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Henkel AG & Co. KGaA

Henkel

Henkel is a global consumer goods and industrial company with leading positions in adhesives, laundry care, and hair care products.

Lobbying Activity

Meeting with Gabriele Bischoff (Member of the European Parliament) and MARKENVERBAND

19 Nov 2025 · Austausch

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

18 Nov 2025 · Single Market Strategy

Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and

6 Nov 2025 · Challenges and needs across the value chain for advancing safer and more sustainable chemistry

Henkel calls for harmonized EU waste and producer rules

5 Nov 2025
Topic — A legislative initiative to promote sustainable production and circular business models.
Message — Henkel wants to harmonize producer responsibility schemes and create a digital reporting register. They propose a single market for waste to improve the availability of recycled materials. Finally, they suggest tax breaks and subsidies to encourage the use of sustainable products.123
Why — Standardization would lower administrative costs and secure access to necessary recycled feedstock.45
Impact — National governments would lose the ability to operate state-run producer responsibility organizations.6
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Meeting with Alexandra Hild (Cabinet of Commissioner Ekaterina Zaharieva), Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva) and

9 Oct 2025 · Startup and Scaleup Strategy; Scaleup Europe Fund

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

3 Oct 2025 · To discuss the upcoming environmental Omnibus

Henkel urges acceptance of mass balance for recycled materials

18 Aug 2025
Topic — The initiative establishes EU rules for calculating recycled content in plastic bottles.
Message — Henkel calls for policies that accept credible mass balance approaches for sustainable materials. They advocate using a complete life cycle approach to compare different recycling technologies.12
Why — Adopting these standards helps the company turn waste into valuable circular resources.3
Impact — Companies producing fuel from plastic lose out as their processes are exempted.4
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

16 May 2025 · Discussion on the sustainability and the chemicals industry.

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

16 May 2025 · to follow

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

16 Apr 2025 · REACH, CLP

Meeting with Verena Mertens (Member of the European Parliament)

2 Apr 2025 · Women in politics

Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur) and European Tyre & Rubber Manufacturers' Association and Continental AG

20 Nov 2024 · Altfahrzeuge-Verordnung

Meeting with Svenja Hahn (Member of the European Parliament)

22 Oct 2024 · Upcoming legislation for the Single Market

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Meeting with Peter Liese (Member of the European Parliament)

6 Nov 2023 · Austausch

Meeting with Jens Geier (Member of the European Parliament)

3 Nov 2023 · Regulation on packaging and waste

Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur)

8 Sept 2023 · Detergents Regulation

Henkel Urges Design Freedom and Clearer Packaging Rules

6 Apr 2023
Topic — The EU is reviewing packaging requirements to improve recycling and reduce waste.
Message — Henkel requests clear technical definitions and exemptions for industrial pallet wrapping. They also advocate for chemical recycling and mass balance methods.12
Why — This would provide investment security while protecting the company's brand identity.34
Impact — Environmental advocates may lose out if industrial sectors are exempt from reuse requirements.5
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Veolia Environnement and

21 Mar 2023 · Packaging Waste

Henkel warns against EU deviating from global chemical standards

18 Oct 2022
Topic — The European Commission is revising chemical regulations to introduce several new hazard classes.
Message — Henkel requests that the EU align with global standards to prevent international disharmonization. They argue that transition periods should only start after adequate guidance is available. Additionally, industry experts should participate in drafting these guidelines to share practical experience.123
Why — This would avoid regulatory uncertainty and allow sufficient time for complex label and formula changes.45
Impact — Environmental groups lose timely protections if the EU delays introducing hazard classes for endocrine disruptors.6
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Henkel urges maximum harmonization of EU due diligence rules

20 May 2022
Topic — A proposal to improve corporate governance by requiring companies to identify and mitigate sustainability risks.
Message — Henkel supports a maximum harmonization approach to both due diligence obligations and enforcement rules. They call on lawmakers that due diligence should be risk-based and focus on potential harm. Civil liability should exclude third parties and be limited to a company's own activities.123
Why — This would provide legal certainty and prevent costly litigation regarding the actions of external suppliers.45
Impact — Victims of human rights abuses by suppliers would lose legal recourse against the parent company.6
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Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

29 Oct 2021

Henkel welcomes the opportunity to comment on the initial IIA for a revision of the Cosmetics Regulation. Our beauty care division with iconic brands such as Schwarzkopf Professional, Syoss or Fa represents over 100 years of experience in product innovation and safe use of cosmetics by consumers and hair care professionals. Extension of a generic risk approach: We underline that the EU Cosmetics Regulation and related standards should be recognized as the best-in-class legislation globally. It represents the highest standard of consumer safety based on a strict science-based and specific risk assessment approach demonstrating a safe use of any cosmetic. Our products are safe and considerations to establish a Generic Risk Assessment (GRA) must not supersede this demonstrated safe use. GRA based on hazard classes should only be applied if a safe use cannot be demonstrated and thus poses an unacceptable risk. Application of GRA without a workable risk-based derogation mechanism would lead to an unjustified loss of safe and essential ingredients, including natural, plant-based substances or preservatives. OSOA / SCCS: Henkel supports a more streamlined approach to safety assessments. We share the viewpoint that effectiveness, efficiency, and coherence in substance management need improvement. A point of departure could be a common pool of hazard data per substance leading to the identification of a starting point for a more detailed and sector specific risk assessment. In that respect, we believe that the well-established role of the SCCS should not change, but rather evolve into a broader center of excellence for methods of risk management assessment. Reviewing the definition of nanomaterial to ensure coherent terminology across chemicals legislation: Henkel supports the ambition to review the definition of nanomaterials to align legislative incoherence and to establish a common legislative terminology. Such an alignment would particularly help competent authorities to establish a shared understanding of the topic and support a smooth functioning of the Single Market. If a horizontal definition is subsequently to be applied across different industry sectors, we call for a targeted and sector-specific transposition for particular cosmetic-specific uses. On a case-by-case basis, uses that would require specific provisions should then be identified. Not all cosmetic uses of nanomaterials need additional provisions in the cosmetics regulation when considering consumer safety, e.g., when applied in rinse-off cleaning products or if bioavailability can be ruled out. None of the many studies available for nano sized ZnO or TiO2 particles gave any evidence that the test materials were able to cross the skin barrier in intact or compromised skin (SCCS/1489/12, SCCS/1516/13 SCCS/1580/16). Mainly based on the missing bioavailability it was concluded that the use of ZnO and TiO2 nanoparticles can be considered not to pose a risk of adverse effects in humans after dermal application. Product-label information: The way consumers inform themselves about products have transformed as well as purchasing of products. Habits are changing at fast speed through constantly growing communication means. Online platforms and data-based technologies offer direct access to brands and product information such as formulations, ingredients or recommended uses. We underline that all current on-pack product labelling requirements are based on decisions taken over 25 years ago. They are outdated and cannot represent the multiple ways, consumers inform themselves today. Thus we support the consideration of digital labelling opportunities together with a simplification of labelling requirements. We invite the EU Commission to assess also digital information to enforcement authorities as an optional compliance tool. Avoiding new labelling requirements not related to uses and thus meaningless to end-users should be a guiding principle in that assessment.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

13 Oct 2021 · Chemicals Strategy and Henkel’s contributions to the Green Deal Agenda particularly on the Circular Economy challenges

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

Henkel welcomes the Commission’s commitment to ensure that the regulatory framework for chemicals reflects the objective to better combine health and environmental protection with increased global competitiveness and a strengthened internal market. However, an open discussion based on a holistic understanding of potential impacts on how this can be best achieved is needed before proposing legislative changes. The EU’s regulatory framework for chemicals accounts for the world’s highest level of protection of human and environmental health today, while providing planning security and openness for innovation. A shift to a primarily hazard-based approach to chemicals regulation would result in significant additional burden for companies while health and environmental benefits remain largely unclear. Furthermore, it is crucial to ensure a coherent policy framework and alignment between the strategies and measures of the Green Deal and the Chemicals Strategy in line with the Better Regulation principle. If CLP is to be revised, its alignment with the UN Globally Harmonized System (UN GHS) must be maintained. Unilateral deviations by implementing a large number of additional hazard classifications should be avoided. Furthermore, the intention to extend the generic approach to risk management from CMR substances to a general approach for managing substances of concern, as put forward in the CSS, is in clear contradiction to the explicit exclusion of risk management decisions without risk assessment enshrined in the UN GHS. Furthermore, where use and disposal of a product are clearly pre-determined and the product is assessed as safe for its intended use by regulation, additional labelling requirements would not bring added value. This is especially relevant in the case of cosmetics, which are labelled with targeted and relevant use instructions and warnings to ensure safe consumer use according to the respective sectoral legislation. To adequately address endocrine disruption, it is paramount to ensure maximum harmonization in line with the WHO definition and consistent with existing EU legislation such as the BPR. Identification of substances of concern should not be mixed with hazard classification. Therefore, the definition and identification of endocrine disrupting chemicals should be regulated in the context of REACH, not under CLP. From a toxicological perspective, an endocrine effect is a mode of action and not a stand-alone endpoint. While adverse effects triggered by EDCs (e.g. carcinogenic effects) are covered by CLP hazard classes today, additional hazard classes would lead to double classification. Additionally, the EDC definition currently discussed at CARACAL in our view is not mature enough to support an adequate and targeted provision in accordance with the timeline envisaged in the Chemicals Strategy. Considerations of a category for “suspected” endocrine disruptors based on in vitro data only is not in line with the latest scientific evidence. We welcome considerations to allow for multilingual fold-out labels and introduce tailored labelling rules in line with the UN GHS. Furthermore, the work of the respective UN GHS Working Group on how to leverage the potential of digital labelling to improve communication of ingredients, safe use, and sustainability of a chemical product should be supported. This would contribute to empowering consumers to make better informed purchasing decisions and further support packaging reduction efforts in line with the Circular Economy Action Plan. Clarifying the role of duty holders for poison center notifications and submission by distributors through an only representative within the scope of the planned CLP revision is welcomed as it could further improve flexibility to comply with notification requirements for imported goods. Please find attached our detailed position.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

Henkel welcomes the Commission’s commitment to ensure that the regulatory framework for chemicals reflects the objective to better combine health and environmental protection with increased global competitiveness and a strengthened internal market. However, an open discussion based on a holistic understanding of potential impacts on how this can be best achieved is needed before proposing legislative changes. The EU’s regulatory framework for chemicals accounts for the world’s highest level of protection of human and environmental health today, while providing planning security and openness for innovation. A shift to a primarily hazard-based approach to chemicals regulation would result in significant additional burden for companies while health and environmental benefits remain largely unclear. Furthermore, it is crucial to ensure a coherent policy framework and alignment between the strategies and measures of the Green Deal and the Chemicals Strategy in line with the Better Regulation principle. If REACH is to be revised, information requirements must remain balanced and take into account the impact on animal welfare. Additional provisions should be based on a tiered approach where substance-related requirements are determined by available information and depending on properties, uses, exposure scenarios and quantities. Considerations to impose a registration provision for certain polymers of concern must be focused on a pragmatic and balanced concept based on valid scientific criteria. Thus, polymers of low concern must be exempt. Furthermore, proportionality of requirements regarding “hazards of concern” and use of assessments for individual substances after registration should be maintained. To address endocrine disruption, it is paramount to ensure maximum harmonization across legislation. An endocrine effect is a mode of action and not a stand-alone endpoint. Additional provisions should be limited to individual substances in the event of a justified suspicion of endocrine effects, based on available use and exposure information. Regarding the potential introduction of a Mixture Assessment Factor (MAF), existing assessment factors for individual substances such as DNEL or PNEC extensively cover potential mixture uncertainties today. If additional factors are to be introduced, concepts from which substance-(group-)specific extrapolation factors can be derived as part of a risk assessment are needed. A generic MAF is unscientific and would disproportionally ban long-standing substances that are safe for their intended use. If implementing a hazard-based generic approach to risk management as proposed in the Chemicals Strategy, benefits, risks, and safe use conditions must be taken into account. Both for the considered restriction of PBT substances and those with other critical hazard properties (e.g. immunotoxicity), the established restriction procedure can be applied today. Finally, while the added value remains largely unclear, the concept of “essential use”, if implemented, should be designed to facilitate case-by-case decisions about derogations from the restriction procedure, based on well-defined scientific criteria and limited to where hazardous substances present an unacceptable risk that cannot be addressed by other risk management options. Please find attached our detailed position.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Response to Revision of EU rules on food contact materials

22 Jan 2021

Henkel’s feedback on the inception impact assessment on the initiative ‘Revision of EU rules on food contact materials (FCM)’ The Framework Regulation (EC) No 1935/2004 sets basic rules for the manufacturing, preparation, storage, transport and distribution of all food contact materials in Europe. This legislation is used as an important reference, not only in Europe, but also in other regions. As an international company, Henkel fully supports the approach of harmonized EU rules instead of numerous national legislations, which lead to high administrative workload to ensure full compliance in each country, not least because most of the national legislations are not officially available in English translations. The most prominent article of the Framework Regulation, article 3, intends to protect human health of all EU citizens. Therefore, Henkel supports solving the existing issues by choosing the proposed option 1 of the inception impact assessment. In our opinion, it is crucial to keep the current Framework Regulation in place as a cornerstone and to develop additional guidance documents in order to clearly define how to apply article 3 of this legislation at the different stages of the supply chain. As already exemplary implemented in the guidance documents on Regulation (EU) No 10/2011, we believe that it is extremely helpful for the different industry sectors to explain in a guidance, valid for all FCMs, how to carry out the risk assessment and how to communicate the result of this work within the supply chain. A standardized template for a harmonized DoC, adapted to the respective stage of the supply chain, would help all members of the value chain to collect the necessary information from their suppliers. It would also support SMEs to properly fulfill their role within the supply chain. In addition to a guidance document on information in the supply chain, we also believe that a general document on migration testing would be very helpful for the compliance work of the different industries. The current lack of clear advice on migration testing for non-plastic FCM makes it difficult for stakeholders to establish reliable test procedures. Furthermore, comparability of tests performed by different stakeholders under different conditions can be challenging at the moment. Regarding the idea to collect all information fully digitalized in one system, Henkel wants to point out that clear rules must be established to ensure a reliable platform for the data transfer and also for the access to this detailed information. The technological progress of each individual company needs to be protected in the best way possible in order to invite all industry sectors to develop innovative solutions for safer and more sustainable products and to contribute to the recyclability of all materials, so that the targets of the EU Green Deal can be reached. Regarding the recycling of plastic materials intended to come in contact with food, we would recommend considering all forms of chemical recycling as an option to contribute to the EU Green Deal. To permit the use of more sustainable products for food contact applications, Henkel welcomes the implementation of rules for the safe use of plant or bio-based materials.
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Response to Empowering the consumer for the green transition

31 Aug 2020

Henkel puts the consumer at the heart of its business and thus supports the European Commission’s ambition to establish a sustainable product policy framework. With more than 185 production sites worldwide and around 20 billion Euros in sales in 2019, Henkel is leading globally in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions. Europe is a key region for Henkel, with over 50 production sites and about 20,000 employees generating roughly half of global sales. Our consumer products are used in millions of households every day. Up to 90 percent of the environmental footprint of our products is generated during their use. Therefore, we are aiming at enabling our customers and consumers to save 50 million metric tons of CO2 over a five-year period up to 2020. With our various ongoing product initiatives launched in 2016, a substantial reduction of about 44 million metric tons has already been achieved until 2019. Easy-to-understand and reliable information on a product’s sustainability characteristics are important to enhance the trust of the consumer. As harmonized criteria are key, Henkel is supporting option 1 of the Commission’s Roadmap proposal, to amend existing consumer protection legislation where necessary. However, it is important to consider that well-functioning sector legislation already exists. In specific, Henkel calls on policy makers to: - Go beyond labelling to establish a sustainable consumer agenda - Establish and enforce a harmonized sectorial framework - Engage in a trusted cooperation with key partners to deliver on the New Consumer Agenda - Apply a flexible approach towards the application of the PEF method - Leverage digital means to make product information more actionable Please find our detailed contribution in the attached document.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

Henkel fully supports the European Commission’s ambition for a transition towards a more sustainable and circular economic system in packaging. Thus, we are welcoming the review of the Packaging and Packaging Waste Directive in order to fully realize the potential of a Circular Economy, notably through addressing the supply gap of high-quality secondary raw materials and increasing the competitiveness of recycled and bio-based materials for packaging. Furthermore, targeted improvements to the regulatory framework need to be addressed. To make a Circular Economy a reality in the EU and support European industry in their effort to further develop and implement sustainable technologies and business models, a conceptual change from treating post-consumer waste in an environmental friendly way to a value-chain thinking is needed. Recycling becomes sourcing and shifts value to the beginning of the packaging value chain, enabling true circularity of materials. Henkel specifically calls on policy makers to: 1. Create a functioning Single Market for secondary raw materials and packaging; 2. Shape and fine-tune the regulatory framework; 3. Promote technological progress to improve recyclability and sortability of packaging; 4. Leverage digital means to facilitate the recyclability of products and materials; 5. Create secure framework conditions for dangerous goods packaging. Please find attached our position paper including an elaboration on these five key demands.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Henkel welcomes the Commission’s commitment to work together with all stakeholders and combine better health and environmental protection with increased global competitiveness. Since early on, we are striving for and actively support the common and global efforts towards green growth, building on a regulatory framework that accounts for the world’s highest level of protection of human and environmental health in Europe. To contribute to protecting citizens and the environment against hazardous chemicals while increasing global competitiveness, it is crucial to support European industry in its continued efforts to ensure the safety of chemicals and incentivise sustainable innovation. In particular, we call on policy makers to: - build on and strengthen the established and functioning regulatory framework for chemicals - promote the Innovation principle as a key element linking substitution to innovation - engage in a trusted cooperation with key partners to deliver on the Green Deal and - ensure coherence with other Green Deal initiatives This needs to be reflected in the new “chemicals strategy for sustainability”, in order to help fostering innovation, strengthen the competitive edge of European industry and create more resilient supply and value chains while respecting the planetary boundaries we are living and operating in. Please find our detailed position attached.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

16 Jun 2020 · Digital

Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

6 May 2020 · Circular Economy, Green Deal

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

17 Mar 2020 · Digital affairs - Digital consumer information and Industry 4.0

Response to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market

4 Mar 2020

Henkel welcomes the announcement of the European Commission to present an integrated initiative for increasing the coherence of EU policies and voluntary principles to help better implementing actions tackling global deforestation and forest degradation in a holistic way. We believe that future legislation should offer greater support for existing initiatives having a direct positive impact on the environment while promoting inclusive economic and social development to tackle major secondary drivers of deforestation on the ground. Stronger partnerships and collaboration between the European Union, member states and producer countries set the right framework to promote sustainable forest management and sustainable agricultural practices. Please find our detailed feedback in the attached document.
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Response to Climate Law

4 Feb 2020

Henkel implements already today a long-term vision of becoming climate-positive and thus, making an active and committed contribution to climate protection. In this context, we are fully supportive of the United Nations’ Paris Agreement on climate change. In order to stop global emissions from increasing further and to make sure emissions are reduced by the required amount, it is crucial to: 1. Increase efficiency: save energy and raw materials; 2. Decarbonize: replace CO2 in energy and raw materials; 3. Use CO2 as a resource: convert CO2 into raw materials. Henkel addresses all three areas. This starts with a strong focus on the production sites, where the goal is to reduce our carbon footprint by 75 percent by 2030. We want to continuously improve our energy efficiency while also drawing 100 percent of the electricity we use from renewable sources. From 2030 onwards, we want to replace the last remaining fossil fuels used in our production with climate-neutral alternatives such as biogas or gas obtained from converting CO2. We also aim to supply surplus carbon-free energy that Henkel does not need for its own purposes to third parties. In doing so, we will avoid emissions from our own activities and enable third parties to avoid potential emissions by using clean energy. Alongside this, we are sharing our commitment to becoming climate-positive with our partners and suppliers. We expect them to set efficiency targets that are as ambitious as our own – and contribute to the reduction of CO2 along the entire value chain. Lifecycle analysis shows that most of the carbon footprint associated with a product is generated when it is used. This is particularly important for Henkel, because our products are used millions of times in households and industrial processes every single day and all around the world. For this reason, we have set ourselves the target of enabling our customers and consumers to save 50 million tons of CO2 by 2020 when using our products. This is thanks to constant development of innovative products and technologies that empower our customers and consumers to cut their carbon footprint. In this context, one example is Henkel’s “BeSmarter” initiative that puts a focus on water as an important resource in personal care habits. We want to create consumer awareness about the responsible use of water. Using less hot water also results in less CO2 emissions. Other examples in this respect are specific Henkel Adhesive Technologies solutions enabling carmakers to use less steel and more aluminum. Lighter car bodies help to increase the fuel efficiency and thus reduce the CO2 emissions of a car.
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Response to A new Circular Economy Action Plan

20 Jan 2020

Henkel welcomes the opportunity to comment before the publication of the “New Circular Economy Action Plan”. Please find our position paper attached.
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Response to Commission Regulation amending Annex XIV to REACH

15 May 2019

Henkel AG & Co. KGaA is the global leader in adhesive technologies, coatings and sealants. We use ADCA as a blowing agent for insulation and acoustic purposes as well as corrosion protection or stiffening a vehicle’s body as part of a manufacturing process for our customers in the automotive industry. We would like to take this opportunity to highlight our concerns regarding the inclusion of ADCA in the proposal to amend Annex XIV of Regulation 1907/2006 and a potential subsequent listing in the respective annex. With 4 Henkel sites (125 employees) and 18 sites of service partners (275 employees) handling ADCA, we predict a direct impact on over 600 formulations (150 in Europe) containing ADCA. Such a regulatory step would significantly impact our business and customer relations as a whole value chain would end up in the authorisation scheme under REACH and not a single producer of a substance. However, the actual exposure scenario at workers’ level represents one singular step of the value chain in the industrial manufacturing process. We share the view of several other industry associations that the Annex XIV listing for ADCA is a disproportionate risk management option. Moreover, we question whether ADCA should be listed as an SVHC at all, as it cannot be considered to meet the criteria of provoking ‘equivalent concerns’ to those elicited by CMR. We therefore support calls for an evaluation and a critical review of the initial ECHA recommendation as new data on uses and exposure is available and should be taken into account when assessing a potential respiratory hazard. This is particularly relevant as the data analysed for the actual listing proposal is outdated, cannot be reproduced and lacks statistic relevance. Appropriate safety measures are in place for workers handling ADCA on our sites. We are happy to report that for more than 35 years, regular medical examinations of our workers’ health did not report any anomaly regarding respiratory impairments or long-term illness due to exposure to ADCA in the manufacturing process. Therefore, we doubt that an inclusion of the substance in Annex XIV would deliver any additional health effect on site in terms of health protection for our workers and to our knowledge there is no evidence for large-scale respiratory illnesses among workers exposed to ADCA across Europe. As a key driver of market development in the sector, Henkel investigates alternatives or substitutes for our applied technologies. In the past, Henkel assessed systematically potential technical alternatives to ADCA (endothermic and exothermic). Through in-house research and laboratory testing series, all assessed chemical alternative compounds proved to be out of scope for the intended applications due to inter alia cancerogenic properties, toxicity, explosive hazards, formaldehyde release or corrosive risks. We can confidentially state that to our knowledge, no valid alternative to ADCA currently exists despite various marketing claims. Hence today and in the foreseeable future, a substitution is impossible without compromising on health, safety of use or product performance. With all uses of ADCA being at an industrial level, we believe that alternative policy measures should be considered to boost ongoing efforts to further minimize exposure in the workplace: To conclude we call for: • The European Commission and the Reach Committee to exclude ADCA from the proposed list of substances for inclusion in Annex XIV of REACH • The European Commission to put in place the necessary steps to establish suitable alternative measures to further ensure that worker exposure is further minimized and controlled at European level.
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Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová) and SC Johnson

8 Feb 2019 · French national legislation regulating sales and the dual quality

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

19 Apr 2018 · 3-D printing technology

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas)

12 Dec 2017 · Key Enabling Technologies

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

3 Feb 2017 · new eco-design requirements for electronic displays

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

2 Feb 2017 · Ecodesign

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

2 Feb 2017 · New eco-design requirements for electronic displays

Response to Criteria to identify endocrine disruptors for biocidal products

27 Jul 2016

Henkel acknowledges the Commission’s proposal on scientific criteria for the determination of chemicals with endocrine disruption properties. We welcome the inclusion of the WHO definition and a “weight of evidence” approach as a basis for decision making in the course of the substance assessment. These are basic requirements to determine the relevance of endocrine activity of a substance for a particular endpoint. We support the Commission in its consideration that establishing different categories of what may be an endocrine disruptor does not help to define what is an endocrine disruptor. And we share the view that such categorization for biocides would decrease legal certainty for regulators and stakeholders, without benefits in terms of protection of health and the environment. However, in their present form, the criteria proposed by the European Commission are not suitable for distinguishing between substances that can be used safely and substances in need of regulation. We are thus of the opinion that an adequate proposal for determination of ED properties should also consider the following points: 1. Potency and severity of effects: To clearly distinguish between those substances which are of high regulatory concern and those which are not, potency, severity, lead toxicity, and (ir)reversibility should also be included in the final criteria. The scientific consensus in Berlin confirmed that these elements belong to the hazard characterisation and not to the risk assessment. 2. The results of the Impact Assessment need to be taken into account more consequently: The Commission confirmed that all four options examined in the impact assessment offer the same high level of protection to human health regarding EDs under the current BP Regulations because they are all based on the WHO definition and because the Regulations are based on a prior approval system and on a highly comprehensive set of data requirements. Under the BP Regulations no active substance – whether is mode of action is known or not – would be authorized in the EU if an unacceptable risk of causing adverse effects to human health or the environment is identified. Option 4 ranks consistently as the best option in the analysis along the dimensions of effectiveness, coherence, and efficiency, looking specifically at economic, social and environmental aspects. Hence, it is incomprehensible that the Commission did not propose Option 4, including well-established principles of risk characterisation and essential factors like potency and severity of effects. The proposed set of criteria (Option 2) do not bring any advantages in terms of environmental and consumer protection, while there are negative impacts on trade and economy. 3. We are aware that “the issue faced by the Commission in this exercise is to establish criteria to determine what is or is not an endocrine disruptor – not to decide how to regulate these substances” (Communication to the EP and the Council). However, regulation is in place already, and the setting out of scientific criteria for the determination of EDs cannot ignore the already established legal consequences of those criteria. Especially, as identification of a substance as an ED is an exclusion criteria under the biocides regulation, excluding those substances from any further risk assessment (with the exemption of negligible risk, i.e. use in closed systems, which is in practice not applicable to the majority of biocidal uses). Therefore, as for ED substances no risk assessment can take place in the normal active substance approval process (as they are excluded per se), the determination of ED properties must include the assessment of relevance to human health and the environment of ED properties.
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Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and BASF SE and

12 Feb 2015 · Digital Single Market, Innovation