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K+S Aktiengesellschaft

K+S AG

Die Interessenvertretung der K+S Aktiengesellschaft dient dem Zweck, das grundsätzliche Verständnis für die Rohstoffgewinnung von Kali- und Steinsalzen, dessen Wertschöpfung und volkswirtschaftlicher Bedeutung im politischen Umfeld zu fördern.

Lobbying Activity

Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair) and Apple Inc. and

23 Feb 2024 · Aktuelle Themen in der Europapolitik und Sachsen

Meeting with Andreas Glück (Member of the European Parliament)

16 Jan 2024 · Soil Monitoring Directive

Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export

28 Jul 2023

As K+S, we provide the agriculture market with highly efficient fertilizing products contributing to crop health and food security. At the same time, we set high standards for all our products and their environmental impacts in line with the high regulatory standards established in the EU. While in general we deem a sound information basis necessary for everyone to make reasonable decisions on which products to use, we have some concerns with the policy options proposed by the EU Commission for the revision of the PIC Regulation. First of all, as the EUs implementation of the UN convention, the PIC Regulation should always be based on the principles of the UN convention. More than 160 contracting parties agreed on these fundamental principles and rules. Single-handed, one-sided deviations by the EU may significantly harm the well-established and efficient information system and global trading cooperations. Additionally, it would patronize many countries and disrupt the level playing field. Therefore, we highly encourage to strive for a global solution. However, instead of promoting amendments on the Rotterdam Convention contributing to higher safety levels worldwide, the EU Commission proposes several one-sided policy options. With the limited information available yet, it is challenging to assess the impact each option would have. Further clarification and definitions are highly necessary. For example, it is not clear what the policy option to introduce production prohibitions for chemical not approved or prohibited for placing on the market and/or use in the EU shall cover. Production bans should generally only be considered as a measure of last resort. There are several reasons possible why a substance or mixture may not be placed on EU market, not all of them basing of insufficient ways to handle them safely. Additionally, the revision of the REACH Regulation, EUs main regulation dealing with chemicals restrictions and prohibitions, is still on-going. The proposed extension of the generic approach to risk management (GRA) would lead to much higher numbers of restricted chemicals. If all these chemicals would become subject to the PIC Regulation, the bureaucratic burden for exporting companies would increase tremendously bringing EUs industry in disadvantage. At the same time, a benefit for human health or the environment may be doubted as the GRA restrictions shall be solely based on the hazard profile and shall not consider even simplest means to handle these hazards safely which may also be applied in third countries. Especially when dealing in the agricultural sector, prohibitions of specific products may directly reflect on crop yields and/or food prizing. On one hand, there may be no suitable alternative leading to lower crop yields and in consequence to shortages and/or increasing prizes for agricultural products. On the other hand, professional users might be forced to switch to alternative products coming from countries with lower standards regarding product safety, occupational health, and productions impact on the environment than the EU. This may lead in the end to higher risks for users and bigger adverse effects on the environment. This would be directly contradicting to the PIC Regulations and Rotterdam Conventions general goal! The PIC Regulation is a suitable and powerful tool to implement worldwide standards. Instead of one-sided hampering with the established system and potentially causing severe trade disruptions and regrettable product substitutions, the EU should promote further improvements at the UN level. For these reasons, we strongly urge to refrain from any generic prohibitions but consider other, less limiting, and more inclusive policy options.
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Response to Environmental claims based on environmental footprint methods

20 Jul 2023

As K+S, we see ourselves as pioneers in environmentally friendly and sustainable mining. Our constant efforts to set global standards resulted in several developments of new techniques and processes to better protect the environment and reduce our products footprints and these efforts are on-going. Therefore, we highly welcome the Commissions initiatives to introduce a regulatory framework allowing for substantiated environmental claims. This new directive will increase transparency and prevent questionable or misleading claims by separating the chaff from the wheat. Nevertheless, we still see need for clarification or improvement. In general, we would like to refer to the input provided by VCI, the German association for the chemical industry. We support VCIs arguments and see a high relevance not only for chemicals but also for fertilizing products. Most importantly from our point of view is that EU-wide unambiguous rules have to apply. National fragmentation should be prevented. This is true for the evaluation procedure as well as for the verification of the environmental claims (including the used methods). Consequently, the mutual recognition of verified claims implemented in Article 10 (7) is of utmost importance. This reduces bureaucratic obstacles and therefore promotes more sustainable products contributing to the initiatives aims. Therefore, Article 10 (8) which undermines this principle should be deleted without substitute.
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

17 May 2023

The Commission aims to improve the communication of labelling information and provide economic operators the flexibility to opt for the rules that are most appropriate for their specific products. In principle, this approach is heavily supported by industry including K+S as it may help save resources and costs, contribute to sustainability and facilitate communication. Thus, it will also contribute to user and environmental safety. However, the current proposal fails these goals as the huge majority of products on the market will not benefit from a digital label. If the text will not be changed significantly before coming into force, the possibility to provide digital labels will not be of any relevance in practice and a huge opportunity to facilitate and improve communication will be not only missed but wasted. Instead of promoting digitalization, simplifying labels and improving communication, the EU Commissions missed the opportunity to adapt the Fertilising Products Regulation to technological and societal changes. Concerns regarding health and environmental safety can easily be allayed as there are already appropriate regulations in place. With more appropriate and proven options already at hand, it is incomprehensible why the expertise and proficiency of farmers is being disregarded and the chance to exploit the potential of digital labels has been wasted. Further harmonization with other legislations and thus simplification and improved communication could have been achieved by introducing the term professional user and agreed technical requirements. But with this very limited applicability of a digital label, the benefits of the proposed amendment will be marginal at best. Please find our extensive elaboration including all our arguments and details on an alternative, more appropriate approach to implement digital labels attached to this submission.
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

The EU Commissions proposal for the Ecodesign for Sustainable Products Regulation (ESPR) will broaden the scope of current ecodesign legislation significantly to contribute to the goals of the Circular Economy Action Plan. In the current call for evidence, different products for end users, intermediary products that need further processing before being used by consumers, and horizontal measures are open for comments regarding their prioritization in the next process steps. As K+S, we do not support prioritising chemicals as intermediate products within the supply chain. Moreover, we do not deem ecodesign requirements for chemicals suitable or expedient due to several reasons. Information on the environmental performance of intermediary products will not enable a consumer to buy more sustainable products. This is particularly obvious when the intermediate is not used as an ingredient, but as a precursor in further chemical reactions, consuming the same. Therefore, intermediary products should not be prioritised in principle to adhere to the basic goals and objectives of the initiative. Furthermore, one substance may have manyfold applications. Its sustainability performance may vary depending on the end-use which impedes a meaningful assessment of its environmental impact as an intermediary product. The approach chosen by the Joint Research Center (JRC) scores different product categories based on different environmental aspects as well as the potential for improvements. In our point of view, this provides the possibility to prioritise different product groups in a reasonable and comprehensive way. Following JRCs assessment, chemicals as intermediary products are not of high priority. This is partially because there is already a distinctive regulatory framework for chemicals in the EU. Substances and mixtures, their production and processing are already subject to several different legislations ensuring minimal impact on the environment. They are assessed in detail under REACH and CPL Regulations, including potential effects on human health and the environment. Production sites must adhere to strict rules regarding emissions to water, air, and soil. Different information requirements ensure relevant data to be passed along the whole supply chain, also covering waste management and treatment. Thus, the overall impact on the environment by chemicals as intermediary products is already low. However, further criteria within the ESPR may lead to conflicting requirements and/or double regulation and may bring EU manufacturers in disadvantage compared to non-EU suppliers. Ready-to-use substances and mixtures that may also be bought by consumers do not fall within the proposed group of chemicals as intermediary products. They will be treated as individual end-use product groups and there are usually supplementary product-specific regulations in place. Adverse effects from chemicals in products or the misuse of products would not be covered by the ESPR criteria for chemicals as intermediates but will need to be addressed in the respective ESPR end-use product group and in case of misuse in other legislations. Prioritising chemicals as intermediary products in the development of specific ESPR criteria would miss the target of the initiative. It might lead to conflicting requirements and/or double regulation. Additionally, the potential for improvement is very low due to the strict regulatory framework in place. Instead, the EU Commission should focus on relevant end-products already identified as having a significant environmental impact and high potential for improvement. Thereby, the sustainability of these most relevant product groups may be improved, and consumers may directly further promote the transition towards more sustainable products by their sound and informed purchase decision.
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Response to European Critical Raw Materials Act

25 Nov 2022

K+S Group is an internationally oriented raw materials company based in Germany with production sites in Europe and North America that supplies the strategic minerals POTASH and SALT to European agriculture (potash fertilizers), industry, the pharmaceutical sector and consumers. We welcome the European Commissions new raw materials initiative and the possibility to contribute to the public consultation on the upcoming EU Raw Materials Act. Russia's war against Ukraine and the disrupted supply chains during the Corona pandemic show that it is of utmost importance to increase the EU's resilience in strategic raw materials. This is not only about future energy supplies in Germany and Europe, but also about minerals such as POTASH and SALT, which are essential for food production, medicine, industry and consumers. It is important that the upcoming EU raw materials act should recognize the strategic importance of domestic production of POTASH and SALT and support strategic raw materials projects such as the transformation of Europe's largest potash mine in Germany (Werra 2060 project, 2023-2027).
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and Verband der Kali- und Salzindustrie e.V.

16 Nov 2020 · Impact of a higher 2030 climate target on the potash industry and ETS-related aspects