LANXESS AG
LANXESS is a leading specialty chemicals company with sales of EUR 6.7 billion in 2023.
ID: 77303494979-13
Lobbying Activity
Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and
4 Nov 2025 · Overview of the Commission's Single Market Strategy.
Response to Food and Feed Safety Simplification Omnibus
13 Oct 2025
LANXESS welcomes this initiative for an omnibus proposal aiming to simplify and clarify regulatory requirements on plant protection products, biocidal products, feed additives, food hygiene and official controls as well as other measures to simplify EU food law. In particular, we would like to highlight the concern emerged around the expiry of data protection for all existing active substances under the Biocidal Products Regulation (BPR) by the end of 2025. Please find our detailed statement in the attached document.
Read full responseMeeting with Stéphane Séjourné (Executive Vice-President) and
5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU
Meeting with Andrea Wechsler (Member of the European Parliament) and Gas Infrastructure Europe and Future Cleantech Architects
9 Apr 2025 · EU energy and industry policy
Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)
8 Apr 2025 · Simplification
Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)
14 Mar 2025
We welcome the opportunity to comment on the Draft Delegated Regulation amending Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards the persistent organic pollutants polychlorinated biphenyls. Please find more details on our position in the attached document.
Read full responseMeeting with Axel Voss (Member of the European Parliament)
17 Jan 2025 · Better Regulation
Meeting with Axel Voss (Member of the European Parliament) and Bundesnotarkammer
3 Sept 2024 · Digital files
Meeting with Alexandra Geese (Member of the European Parliament) and Bayer AG and Covestro AG
9 Apr 2024 · European Elections
Meeting with Jens Geier (Member of the European Parliament)
26 Jul 2023 · Exchange on the Net Zero Industry Act (staff level)
Response to European Critical Raw Materials Act
26 Jun 2023
LANXESS welcomes the opportunity to contribute to the European Commission's proposal to establish a framework for ensuring a secure and sustainable supply of critical raw materials. LANXESS acknowledge that phosphorus and phosphate rock have been included in the Critical Raw Materials list in the EU Commissions proposal for a European Critical Raw Materials Act. However, phosphorus should be renamed as Elemental Phosphorus (P4 and derivatives). Elemental phosphorus (P4), also called white phosphorus or yellow phosphorus, is the elemental form of phosphorus which is produced from phosphate rock by a thermal process in P4 ovens. Currently, there is no production of Elemental Phosphorus (P4) in Europe. The last furnace located in Europe closed in 2012. This means that the EU entirely depends on imports mainly from Kazakhstan and Vietnam. Given the high strategic importance of elemental phosphorus (P4) as a key enabler of the green transition and to strengthen the EU´s economic resilience and strategic autonomy, elemental phosphorus (P4) shall also be included in the Strategic Raw Materials list. The economic importance of Elemental Phosphorus (P4) should also be recognised not only due to the limited diversification of external supply but specially because of the impossibility to be substituted by other raw materials used in strategic technology applications from strategic value chains (e.g. batteries, ICT, energy storage, defence). As for instance in the production of batteries, LiPF6 is the dominating conductive salt for electrolytes and the whole battery value chain depends on it. LiPF6 can only be produced from elemental phosphorus P4, and not from other phosphorus sources. Additionally, the European Critical Raw Material Act aims that the EUs consumption of strategic raw materials is partially covered by secondary raw materials, which would improve both the security and sustainability of the EUs raw material supply. If Elemental Phosphorus (P4) is not included in the strategic raw materials list, several recycling projects which are under development to produce very high-purity elemental phosphorus (P4) in Europe from secondary materials (such as sewage sludge) would not be considered as a Strategic Project under the European Critical Raw Materials Act. Thus, it would be extremely important that Elemental Phosphorus (P4) is recognized as a Strategic raw material to foster alternative and sustainable elemental phosphorus (P4) sources in Europe, with a very low product carbon footprint.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
11 May 2023
LANXESS AG, as a leading speciality chemicals company, welcomes the opportunity to contribute to the European Commission´s preparatory work in defining the order of priority in which intermediate and end-products should be tackled and whether horizontal measures identified as potential priorities under the Ecodesign for Sustainable Products Regulation (ESPR) are the best. We strongly believe the ESPR should focus on establishing criteria to foster environmental /sustainability requirements for products aiming to achieve the European Union´s circular economy objectives. Accordingly, please find attached LANXESS´s views on the order of priority in which intermediate and end products should be tackled under the future Ecodesign for Sustainable Products Regulation (ESPR).
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
29 Mar 2023
LANXESS fully supports the aims of the CLP Revision to better identify and classify hazardous chemicals, to improve communication on chemical hazards and to address legal gaps and high levels of non-compliance. We therefore welcome the measures proposed in the draft legal text regarding digital labelling, the labelling of substances and mixtures in very small containers as well as the clarification of provisions regarding distance sales of chemicals. We are, however, concerned that the CLP Regulation is increasingly used for risk management as a direct result of a harmonized classification. This concern is confirmed by the EU Commissions plans for the application of the so-called generic approach to risk management as announced in the Chemicals Strategy for Sustainability. Additionally, the regulation of many products such as biocides, pesticides, cosmetics is directly linked to the CLP hazard classes. Using harmonized classification and labelling for regulatory risk management will have unforeseeable and unintended impacts such as products with a high benefit for society vanishing from the European market. Therefore, no risk management measure should be taken without a prior risk assessment and a consultation of the stakeholders concerned by the measure. So far there has been no assessment of the impacts of the ripple effect that the implementation of new CLP hazard classes could have along the whole value chain. Moreover, a continuous deviation of the CLP Regulation from the UN GHS puts an additional burden on the EU chemical industry and hampers its global competitiveness. Please refer to the attached document for a more detailed comment.
Read full responseMeeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Salzgitter AG and
22 Mar 2023 · Green transition and innovation
Meeting with Peter Liese (Member of the European Parliament, Rapporteur)
27 Feb 2023 · Fit for 55
Response to Introducing new hazard classes–CLP revision
17 Oct 2022
As the EU Commission has stated several times “the CLP Regulation is the core piece of Union legislation for the hazard assessment of chemicals, stemming from the United Nations’ global standard (GHS), and sets out the hazard classification of chemicals and how to communicate those hazards to consumers and workers”. We are, however, concerned that the CLP Regulation is no longer used for its initial purpose, i.e. hazard assessment and communication, but increasingly for risk management as a direct result of a harmonized classification. This concern is confirmed by the EU Commission’s plans for the application of the so-called “generic approach to risk management” as announced in the Chemicals Strategy for Sustainability. Additionally, the regulation of many products such as biocides, pesticides, cosmetics is directly linked to the CLP hazard classes. Using harmonized classification and labelling for regulatory risk management will have unforeseeable and unintended impacts such as products with a high benefit for society vanishing from the European market. Therefore, no risk management measure should be taken without a prior risk assessment and a consultation of the stakeholders concerned by the measure. So far there has been no assessment of the impacts of the ripple effect that the implementation of new CLP hazard classes could have along the whole value chain.
Moreover, a continuous deviation of the CLP Regulation from the UN GHS puts an additional burden on the EU chemical industry and hampers its global competitiveness.
LANXESS does not support the introduction of CLP hazard classes for endocrine disruptors (ED). In contrast to the existing classification categories (e.g. carcinogenic, toxic for reproduction, etc.) endocrine disruption is considered to be a mode of action and not a hazard property. To be considered as an ED (at least for human health) the substance must elicit an adverse effect. Since this by definition will lead to a classification as carcinogenic, mutagenic or at relevant doses to STOT RE, classification as ED will lead to double classifications. Moreover, with the foreseen changes of the REACH Annexes regarding information requirements for EDs, also ecotoxicological tests concerning endocrine effects will be mandatory. Thus, if adverse endocrine effects (in the environment) are detected, they will automatically be taken into account under REACH. The CLP Regulation is therefore not an appropriate legal framework for EDs. From our point of view, it would be sufficient to identify EDs under one horizontal legislation like the REACH Regulation and if necessary regulate them under sector specific regulations like the Biocidal Product Regulation or the Plant Protection Products Regulation- provided that clear guidelines for the (risk) assessment of EDs are available and applied in line with the “one substance, one assessment” principle .
The introduction of new hazard classes would most likely result in a significant increase of animal testing. In the interest of animal welfare reliable alternatives to animal testing should first be available and accepted before the new hazard classes are being implemented.
We note that certain paragraphs and definitions of the draft text on hazard classes for EDs are vague and open to interpretation, which leads to legal uncertainty. The criteria and all additional data that may be used for classification should therefore be specified in the legal text in as much detail as possible in order to avoid lengthy and complicated guidance development and bottlenecks during the CLH process. Guidance documents on the process for harmonized classification and labelling should be available before the entry into force of the delegated act.
In case new hazard classes are nevertheless introduced in CLP, the evidence of an adverse effect must be a prerequisite for the classification of substances for endocrine disrupting properties for human health or the environment.
Read full responseResponse to Streamlining EU scientific and technical work on chemicals through the EU agencies
11 Apr 2022
LANXESS welcomes the initiative by the European Commission to streamline the assessment of chemicals towards “one substance, one assessment” in order to increase transparency and coherence.
However, this can only be achieved, if the following aspects are taken into account when implementing the “one substance, one assessment” principle:
- Transparency of the assessment must be ensured: All information regarding the evaluating authority, the process and status of the assessment as well as all relevant documentation must be available to all stakeholders.
- The assessment of chemicals must be science-based.
- Better coordination: Different bodies active in the assessment of chemicals must ensure proper coordination of their work, especially when they are assessing the same substance. This includes an exchange of information such as results of previous assessments.
- It must be ensured that each body (i.e. authority, agency, working group, etc.) that is carrying out an assessment of (groups of) chemicals is equipped with sufficient expertise necessary for the specific assessment, e.g. in the field of toxicology, ecotoxicology, occupational safety and health, exposure assessment, etc.
- Coordination between EU member states: Also the national authorities of each EU member state that are active in the assessment of chemicals, e.g. under REACH, should be included in the “one substance, one assessment” initiative in order to prevent diverging views between member states and/or EU authorities regarding the assessment of (groups of) chemicals.
In general LANXESS advocates for a “one substance, one hazard assessment” approach: Hazard assessment should be carried out horizontally, for example under REACH, whereas risk assessment should be done under sector specific legislation. This way it can be ensured that potential risks of a chemical substance are regulated using the most appropriate regulatory tool.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
31 May 2021
We welcome the possibility to provide input to the Inception Impact Assessment on the revision of the REACH Regulation.
LANXESS supports the Green Deal goals of the European Commission. Sustainability plays a crucial role in the corporate strategy of LANXESS. We, therefore welcome the fact that the European Commission puts a strong focus on sustainability in its future chemicals policy.
With REACH we already have the most ambitious and comprehensive legislative framework for the assessment and regulation of chemicals in the world. Therefore, we ask the European Commission to focus the targeted revision of the REACH Regulation on achieving better coherence, regulatory predictability and a more harmonized EU-wide enforcement.
A strong tightening of the legal provisions of the REACH Regulation together with many other legislative proposals as announced in the Chemicals Strategy for Sustainability could, from our point of view, further jeopardize Europe as an important location for the chemical industry and thus hamper the EU’s global competitiveness.
Please find our detailed statement in the attached document.
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
31 May 2021
We welcome the possibility to provide input to the Inception Impact Assessment on the revision of the CLP Regulation.
As the EU Commission states in the introduction to the Inception Impact Assessment for the revision of the CLP Regulation “the CLP Regulation is the core piece of Union legislation for the hazard assessment of chemicals, stemming from the United Nations’ global standard (GHS), and sets out the hazard classification of chemicals and how to communicate those hazards to consumers and workers”. We are, however, concerned that the CLP Regulation is no longer used for its initial purpose, i.e. hazard assessment and communication, but more and more for risk management as a direct result of a harmonized classification. This concern is confirmed by the EU Commission’s plans for the application of the so-called “generic approach to risk management” as announced in the Chemicals Strategy for Sustainability. Applying this approach with a direct link to a harmonized classification and labelling will have unforeseeable and unintended impacts such as products with a high benefit for society vanishing from the European market. Therefore, no risk management measure should be taken without a prior risk assessment and a consultation of the stakeholders concerned by the measure.
Moreover, a continuous deviation of the CLP Regulation from the UN GHS puts an additional burden on the EU chemical industry and hampers its global competitiveness. Therefore, we strongly call for any change of the current classification and labelling system to be preceded by a change of the UN GHS.
Please find our detailed statement in the attached document.
Read full responseMeeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)
19 Feb 2018 · Digital skills
Response to Criteria to identify endocrine disruptors for biocidal products
28 Jul 2016
We acknowledge the efforts of the European Commission to define criteria for endocrine disruptors, however we believe that the current proposal is not yet fit for the purpose of regulating biocidal substances. We are of the opinion that only such substances should be classified as endocrine disruptors that do pose a risk at use conditions and that potency should be part of the assessment process.
While we support using the WHO definition for endocrine disruptors as a starting point and agree with defining “known” endocrine disruptors to be regulated under the BPR, we believe the current proposal does not provide enough guidance as to the actual criteria being applied in future substance assessments.
We support the WHO IPCS definition as a starting point for the criteria, with clear reference to all three elements: adverse effects, mode of action and causality, as well as the use of the WHO IPCS definition of adverse effects. This is a good basis, it is a harmonized definition, which is widely accepted and supported. However, on its own, it does not provide meaningful scientific criteria that are needed to allow appropriate screening of the substances by distinguishing between those that could cause harm under realistic exposure conditions and those that would pose no threat to human and animal safety or the environment at realistic exposure level. The current proposal falls short of including the necessary elements that allow for a full risk assessment. It has to be noted that an understanding of a substance’s potency and consideration of existing dose-response relation and, consequently, the derivation of limit values for safe use are appropriate and necessary elements that need to be taken into account, and therefore need to be added to the current Commission proposal.
Applying the Commission proposal as it stands, with less than clear criteria to be applied, could potentially lead to substances being banned which have valuable contributions to public health and society - purely on the identification of a possible hazard, disregarding the fact that in their current use no safety concerns to humans, animals or the environment are to be expected.
The purpose of regulatory measures should be to enable regulators and the industry to distinguish between substances that truly pose a risk through endocrine disruption and substances with a potential hazard which pose no risk to humans or the environment at any realistic use conditions. It has to be kept in mind that an adverse endocrine-mediated effect shown in laboratory conditions at exceptionally high doses bears no relation to real human or environmental exposures and risks. These adverse effects must be relevant to humans and wildlife populations, not to be secondary to other toxic effects, and occur at exposure levels indicative of significant potency. Only those substances should be considered endocrine disruptors as for the purpose of imposing regulatory consequences (exclusion criteria).
We support the Commission’s view that only ‘known’ endocrine disruptors should be regulated by the definition as this provides scientific and legal certainty. Opening up the definition to “presumed” endocrine disruptors would scrutinize substances, where (by definition) no clear causal link was provided between the endocrine mode of action and the adverse effect. This would lead to significant regulatory risk for companies, fewer substances being supported to fulfil vital functions in public sphere and increase the burden on authorities to assess a wide array of additional substances that are not clearly identified as having an adverse effect, rather on focusing on the ones where the definition is met.
Read full responseMeeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)
29 Jan 2016 · The role of innovation in the Energy Union