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GLASS ALLIANCE EUROPE AISBL

GAE

Glass Alliance Europe represents the European glass industries, coordinating their views on legislative developments.

Lobbying Activity

Glass Alliance Europe demands robust carbon border rules for industry

25 Sept 2025
Topic — Rules for adjusting carbon border certificates to reflect free emission trading allowances.
Message — The association calls for CBAM to cover manufacturing, electricity, and transport emissions with robust verification. They urge the Commission to apply high default values for importers who fail to report data.12
Why — This would prevent foreign competitors from undercutting EU prices through lower environmental costs.3
Impact — Non-EU manufacturers in carbon-intensive countries would face significantly higher costs and stricter reporting.4
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Glass Alliance Europe demands strict standards for foreign carbon pricing

25 Sept 2025
Topic — Rules for calculating carbon price credits paid in non-EU countries under CBAM.
Message — The organization demands that the Commission apply strict and transparent criteria for foreign systems. They insist that any refunds or compensations provided to exporters must be disallowed. Credits should be limited to the actual, verified costs borne by producers.123
Why — This ensures imported products face a carbon cost equivalent to European glass.4
Impact — Exporters from nations that provide preferential treatment or lack equivalent standards.5
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Glass Alliance Europe calls for strict carbon border rules

25 Sept 2025
Topic — This consultation defines the methodology for calculating embedded emissions during CBAM's definitive phase.
Message — They demand robust, independent verification of emissions and high default values for importers. They also urge including transport emissions and strict oversight of foreign carbon pricing.123
Why — Strict rules ensure foreign competitors face carbon costs equivalent to EU manufacturers.4
Impact — Importers from low-standard countries face higher costs and stricter reporting requirements.5
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Meeting with Stefan Leiner (Head of Unit Environment)

11 Sept 2025 · Exchange of views on the BREF work programme under the Industrial Emissions Directive (IED)

Glass Alliance Europe urges realistic emissions cap reduction targets

4 Jul 2025
Topic — The consultation reviews the EU Emissions Trading System and market stability.
Message — Review the emissions cap trajectory to avoid reaching zero by 2040. Ensure benchmarks remain technologically achievable and provide robust carbon leakage protection.12
Why — A slower decarbonisation pace protects industries from closing due to high costs.3
Impact — The power sector receives fewer emission allowances to support industrial competitiveness.4
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Meeting with Wopke Hoekstra (Commissioner) and

22 May 2025 · The global/Chinese overcapacity in glass production and dumping on the EU market and the role of the European glass industry for greenhouse gas reduction in the EU

Meeting with Elena Donazzan (Member of the European Parliament)

12 May 2025 · Industrie energivore e sfide dell'industria del vetro

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Tom Berendsen (Member of the European Parliament) and RWE AG

25 Feb 2025 · Work visit

Meeting with Paulo Cunha (Member of the European Parliament)

4 Dec 2024 · Glass industry

Meeting with Radan Kanev (Member of the European Parliament)

13 Nov 2024 · Future of the glass industry in the Clean Industrial Deal

Glass Alliance Europe urges changes to carbon allowance rules

28 Dec 2023
Topic — The consultation updates rules for free carbon allowance allocations under the EU Emissions Trading System.
Message — Apply climate neutrality penalties at the sub-installation level instead of for entire facilities. Keep reduction factors for process emissions at 3% to ensure technical feasibility. Provide more time for energy efficiency measures before cutting free allowances.123
Why — This would reduce compliance costs and prevent significant cuts to an installation's free allowances.45
Impact — Environmental groups face setbacks if industrial sectors delay significant greenhouse gas emission reductions.6
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Glass Alliance Europe Urges Flexible Climate Plan Timelines

31 Aug 2023
Topic — Rules for climate-neutrality plans for installations receiving free carbon emission allowances.
Message — Milestones should be adjusted to match industrial furnace investment cycles. The group argues that emission reductions cannot be linear for all industries.12
Why — This would reduce costs by aligning climate targets with existing equipment lifecycles.34
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Glass Alliance Europe opposes reporting sensitive production data

23 Jun 2022
Topic — The Commission is revising how industrial installations report pollutants to improve public access.
Message — The organization objects to rules requiring reporting of production volumes, employee numbers, and operating hours. They argue this data should not be requested at all to protect business confidentiality.12
Why — Protecting this information prevents competitors from calculating sensitive operating costs and maintains market advantage.3
Impact — Public transparency suffers as researchers cannot contextualize pollution data against industrial production levels.45
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Glass Alliance Europe warns against sharing confidential industrial data

23 Jun 2022
Topic — This consultation addresses updating EU rules to reduce industrial pollution levels.
Message — The group requests flexibility for innovation and the protection of business secrets. They call for the removal of requirements granting NGOs access to confidential information.12
Why — This protection preserves their competitive advantage and minimizes new administrative costs.34
Impact — Environmental groups lose the ability to scrutinize detailed industrial data.56
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Response to Revision of the Energy Tax Directive

17 Nov 2021

Glass Alliance Europe input to the Public Consultation on the Revision of the Energy Taxation Directive (ETD). 17 November 2021 Glass Alliance Europe (GAE), the European Alliance of Glass Industries, welcomes the opportunity to provide feedback on the Commission proposal to introduce a Energy Taxation Directive (ETD). Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution. To reach carbon neutrality, European glass manufacturers will have to invest massively in R&D and new technologies. This investment effort will take place in a context of high CO2 prices and energy prices. Maintaining the competitiveness of European manufacturers already exposed to unfair competition from countries with no or laxer climate policies is therefore essential. However, GAE has noted with concern that the draft Energy Taxation Directive 2022 no longer explicitly mentions mineralogical processes in Article 3 (b) which are out of scope. Considering the energy intensity and high trade intensity faced by the European glass industry, keeping the current applicable tax exemption is essential for its international competitiveness. Adding mineralogical processes in the new ETD would cost hundreds of millions of Euros to the glass industry. This would constitute a double burden with the Emission Trading Scheme, and severely undermine the capacity for the glass industry to invest in low carbon technology and succeed its energy transition. Based on above considerations, GAE asks the EU Commission to keep 'mineralogical processes' in the list of uses of energy products and electricity in Article 3 1. (b) of the Proposal for a COUNCIL DIRECTIVE restructuring the Union framework for the taxation of energy products and electricity. The more the glass industry moves towards low carbon production technologies, the more electricity it will use as an alternative to fossil fuel (increasing the share of electricity in its energy mix). Taking mineralogical processes not explicitly out the scope of the energy taxation directive will increase production costs and will increase glass industry electricity tax burden, therefore making investments into decarbonisation more insecure and costly, and less attractive. This contradicts the aim of the Commission that “electricity should always be among the least taxed energy sources in view of fostering its use”. Additionally, it has to be noticed that the move to electrification is already penalized by the fact that glass industrial sectors are not compensated for indirect carbon costs associated with electricity.
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Response to Carbon Border Adjustment Mechanism

17 Nov 2021

Glass Alliance Europe input to the Public Consultation on the Carbon Border Adjustment Mechanism Proposal. Glass Alliance Europe (GAE), the European Alliance of Glass Industries, welcomes the opportunity to provide feed-back on the Commission proposal to introduce a Carbon Border Adjustment Mechanism. Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution. CBAM and free allocation CBAM should not be perceived as an alternative to the free allocation of ETS allowances as both measures address different types of carbon leakage. For instance, a CBAM alone would not solve the issue of carbon leakage for EU industries that are mainly export-oriented. From a legal point of view, the co-existence of free allowances and a CBAM under the EU ETS umbrella can be WTO compatible See also the position paper on the Alliance of EII (attached). The consistency with WTO rules can be achieved by treating importers and EU manufacturers on the same footing, requiring importers to only buy allowances above the benchmark levels. The co-existence of free allowances and CBAM would reduce additional costs for EU manufacturers, allow sufficient time for the deployment of low carbon technologies and alleviate the impact on EU value chains and final consumers. Solution for exports EU manufacturers will bear carbon costs for the entirety of their production, while foreign manufacturers will only face additional costs for the exports to the EU. This asymmetry will make EU exports more expensive than local production in regions where no (or less) carbon costs exist. This will inevitably result in lower access to export markets for the European industry, with a negative impact on EU trade balance, on EU manufacturers competitiveness and on global CO2 emissions. It is therefore crucial to design a system for EU exports as part of CBAM. Such solution should be developed in time for the implementation of CBAM. This would act as a further incentive to ensure third countries set up carbon pricing schemes. Monitoring and Verification Under the EU ETS, EU operators must comply with annual monitoring, reporting and verification requirements with data verified by an EU accredited verifier. Shall a CBAM be introduced, the same level of control should apply to non-EU operators importing products. Ideally, emissions should be calculated and reported at installation level, as it is the case for EU operators. Defining the exact carbon content of imported products is critical to the success of the CBAM. Both direct and indirect emissions should be accounted plus emissions resulting from the transport of the goods up to the EU border. Should the legislator wish to propose the introduction of benchmarks (at the relevant statistical level; i.e. NACE or Prodcom), these should be set per product and country of origin. To avoid the import of carbon-intensive products to the EU, the imported product benchmarks per country of origin should be set at adequate levels so to incentivize non-EU operators to present emissions’ reports verified by an EU accredited verifier. Circumvention measures The CBAM proposal is complex and open to loopholes and circumvention. In the Commission proposal, the definition of circumvention (i.e. finding ways to avoid the CBAM) is too restrictive and limited to slight product modifications. There are however other means to get round the CBAM such as resource shuffling (allocating low carbon production in a country for EU exports with no effect on the overall CO2 emissions), transhipment strategies (if exemptions exist) or costs absorption (only part of the foreign production is subject to CBAM). The proposal should therefore better define and address circumvention risks.
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Glass Alliance Europe demands protection against rising carbon costs

8 Nov 2021
Topic — Review of the EU Emissions Trading System to meet higher climate targets.
Message — The group seeks to avoid correction factors and keep free allowances with border taxes. They also request that electrification becomes eligible for financial compensation.123
Why — This would protect glass manufacturers from high carbon prices and international competition.4
Impact — The power sector could face stricter caps to accommodate industry's demand for allowances.5
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Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Response to Revision of EU rules on food contact materials

28 Jan 2021

Glass Alliance Europe (GAE) supports the improvement of FCM safety and welcomes the current work of the Commission. GAE would like to contribute with some important comments, as specified in the appended annex.
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Response to Chemicals strategy for sustainability

19 Jun 2020

GLASS ALLIANCE EUROPE Contribution to the Roadmap on the Chemicals Strategy Sustainability The European Glass Industries welcome the roadmap’s consultation on „Chemicals - strategy for sustainability“ as a part of the Green Deal. Indeed, the glass sectors support a sustainable use of chemicals and wish to cooperate in the further developments of the chemicals policies. The glass manufacturing processes require the use of different chemicals, already covered by EU regulations such as REACH, CLP, Circular Economy, Waste Directive and Occupational Safety and Health regulations. Hence, additional regulations should be framed to not multiply the obligations from the industrial actors, but to address potential gaps or existing issues in the current regulations. More precisely, the glass manufacturers are supporting the announced simplification and strengthening of the legal framework, notably with the process of ‘one substance – one assessment’ proposed in the roadmap. Indeed, as glass is considered as one matrix substance, its assessment needs to remain based on the evaluation on the substance glass present in the final products, and not from the raw materials used to manufacture it. Additional specificities linked to the matrix characteristics should also be kept in mind at the time of setting or updating chemical regulations. European glass production is supplying a wide range of product to the European society supporting innovation across Europe for example within automotive, renewable energy, building and infrastructure as well as pharmaceutical sectors. Glass products contribute to the sustainability of the EU especially to a circular economy and the manufacturers wish to contribute to the ambitions promoted via the EU Green Deal. Container glass products, used for safe packing of food and drinks, are recycled multiple times. Flat glass products help to reduce energy consumption in buildings and automotives vehicles as well as producing renewable energy via solar panels and contributing to society’s health and well-being via the transparency of glass ensuring access to natural light. Glass fibre products are the most widely used reinforcement for composite material, delivering mechanical strength, light weight and durability (corrosion resistance). Composites applications contribute to sustainability improvements in transportation (e.g. automotive, trains, aircrafts), renewable energy (e.g. windmill blades), infrastructure (e.g. composite bridges), drinking water supply pipes, etc. Domestic glass articles are fully reusable and recyclable. Special glasses have very different applications as thermo-change resistant materials for astronomy and standardization applications, chemical resistant glasses for laboratories and pharma packaging, lenses for microscopes as well as image and light guides for endoscopes ensuring medical and pharmaceutical crucial operating steps. With all these applications, the glass industry makes a substantial contribution to sustainability with innovative solutions.
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Response to EU rules on industrial emissions - revision

20 Apr 2020

Glass Alliance Europe (GAE) welcomes this opportunity to comment the inception impact assessment on the Industrial Emission Directive (IED) review and would like to highlight two elements that should be taken into account at the time of the impact assessment. Firstly, while the European glass sector wants to contribute to the decarbonisation of the economy, notably by implementing GHG abatement measures on manufacturing sites, these actions and moreover their results in term of CO2 emissions are already covered by the Directive 2003/87/EC (also called EU ETS Directive). Hence, GAE, as well as many Energy Intensive Industries, rejects the option to regulate GHG emissions under an IED permitting regime, without prejudice to the article 9.1 of the IED (see enclosed EIIs Joint contribution). Secondly, the Green Deal zero pollution ambition needs a cautious implementation into the IED. Indeed, this ambition needs to be translated in a coherent way by taking into account the technologies currently available on the market, i.e. the Best Available Technics (BAT), which are at the source of the IED permitting in Europe.
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Response to 2030 Climate Target Plan

15 Apr 2020

Glass Alliance Europe, the European Alliance of Glass Industries, welcomes the opportunity to comment on the draft 2030 Target Climate Plan. The association has decided to submit a joint contribution, together with 11 other energy industries, to highlight a number of key elements that would need to be considered for an increase in the GHG emission reductions target for 2030 (in attachment). Glass Alliance Europe wishes to stress that a number of enabling conditions are required for a swift reduction of manufacturing emissions; e.g. availability of disruptive technology, enabling infrastructures, carbon neutral energy, and financing. The assessment should therefore consider if these conditions are available (in practice and not theoretically) for further increasing the contribution of energy intensive sectors by 2030 compared to the current target. Glass Alliance Europe shares the European Commission views when it states that the mitigation potentials between the different sectors of the economy differ strongly. Studies show that the mitigation potential in the building and transport sectors are particularly high. Therefore, the European Commission should consider in its impact assessment increasing significantly the GHG emission reduction effort in these sectors where solutions are available on the short term. Finally, a possible increase of EIIs’ carbon leakage exposure should be assessed alongside the revision of the 2030 climate targets. Should the emission reductions target for energy intensive being reviewed in 2021, this will inevitably impact the carbon leakage exposure of the energy intensive sectors.
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Response to Climate Law

3 Feb 2020

The European Glass Sector Contribution to the Roadmap on New Climate Law In the context of urgent action to reduce carbon emissions, the European Commission proposes to write into law the goal set out in the European Green Deal – for Europe’s economy and society to become climate-neutral by 2050. Glass Alliance Europe agrees that, should the objective of climate-neutrality be confirmed, a Climate Law would provide certainty on the direction the European Union will pursue in its public action. It is all the more important to the European glass industries that certainty and clarity be provided on the measures that the European Union will introduce in the coming years. Glass Alliance Europe shares the view expressed by the European Commission that the climate-neutrality objective is achievable only if all EU policies contribute to this goal and all sectors of the economy and society play their part. In this respect, a competitive EU industrial basis at the forefront of low-carbon solutions will be crucial for the transition of all economic sectors of the European economy. Glass is in this sense a key enabling material for the transition in sectors with the highest emissions reduction potential (i.e. energy, building and transport) which make it an essential product for a carbon-neutral Europe. By being an infinitely recyclable material, reusable in its container applications, glass also contributes greatly to achieving a genuine circular economy, saving resources and reducing carbon emissions. The European glass industry has invested in the decarbonisation of its manufacturing processes and will continue investing to manufacture glass products fit for a sustainable, resource-efficient, low-carbon European society. Notwithstanding, it is the authorities’ actions which will provide the enabling framework for the industrial revolution envisaged in the Green Deal. The EU industrial strategy announced for March 2020 and its subsequent public measures will therefore be crucial to set a decarbonisation pathway that safeguards the affordability of glass products, overcomes the bottlenecks to the decarbonisation of manufacturing processes, guarantees that infrastructures are in place to ensure the constant and affordable flow of renewable energy sources and the good functioning of the EU internal market.
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Glass industry urges symmetry in EU carbon permit rules

9 Jul 2019
Topic — The European Commission is updating rules for industrial free allocation under the ETS.
Message — The association opposes zeroing out allocations during one-year production gaps. They demand preserving the two-year rolling average to maintain regulatory symmetry.12
Why — This would prevent glass manufacturers from facing permanent permit losses during flexible production cycles.34
Impact — Regulators would lose a mechanism intended to prevent over-allocation when activities cease.5
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Response to Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials

25 Jun 2019

Glass Alliance Europe supports the development of a harmonised European food contact legislation for glass products and welcomes the announced impact assessment. However, the glass sector considers that essential elements are modified in this proposed legislation, i.e. the major changes introduced by the scope modification and the limit values. Therefore, a co-decision process would be more appropriate than an implementing act. As announced in the inception impact assessment document, the impact assessment should be proportionate. Glass Alliance Europe acknowledges this principle and considers that as glass would be introduced within the scope, with possible impact also to other applications than FCM, a full (not proportionate) in-depth impact assessment should be realized for the different glass sectors. Glass Alliance Europe wishes to underline that in most cases the migration levels from glass articles are so low that they do not endanger human health see e.g. the French Glass Federation analysis for different glass articles . This is particularly the case for soda-lime silicate glass, which is the type of glass commonly used to produce flat glass, see Glass for Europe study showing insignificant releases of metals from flat glass products . The impact assessment should also evaluate when systematic testing is required. Contrary to ceramics articles, glass articles are produced by shaping a homogeneous molten material. If one glass article complies with migration limit values, articles produced on the basis of the same composition specification in the same process will also comply. Moreover, as glass is essentially inert, most of the glass articles would be compliant with the new limit values, in particular in the case of industrial production (which is the case for most of the glass articles). Requesting systematic testing for all kinds of articles seems therefore unnecessary. The impact assessment should assess testing requirements on a pragmatic basis in order to ensure that the legislation does not consider compulsory systematic testing. Glass Alliance Europe calls for considering the different glass applications within a full (not proportionate) impact assessment: - To adapt testing methods to glass products in order to reflect ‘real-life’ use scenarios and - to link limit values to testing methods. See also appended full position paper and related supporting documents
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Response to Bisphenol A in varnishes and coatings and plastics intended to come into contact with food

18 Sept 2017

For an adequate application of this regulation , it must be clarified that it applied only on FCM in direct contact , as it is already the case in France. Law No. 2010-729 of 30 June 2010, as amended by Law No. 2012-1442 of 24 December 2012, suspends the manufacture of [*] imports, exports [*] and placing on the market free of charge or of any packaging, container or utensil comprising bisphenol A and intended to come into direct contact with all foodstuffs from 1 January 2015. This is further explained on the website : https://www.economie.gouv.fr/dgccrf/mise-en-oeuvre-loi-bisphenol-a-bpa : In the wording of section 2 of the Act, the use of the terms "direct contact" excludes from its application: • materials used behind a chemical migration barrier material such as varnishes or printing inks deposited on the outer part of metal or glass containers such as metal cans for beverages or metal cans and glass jars for preserves . • so-called secondary packagings (packagings for combining consumer sales units) or tertiary packaging (transport, logistics). Also in the German draft (2016) Twenty-First Ordinance amending the Consumer Goods Ordinance (Bedarfsgegenständeverordnung)*), Article 4(10) excludes from the ruling those printed food contact materials and articles with regard to which a transfer of substances from the printing ink onto the food is ruled out. Examples for such food contact materials and articles include glass bottles or metal cans on which the printed labels or similar material are printed on the side that is turned away from the food. Based on their nature and their mode of handling, it can be assumed with regard to such food contact materials and articles that no transfer can take place from the constituent parts of the printing inks onto the food.
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Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review