Industrievereinigung Chemiefaser e. V.
IVC
Als bundesweiter Verband der bedeutenden und innovativen Chemiefaserhersteller in Deutschland, Österreich und der Schweiz engagiert sich die Industrievereinigung Chemiefaser e.V.
ID: 49913771894-86
Lobbying Activity
Response to Circular Economy Act
2 Oct 2025
Cost-covering collection and sorting must be established in the countries. The sorted materials must meet the requirements of the users. If materials are of inferior quality or do not meet the requirements, they must be sent for chemical recycling. The raw materials obtained must be of the same quality and cost as petroleum-based raw materials.
Read full responseResponse to Streamlining EU scientific and technical work on chemicals through the EU agencies
12 Apr 2022
IVC begrüßt den Schritt in Richtung "Eine Substanz - eine Bewertung" und unterstützt eine enge Zusammenarbeit zwischen EU-Agenturen und wissenschaftlichen Einrichtungen. Ein zweckmäßiger "Ein Stoff - eine Bewertung"-Ansatz sollte zu folgenden Ergebnissen führen.
- Erhöhte Effizienz und Vorhersehbarkeit;
- Verbesserte Konsistenz der Bewertungen und ihrer Ergebnisse unter Verwendung desselben Datensatzes;
- Verbesserte Robustheit der Bewertungen;
- Einbindung des richtigen Fachwissens am richtigen Ort zur richtigen Zeit;
- Bereitstellung von maßgeschneiderten Bewertungen im Rahmen spezifischer Rechtsvorschriften, sofern relevant;
- Optimale Nutzung der Ressourcen.
Um dieses Ziel zu erreichen, sind Maßnahmen auf mehreren Ebenen erforderlich, darunter:
- Enge Koordinierung der Bewertungen zwischen den verschiedenen vorgelagerten Generaldirektionen, wissenschaftlichen Ausschüssen (einschließlich wissenschaftlicher Gremien) und Agenturen auf europäischer Ebene; dies schließt eine stärkere Koordinierung der Regulierungsinitiativen der Mitgliedstaaten ein;
- Gemeinsame Nutzung von Daten durch Ausschüsse und Agenturen;
- Anwendung einer einheitlichen Gefahrenbewertung;
- Zentralisierung der Instrumente und Methoden zur Expositionsbewertung auf einer gemeinsamen Plattform;
- Sicherstellung eines maßgeschneiderten Risikomanagements;
- Erhöhung der Transparenz von Entscheidungen und Prozessen.
Als IVC sind wir der Meinung, dass sowohl die Industrie als auch die Regulierungsbehörden von dem Ansatz "ein Stoff, eine Bewertung" profitieren werden, wenn er gut umgesetzt wird. Die Klarheit des Prozesses wird die Vorhersehbarkeit erhöhen und zur Rationalisierung der Ressourcen auf beiden Seiten beitragen.
Wir unterstützen das von Cefic für diese Konsultation vorgelegte Positionspapier.
Read full responseResponse to Measures to reduce microplastic pollution
18 Jan 2022
Industrievereinigung Chemiefaser e.V. (IVC) as the Association of the German, Austrian and Swiss Man-Made Fibres Industries supports the idea by the European Commission to evaluate measures to reduce the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets.
We also support and have contributed to the detailed VCI position paper attached and provide here the short summary of the most important key points of the VCI position to comply the required number of characters.
General:
- We support the idea by the European Commission to evaluate measures to reduce the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets.
- An EU comprehensive approach dealing with the issue of microplastics (intentionally/unintentionally) would be welcome, especially to enable a continuous exchange between the concerned stakeholders. For example, the still ongoing restriction process regarding intentionally added microplastics shows that there is a great need for knowledge exchange.
- We support research activities on this topic by the industry and by government-funded projects. In this context we also like to highlight the activities of CEFIC LRI.
- A compilation of the generally available information could make it even easier for the end user to make a more informed decision.
- We welcome harmonised measures across Europe that give the industry more planning and legal certainty in the way their products are marketed, instead of national regulatory peculiarities.
Textiles:
- Policies should distinguish between clothing produced in the EU and clothing imported from third countries and consumed in the EU as well as between clothing and other kinds of textiles (home textiles, technical textiles).
- The man-made fibres industry has progressed considerable towards a global standardised method to assess material loss from fabrics and by improving manufacturing processes.
- Five associations – AISE, CIRFS, EOG, EURATEX and FESI – agree to support finding effective and economically feasible solutions for the prevention of microplastic release into the aquatic environment during the washing of synthetic textiles under the Cross Industry Agreement (CIA).
- Studies have shown that a large proportion of synthetic fibres emitted from textiles can be removed from the water by treatment in wastewater treatment plants. However, in this case, the sludge must be incinerated / energetically recovered and not used for agriculture.
Plastic pellets:
- Plastic processing is carried out in industrial plants which are already subject to strict regulatory requirements and controls at national and local levels.
- As an important raw material, the release of plastic granules into the environment should be avoided by already practiced careful handling of plastic granules.
- The Operation Clean Sweep® (OCS) programme aims at preventing and reducing the losses of plastic granules or pellets along the entire pellet-handling value chain (production, transportation, processing and recycling).
- It is essential to ensure that intended measures are feasible/practicable for small and medium-sized companies and consider the ongoing industry-led activities for reporting and auditing as well as ECHA’s regulation on the restriction of intentionally added microplastics.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
IVC and CIRFS welcomes the Commission’s initiative to prepare a Communication on a Policy Framework for BBPs and BDCPs.
Given the increasing relevance of biobased plastics (BBP) and biodegradable and compostable plastics (BDCP), the development of standards and criteria concerning sourcing, labelling and use of BBP and BDCP, as well as the definition of terms like 'biobased content' and others, is needed.
Considering the potential ecological and economic impacts of the framework, the scope of the corresponding EU Policy Framework should be set clearly and carefully. Besides the two obvious key questions regarding the terms 'biobased' and 'biodegradable', the definition of the term 'plastics' will be crucial. Concerning the latter, we suggest considering and revising the interpretation in the guidelines for the Single-Use Plastics Directive (SUPD).
In the SUPD [1], the term 'not chemically modified', as defined in the REACH regulation [2], is used for the definition of the scope of the directive. The SUPD guidelines [3] interpret 'not chemically modified' as follows: "the decision whether a polymer has been chemically modified in its production or not should take into account only the difference between the ingoing and the resulting polymer, disregarding any modifications which might have taken place during production processes [...]".
As the objective of the SUPD is to minimize the environmental impact of single-use products, the biodegradability of a material should at least be introduced as a co-criterion. Without its inclusion, biodegradable products made of marginally chemically modified polymers or containing minute amounts of modified polymers, would be classified as plastic and thus be affected by the SUPD and the upcoming policy framework. Furthermore, a threshold in the sense of a de minimis rule for ‘not chemically modified’ polymers should be introduced. A material consisting of a natural ‘not chemically modified’ polymer, by e.g. more than 99%, should not be considered as plastic. In particular, if the material meets all requirements concerning biodegradability in the respective terrestrial or marine environment, the classification of such a product as plastic would not be in line with the SUPD’s objective. Otherwise, products such as bleached cotton or toilet paper, which are containing traces of chemically modified polymers, would also be classified as chemically modified and thus as plastic, although they have been proven environmentally sound.
Appropriate requirements and definitions for biodegradability are particularly important in this context. Biodegradability should not be defined in such a way that even a large proportion of natural organic materials (e.g. wool, wood, nutshells, seeds) cannot meet the requirements. Such a restrictive approach will exclude a wide range of potential innovative material solutions and development directions from the beginning. Practically this means, that a man-made material that takes 120 days to degrade by more than 90% in a biodegradation test in the determining environmental compartment is still a very good alternative to materials that take 120 weeks, months or even years.
In order to avoid confusion and to ensure a proper framework development process, the question concerning the definition of the term 'plastics' and its interpretation as well as appropriate requirements and definitions for biodegradability should be addressed at an early stage of discussions. As the most coherent approach would be to follow the SUPD, the associated guidelines should first undergo a corresponding revision earlier than planned in 2027, in order to align the definitions with the directive’s objective.
Finally, we want to emphasize that the biodegradability is a decisive environmental property. Only when the aforementioned crucial fundamentals are clarified, then one can proceed successfully on the development of a policy framework on BBP and BDCP.
Read full response4 Feb 2019
Industrievereinigung Chemiefaser e.V. (IVC) welcomes this public consultation under the Better Regulation initiative. IVC is the representative of major man-made fibres manufacturers in Germany, Austria and Switzerland.
For our industry titanium dioxide is the essential pigment and is used as one of the most important delustering agent additives in man-made fibre production. Different amounts of TiO2 are used to gain various characteristics on synthetic fibres in industrial applications. Titanium dioxide is embedded in the polymer matrix and thus not freely available.
The proposal for classification and labelling of titanium dioxide is inappropriate from the toxicological and epidemiological perspective. The criteria for classification are not met. Consequently titanium dioxide should not be included in the 14. ATP as it has been proposed by the Germany/the German authorities.
The hazard described for titanium dioxide (“general particle effects”) is not specific to the substance itself, but applies to all substances in powder form known as “Poorly Soluble particles with Low Toxicity” (PSLTs). Therefore, any decision taken on titanium dioxide sets a precedent for this entire group of substances.
Germany has made the alternative proposal to harmonise the different general dust limits which are currently applied in Europe. This approach addresses effectively and proportionately the potential effects of PSLT substances like titanium dioxide. In addition, such harmonisation would be a great step for European workers health and safety standards.
In contrast, the proposed classification of titanium dioxide under CLP would have no direct beneficial effect on the health and safety of workers. In addition, it is highly questionable if the CLP regulation legally allows a classification based on non-substance specific effects.
Also, a classification of titanium dioxide would have far-reaching and significant unwanted consequences: For example, every waste with a titanium dioxide content of 1% or more would have to be treated as "hazardous waste”. This would apply to a variety of waste streams, such as plastic waste, construction waste such as old window frames, wallpaper and paint residues, high quality papers, furniture, ceramics, medicines etc. For such waste streams a classification would drastically reduce the options for recycling and increase costs to the economy and consumers. Such classification would also have significant negative effects on food contact materials and toys for example.
Conclusion
A classification would not contribute to improving the protection of health and environment, while it would have serious and disproportionately problematic effects in almost all legal fields. Consequently it is essential not to include titanium dioxide in the 14. ATP. Instead, initially an overall concept should be developed for the safe handling of PSLT dust.
Moreover, a classification under the CLP Regulation would contravene the principle of proportionality enshrined in European law, as such a classification is neither suitable and necessary nor appropriate and thus uncalled for according to Article 37(5) of the CLP Regulation.
The alternative proposal to harmonise the different general dust limits currently applied in Europe gives the right answer to the issue at stake and would be a big step for European occupational safety standards. The proposed warning label for liquid and solid mixtures (in Annex II CLP regulation) is misleading, disproportionate and therefore also rejected.
For more information, please read the attached uploaded document.
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