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KGHM Polska Miedź Spółka Akcyjna

KGHM

KGHM is a major global producer of copper and silver with extensive mining and smelting operations.

Lobbying Activity

KGHM seeks six-year transition for mining sector carcinogen limits

15 Oct 2025
Topic — The EU is updating safety rules protecting workers from exposure to cancer-causing chemicals.
Message — KGHM requests a six-year transition period for mining sector exposure limits. Replacing their 1,200 diesel-powered machines is a costly and lengthy process.12
Why — A longer transition allows the company to spread out significant machinery replacement costs.3
Impact — Miners face continued exposure to harmful diesel exhaust fumes during the extended transition period.4
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Polish mining giant KGHM demands clear EU waste-to-product rules

14 Oct 2025
Topic — The consultation gathers views on the Circular Economy Act to promote sustainable production.
Message — KGHM calls for clear and harmonized end-of-waste criteria for metallurgical slags and dusts. They want these standards defined by EU regulation to ensure uniform and practical application.12
Why — Centralized rules would help the company reduce bureaucracy and bypass costly, time-consuming administrative procedures.34
Impact — Producers of primary resources lose market share as recycled slag reduces demand for natural aggregates.5
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KGHM warns against listing coal tar pitch as hazardous

11 Aug 2025
Topic — Consultation on amending the list of hazardous chemicals for import and export.
Message — KGHM opposes the inclusion of high temperature coal tar pitch in the regulation. They argue it is essential for copper smelting and lacks viable substitutes.123
Why — This ensures uninterrupted copper production and avoids higher costs from sourcing alternatives.45
Impact — EU green energy goals suffer if domestic copper supply for technologies is disrupted.67
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and International Copper Association Europe and

24 Jun 2025 · Implementation of Critical Raw Materials Act

Meeting with Léon Delvaux (Director Trade) and EUROMETAUX and

23 May 2025 · Discussion on the availability of copper scrap in the EU market

Meeting with Ditte Juul-Joergensen (Director-General Energy) and European Chemical Industry Council and

28 Jan 2025 · Competitiveness, Clean Industrial Deal and energy and their impact on European industry.

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and International Copper Association Europe and

16 Jan 2024 · Clean air

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič) and International Copper Association Europe and

16 Jan 2024 · Clean air

Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič) and EUROMETAUX and

7 Jul 2023 · Critical Raw Materials Act

KGHM urges protection for sensitive data in sustainability reports

5 Jul 2023
Topic — This consultation defines the specific standards companies must use for mandatory sustainability reporting.
Message — KGHM wants to keep double materiality to limit reporting to relevant information. They also demand protections for confidential business data and technological secrets. Finally, they seek clarity on reporting for joint ventures and uncertain financial forecasts.123
Why — This would protect their competitive edge and reduce the costs of information gathering.45
Impact — External parties lose the ability to assess a company's vulnerability to material shortages.6
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KGHM urges EU to include copper and mining in taxonomy

28 Apr 2023
Topic — This consultation defines sustainable activities for the EU’s green investment classification system.
Message — KGHM requests the inclusion of copper production and mining waste recovery in the taxonomy. They argue that remediation should be considered part of ongoing mining operations rather than a separate activity. They also seek exemptions for seasonal accommodation facilities from burdensome environmental management systems.123
Why — These changes would allow the company to access cheaper green financing for mining.4
Impact — Environmental groups and consumers may face risks from increased use of hazardous substances.5
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KGHM warns strict lead limits threaten industry survival

26 Apr 2023
Topic — EU consultation on updating workplace exposure limits for lead and inorganic compounds.
Message — The company requests longer transition periods of up to ten years for primary lead producers. They propose reaching 35 µg/dL within five years and 20 µg/dL within a decade.123
Why — Extended deadlines would prevent high investment costs and the cessation of local production.45
Impact — Reduced domestic lead supply would harm European raw material security and battery manufacturers.67
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Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur)

13 Apr 2022 · Critical Raw Materials, EU Industrial Policy, Green Deal

Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find attached the contribution of KGHM Polska Miedź S.A. to the public consultation on the revision of the EU ETS Directive.
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KGHM urges EU to align chemical rules with global standards

1 Jun 2021
Topic — Revision of EU rules on the classification, labelling, and packaging of chemicals.
Message — KGHM recommends that new hazard classes be established at the global level before modifying EU rules. They suggest addressing endocrine disruptors through existing legislation rather than creating new categories.12
Why — Alignment avoids unnecessary costs and administrative burdens from diverging international and EU regulations.3
Impact — Environmental groups lose the protection provided by automatic bans triggered by hazard classifications.4
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KGHM urges proportionate REACH rules to protect industrial innovation

1 Jun 2021
Topic — Revision of EU legislation on registration, evaluation, authorisation and restriction of hazardous chemicals.
Message — KGHM requests a proportionate approach for low-tonnage substances and the use of exposure-based data in risk assessments. They advocate for overhauling the authorisation system and fully considering recycling in life-cycle footprints.123
Why — This would reduce administrative burdens and prevent unnecessary costs for small-volume substances.45
Impact — Environmental and health groups lose the stricter protections provided by a hazard-based chemical ban.6
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Response to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025

4 Jan 2021

KGHM Polska Miedź S.A. would like to take the opportunity to submit the attached comments on the draft benchmarks. Thank you in advance for taking our input into consideration.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Please find attached KGHM Polska Miedź S.A. response to draft delegated regulation on sustainable finance - taxonomy.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Please find attached KGHM Polska Miedź S.A. comments on the Inception Impact Assessment on the Environmental and Energy State Aid Guidelines.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please find attached the position of KGHM Polska Miedź S.A. on the Inception Impact Assessment on the EU ETS.
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Polish mining giant KGHM demands support for stricter safety limits

25 Nov 2020
Topic — EU initiative to update occupational health and safety standards from 2021 to 2027.
Message — KGHM requests a moratorium on new safety limits and financial aid for technology upgrades. They also call for industry data to be prioritized in scientific reports.12
Why — This would lower compliance costs and avoid immediate million-dollar investments in new machinery.34
Impact — Workers could face higher cancer risks if limits on hazardous chemicals are delayed.5
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Response to Climate Law

1 May 2020

KGHM Polska Miedź S.A. welcomes the opportunity to provide its comments on the European Climate Law Regulation. We would like to highlight, among others, the following issues: - the need for carry out a proper and up-to-date impact assessment, - the need to improve the competitiveness of European industry and to maintain a level playing field at global level, - the inadequacy of the chosen legislative procedure (delegated acts) for establishing and adopting trajectory, - ensuring conditions for a fair transformation and availability of financing for necessary investments. Our more detailed comments can be found in the attached document.
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KGHM warns against including mining in industrial emissions rules

21 Apr 2020
Topic — The European Commission is revising environmental rules for industrial facilities across the EU.
Message — KGHM opposes adding mining, arguing extraction processes are too unique for standardized techniques. They also reject regulating greenhouse gas emissions to avoid double regulation and complex systems.12
Why — Excluding mining protects the company's competitiveness in global markets where costs cannot be passed on.3
Impact — Society could miss out on environmental improvements if mining is excluded from stricter regulations.4
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Response to 2030 Climate Target Plan

15 Apr 2020

KGHM Polska Miedź S.A. takes this opportunity to provide its initial comments of the 2030 Climate Target Plan Inception Impact Assessment (IIA). We recognize the Commission’s plans as described in the European Green Deal Communication. As regards the 2030 targets we strongly believe any decision must be taken on the basis of in-depth and thorough analysis. An impact assessment should carefully assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth and enhances economic competitiveness through accelerating innovation and developing Europe’s industry. It is crucial that in the transition to become climate neutral, the industry can maintain and even improve competitiveness. We will continue to provide further input on the Commission’s plans.
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KGHM warns Aarhus revision threatens green transition investments

2 Apr 2020
Topic — A consultation on revising EU rules for public access to justice.
Message — The organization opposes expanding review access, arguing existing channels are already open. They suggest the revision should not create additional or unnecessary burdens for industry.12
Why — This position helps the company avoid legal uncertainties and protects mining investments.3
Impact — Civil society groups lose improved opportunities to challenge decisions affecting the environment.4
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Response to Revision of the Energy Tax Directive

1 Apr 2020

KGHM Polska Miedź S.A. is a major copper and silver producer (both mining and processing) for more than 50 years. We welcome the Commission’s decision to review the Energy Taxation Directive (ETD) and to provide an opportunity to respond to the public consultation on the Roadmap for its revision. The EU is currently in the process of evaluating the possibility to further raise its climate goals under the European Green Deal. In this regard, energy taxation has a crucial role to play. We we would like to outline certain potential impacts, as well as opportunities, from the perspective of highly electro-intensive company. Please find attached our detailed comments. We would highly appreciate to participate in the future consultation steps.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

KGHM Polska Miedź S.A. is a major copper and silver producer (both mining and processing) for more than 50 years. We welcome the possibility to provide feedback on the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM). The design of a carbon border adjustment mechanism or any alternative solution requires careful considerations and a detailed impact assessment. Due to the innovative nature of this instrument, CBAM should be introduced gradually by including selected sectors in the pilot phase. Only at the next stage, after a thorough analysis of its functioning during the test period, a wider approach can be considered. A well-designed CBAM should comply with WTO and other trade regulations in order to minimise the risk of retaliation. A fully functioning EU ETS is one which provides adequate protection against carbon leakage. As Europe’s most electro-intensive industry, we believe that existing carbon leakage measures in the form of free allowances and indirect costs compensation system, although not fully sufficient, are the optimal instruments to protect our industry from carbon leakage and should be maintain. We would highly appreciate to participate in the future consultation steps.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

5 Mar 2020 · Meeting with KGHM