adjustments to product formulations in view of their placing on the market and for the withdrawal of non-compliant products from the market. For the “other conditions” for PHMB, Cosmetica Italia proposes the agreed standard wording for inhalation exposure to be consistent throughout the Regulation: ”Not to be used in applications that may lead to exposure of the end user’s lungs by inhalation” and a transitional period of 6 months for products to be made available on the market. • For Octamethylcyclotetrasiloxane (D4) there was a positive SCCS opinion in 2010. It was not included in the European Commission list of ‘Substances considered as banned under Article 15’. Consequently, some SMEs continued to use the substance in cosmetic products and an immediate ban would result in a significant impact to these businesses. Cosmetica Italia does no longer pursue the exemption procedure and agrees that the substance is listed in Annex II. However, given that current use is recognized as safe by the SCCS and the fact that it was not communicated by the Commission as being in the scope of the Article 15 ban, a transition time of 12 months should be granted from the time of publication of the ban to allow companies finalization of reformulations
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Response to Flavourings - as regards certain flavouring substances

22 Nov 2016

AISPEC Gruppo aromi e fragranze (The Italian Association of flavour and fragrance companies) represents the Italian Flavour Industry. AISPEC Gruppo aromi e fragranze has the following comments in relation to the Commission proposal for a regulation on so-called FGE203 flavouring substances. The FGE203 substances are considered ‘flavouring substances under evaluation’. Regulation (EU) No 872/2012 does not foresee in an option to introduce ‘interim risk management measures’ for ‘flavouring substances under evaluation’. Article 4 of Regulation (EU) No 872/2012 clearly states that ‘Flavouring substances under evaluation may be placed on the market and used in or on foods pending their inclusion as evaluated flavouring substances in Part A of the Union list or their removal from that list.’ In April 2014 EFSA issued an opinion (FGE.203Rev1) on the substances of this group in which the EFSA CEF Panel stated that the concern for two representative substances could not be ruled out based on the available data at that time. Consequently the Industry has embarked on additional testing to demonstrate the safety of these materials. For the substances of this group (FGE.203) the industry has meanwhile submitted additional data to enable EFSA to complete the safety assessment. It is expected that EFSA will re-evaluate these substances based on the additional information submitted by industry and that based on this new info EFSA will clear these substances from the genotoxicity concern. Consequently this will be a precautionary measure applying for only an interim period, which makes it very disproportionate. Moreover, such precautionary measure will create unnecessary administrative burden for the flavour and food business operators: a huge workload is generated for the flavour companies to inform their customers (food companies) about the presence and use levels of the affected flavouring substances. Such measure may also lead to unnecessary reformulations. For the above reasons AISPEC Gruppo aromi e fragranze advocates a “status quo” where the legal status of the substances of this group (FGE.203) is not changed, but remains with a legal certainty as reflected in part A of Regulation (EU) No 872/2012 (EU Union List) with footnotes referring to the ongoing safety assessment by EFSA, until the completion of the safety assessment by EFSA based on the newly provided data by the European Flavour Industry (EFFA).
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Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

25 Sept 2015 · Commissioner's priorities, medicated feed