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MOL Hungarian Oil and Gas Company

MOL Group

MOL Hungarian Oil and Gas Company is an integrated international oil and gas company headquartered in Budapest, Hungary, operating in over 30 countries.

Lobbying Activity

MOL urges regional balance in European Competitiveness Fund design

12 Nov 2025
Topic — EU budget proposal consolidating research and innovation funding into single competitiveness fund.
Message — MOL requests mechanisms to address regional imbalances in innovation funding and clearer implementation details. They argue centralization risks widening the gap between advanced and less-developed regions. The company seeks explicit support for transitional technologies and a comprehensive decarbonization roadmap.123
Why — This would ensure their regions access funding and secure financing for their transitional energy technologies.45
Impact — Less-developed regions lose if centralization favors Western Member States with stronger innovation capacity.67
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MOL urges equal access to EU innovation funding for Central-Eastern Europe

6 Nov 2025
Topic — EU research and innovation framework programme for 2028-2034 covering industrial transformation and clean energy.
Message — MOL requests stronger guarantees for regional balance in funding distribution and support for transition technologies like carbon capture and hydrogen. They want more flexible consortium rules allowing large companies to apply independently for industrial demonstration projects.12
Why — This would increase their access to EU funding for decarbonisation technologies and reduce administrative barriers.34
Impact — Smaller research organizations lose if large companies can bypass consortium requirements for funding.5
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Meeting with Kitti Nyitrai (Head of Unit Energy)

4 Nov 2025 · Current and future challenges for the industry

Meeting with Dan Jørgensen (Commissioner) and

29 Oct 2025 · Phasing-out of RU energy imports

Meeting with Paulius Saudargas (Member of the European Parliament, Rapporteur for opinion)

25 Sept 2025 · Phasing out Russian energy imports

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Dan Jørgensen)

22 Sept 2025 · Regional gas infrastructure

Meeting with Ernő Schaller-Baross (Member of the European Parliament)

20 Sept 2025 · Exchange of views

Meeting with Martin Hojsík (Member of the European Parliament)

12 Sept 2025 · REPowerEU Roadmap

Meeting with András Gyürk (Member of the European Parliament)

10 Sept 2025 · Security of energy supply

Meeting with Jana Nagyová (Member of the European Parliament)

9 Sept 2025 · RePower EU Roadmap

Meeting with Jens Geier (Member of the European Parliament)

9 Sept 2025 · Exchange on European Gas Grid Development

Meeting with Iuliu Winkler (Member of the European Parliament)

9 Sept 2025 · RepowerEU Roadmap

Meeting with Andrea Wechsler (Member of the European Parliament)

9 Sept 2025 · EU Energy and industry policy

Meeting with Adina Vălean (Member of the European Parliament)

9 Sept 2025 · energy infrastructure

Response to Clean corporate vehicles

8 Sept 2025

Please find enclosed our detailed position.
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MOL Group calls for proportional funding for transport energy transition

4 Sept 2025
Topic — Strategic framework to boost investments in renewable fuels for aviation and waterborne transport.
Message — MOL requests continuous funding proportional to the transport sector's investment needs for decarbonization. They advocate for support beyond initial pilot technologies to help scale up existing sustainable solutions. Regulators should also reduce fixed power tariffs that hinder the rollout of charging infrastructure.12
Why — Increased funding and lower operational fees would de-risk their transition to low-carbon fuel production.3
Impact — Power grid operators could lose revenue if fixed capacity tariffs for chargers are reduced.4
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MOL Group urges swift adoption of chemical recycling rules

18 Aug 2025
Topic — Common rules for calculating and reporting recycled content in single-use plastic bottles.
Message — MOL Group calls for the swift adoption of rules to secure investment certainty. They support the fuel-use excluded methodology as a blueprint for future recycling regulations.123
Why — MOL would benefit from utilizing its existing chemical assets and protecting its confidential information.45
Impact — Environmental advocates lose if credit transfers across different industrial sites are permitted.6
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Meeting with Eszter Lakos (Member of the European Parliament)

15 Jul 2025 · EU energy policies

MOL Group calls for robust funding to accelerate decarbonisation

8 Jul 2025
Topic — This consultation addresses policies to support the decarbonisation and competitiveness of industry.
Message — MOL Group requests that all financial instruments be accessible to European industry. They also demand support for all green technologies and incentives for local materials. Additionally, they seek centralized and harmonized permitting processes across all Member States.12
Why — Financial aid and local content requirements would secure their investments and market position.3
Impact — Non-European suppliers lose market share due to proposed requirements for local content.4
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MOL Group warns EU carbon market risks industrial competitiveness

7 Jul 2025
Topic — The European Commission is reviewing the EU emissions trading system and market stability reserve.
Message — MOL Group calls for preserving free carbon allocations and increasing financial support for industrial decarbonization. They propose swapping emission quota obligations for direct investments in low-carbon technology. They also oppose including municipal waste incineration in the system.123
Why — The proposals would reduce the company's compliance costs and secure subsidies for green investments.4
Impact — Western European projects would lose their dominant share of innovation funding under proposed regional quotas.5
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Meeting with Cristina Lobillo Borrero (Director Energy)

11 Jun 2025 · Presentation of MOL Group's position on RePower EU and Roadmap

Meeting with András Tivadar Kulja (Member of the European Parliament)

15 May 2025 · Waste management and recycling

Meeting with Aurel Ciobanu-Dordea (Director Environment)

15 May 2025 · Exchange of views on Circular Economy Act

MOL Group urges delay and 1% threshold for CO2 storage

16 Apr 2025
Topic — New EU rules require oil and gas producers to provide carbon storage capacity.
Message — MOL requests postponing the 2025 planning deadline and setting a 1% production threshold for exemptions. They also demand the removal of requirements to disclose sensitive commercial project data.123
Why — This would reduce immediate compliance pressure and protect trade secrets from competitors.4
Impact — Smaller oil and gas producers would be forced to contribute to storage targets.5
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Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

15 Apr 2025 · Energy and energy-intensive industries in Europe, Competition policy (i.e. mergers)

Meeting with Valdis Dombrovskis (Commissioner) and

27 Mar 2025 · Competitiveness

Meeting with Maroš Šefčovič (Commissioner) and

30 Jan 2025 · EU Trade and Economic Security

Meeting with Ernő Schaller-Baross (Member of the European Parliament)

12 Nov 2024 · Annual Reception - Exchange of views

Meeting with Eszter Lakos (Member of the European Parliament)

12 Nov 2024 · EU energy policy

Meeting with Kinga Kollár (Member of the European Parliament)

12 Nov 2024 · Oil sector

MOL Group seeks exemptions to reduce biomethane administrative burdens

7 Nov 2024
Topic — Proposed rules extending the Union database to cover raw fuel material production.
Message — MOL proposes exempting suppliers within 50km of plants from registration to reduce bureaucracy. They also suggest long-term contracts should serve as sufficient evidence of traceability for farmers.12
Why — Reducing administrative requirements prevents shifting investments from biomethane toward the electricity sector.3
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MOL Group demands faster inclusion of nuclear in fuel methodology

25 Oct 2024
Topic — This consultation establishes the methodology for certifying greenhouse gas savings from low-carbon fuels.
Message — MOL demands the immediate recognition of nuclear electricity and industrial use of solid carbon. They seek clarity on methane emissions to avoid investment uncertainty.12
Why — Faster rules for nuclear power would improve the feasibility of MOL's projects.34
Impact — Environmental groups lose if carbon from natural gas avoids permanent storage requirements.5
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Meeting with András Tivadar Kulja (Member of the European Parliament)

30 Sept 2024 · Recycling in Hungary

Meeting with András László (Member of the European Parliament)

17 Sept 2024 · Delegation meeting

Meeting with Viktória Ferenc (Member of the European Parliament)

17 Sept 2024 · Excange of views

Meeting with Enikő Győri (Member of the European Parliament)

17 Sept 2024 · exchange of views

Meeting with András Gyürk (Member of the European Parliament)

17 Sept 2024 · Overview of the EU priorites of Mol

Meeting with Ernő Schaller-Baross (Member of the European Parliament)

17 Sept 2024 · Exchange of views

Meeting with Pál Szekeres (Member of the European Parliament)

17 Sept 2024 · Hungarian Delegation meeting

Meeting with András Gyürk (Member of the European Parliament)

29 Aug 2024 · Overview of energy policy priorities for the upcoming mandate

Meeting with Maroš Šefčovič (Executive Vice-President) and

16 Apr 2024 · IOGP Roundtable

Meeting with András Gyürk (Member of the European Parliament) and EuroAtlantic Consulting Investment PLC

20 Mar 2024 · Exchange of views

Meeting with Maroš Šefčovič (Executive Vice-President) and

5 Feb 2024 · High-Level roundtable with Suppliers

Response to Measures to reduce microplastic pollution

17 Jan 2024

Please see our feedback in the attached file.
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MOL Group urges flexibility in EU vehicle recycling rules

2 Dec 2023
Topic — The consultation addresses new EU regulations for vehicle design and end-of-life recycling.
Message — MOL Group argues for pre-consumer recyclate recognition and flexible national waste systems. They suggest replacing strict model-specific requirements with broader manufacturer-to-manufacturer loops. They also propose delaying plastic recycling targets to ensure technical and commercial feasibility.123
Why — This would reduce operational expenses by avoiding complex tracking and cross-border transport costs.4
Impact — Environmental goals are undermined by the request to delay plastic recycling targets for years.5
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MOL Group Urges EU to Simplify Complex Sustainability Reporting

1 Dec 2023
Topic — Commission initiative to reduce reporting burdens on companies by twenty-five percent.
Message — MOL proposes narrowing value chain reporting to Tier-1 or Tier-2 to ensure proportionality. They request extending phase-in periods and making certain sustainability indicators optional to reduce redundancy.12
Why — Reducing reporting requirements would lower administrative costs and the need for extra staff.34
Impact — Environmental groups lose oversight of indirect emissions from complex oil supply chains.5
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MOL Group warns Taxonomy criteria risk understating actual progress

2 May 2023
Topic — This consultation establishes classification criteria for investment purposes regarding EU environmental objectives.
Message — MOL Group urges the EU to adopt more realistic recycled content targets and recognize chemical recycling potential. They request that technical screening criteria align with upcoming legislation like the Packaging and Packaging Waste Regulation. The company also advocates for including mixed waste collection and voluntary remediation activities within the taxonomy.123
Why — The company would avoid high compliance costs and protect its investments in chemical recycling technology.45
Impact — Environmental organizations lose as lower recycling targets and lenient thresholds weaken overall circular economy standards.67
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MOL Group urges market-driven approach to new packaging rules

17 Feb 2023
Topic — The Commission is revising rules to reduce waste and improve packaging design for circularity.
Message — MOL Group requests that recycling rules include innovative chemical technologies and allow for-profit waste system operators. They argue against mandatory material composition labelling which they claim confuses consumers.123
Why — This protects their chemical recycling investments and permits profit from waste management infrastructure.45
Impact — Developing member states could face disproportionate burdens from uniform waste reduction targets.6
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Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Jan 2023 · Current economic and energy market situation of the EU (Meeting Slovnaft-100% part MoL Group)

MOL Group warns against adding feedstocks to capped list

2 Jan 2023
Topic — The European Commission is updating the list of sustainable feedstocks for producing biofuels.
Message — MOL Group urges the Commission not to add any new feedstocks to the capped list. They argue that moving materials to this list creates significant investment risks.12
Why — This would prevent competition for existing products within the current biofuel production cap.3
Impact — Renewable energy developers lose opportunities to scale up production using newly identified sustainable materials.4
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Meeting with Martin Hojsík (Member of the European Parliament)

16 Nov 2022 · Energy security, decarbonisation and circular economy

MOL Group urges practical refinery-level renewable fuel calculation rules

19 Jul 2022
Topic — EU methodology for determining renewable shares in fuels produced by co-processing biomass and fossil fuels.
Message — MOL requests unit-level system boundaries instead of refinery-wide measurements. They also seek to eliminate the requirement for keeping physical samples of every production batch.12
Why — This approach would lower compliance costs and provide investment certainty for biofuel production.3
Impact — Member State authorities would lose direct control if third-party schemes handle all verification.4
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MOL Group urges flexible GHG rules for synthetic fuels

17 Jun 2022
Topic — Establishing a methodology to calculate greenhouse gas savings for renewable and recycled fuels.
Message — MOL requests renewable energy definitions use heating values instead of molecular structures. They advocate for indefinite industrial carbon dioxide use and mass-balance allocation for emissions.123
Why — This would stabilize investment and prevent volatile carbon intensity ratings for their fuels.45
Impact — Environmental advocates lose the opportunity to mandate cleaner direct air capture technology.6
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MOL Group urges EU to relax methane leak detection requirements

15 Apr 2022
Topic — EU policy proposal for monitoring and reporting methane leaks in the energy sector.
Message — MOL Group requests doubling the implementation timeframe and switching from quarterly to annual reporting. They also advocate for increasing the leak detection threshold to 1,000 ppm.1234
Why — This would reduce its compliance costs and alleviate administrative pressure on human resources.56
Impact — Environmental interests lose from delayed detection and repair of smaller methane leaks.7
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Response to Revision of EU rules on Gas

12 Apr 2022

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model. We welcome the Gas Package aiming to establish rules for the transport, supply and storage of natural gas system and its transition to the system based on renewable and low-carbon gases. Such a green transition can only take place if the required changes do not impose disproportionate burden on society and provide appropriate incentives for investment in the energy systems. In addition, during the transition, security of energy supply must also be ensured. Based on these principles MOL Group proposes some comments to be considered. Our feedback is attached and integrates viewpoints on both the Regulation and Directive.
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Response to Revision of EU rules on Gas

12 Apr 2022

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model. We welcome the Gas Package aiming to establish rules for the transport, supply and storage of natural gas system and its transition to the system based on renewable and low-carbon gases. Such a green transition can only take place if the required changes do not impose disproportionate burden on society and provide appropriate incentives for investment in the energy systems. In addition, during the transition, security of energy supply must also be ensured. Based on these principles MOL Group proposes some comments to be considered. Our feedback is attached and addresses viewpoints on both the Regulation and Directive.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

Please find attached the feedback of the MOL Group.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The decarbonization of aviation sector is in the focus of the Fit for 55 package by introducing several provisions (ETS, ETD, RefuelEU Aviation) which intend to regulate the emissions of the sector. In addition, aviation is subject to international regulation as well. Hence, complying to obligations set for this sector is especially challenging due to the reinforced effects of these different provisions. The proposal for RefuelEU Aviaton Regulation represents a great challenge and high-investment risk for all the stakeholders, thus it is crucial to provide a clear regulatory framework and more flexibility during the transition period. Therefore, please find attached the document in which MOL Group would like to highlight the main concerns and express the following recommendations in details: • A revision of the availability of sustainable aviation fuels is proposed before 2025 to adopt targets for sustainable aviation fuel mandate. • Full consistency is required between RED and RefuelEU Aviation regulation to: (i) allow the use of co-processed fuels; (ii) make H2 used in refinery eligible; (iii) make 1G biofuels within the range of food and feed cap eligible; (iv) eliminate 1,7e% cap on part B feedstocks in Annex IX, RED II. • It is proposed to apply pooling for obligated fuel suppliers delivering to multiple airports all over the European Union.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. MOL Group was part of a unique cooperation of four leading companies from the electricity and oil & gas sectors joining forces with car manufacturers to create interoperable and non-discriminatory EV charging network in the Central and Eastern European region (NEXT-E project), installing 222 multi-standard fast chargers (50 kW) and 30 ultra-chargers (150-350 kW) along TEN-T core corridors and core network. Based on our experience, we are in favour of establishing an alternative fuel infrastructure network that ensures adequate business returns. To this end, uniform European regulatory action is needed, but it is also necessary to adopt provisions that take into account different national circumstances. The ambitious goals of the Commission proposal can only be achieved if EU and national funds are ongoingly available, to increase the attractiveness of these investments for the private sector. Please find below our detailed recommendations to ensure a more flexible, gradual and consistent regulatory environment to support the green transition. To summarise: • We do not believe that a minimum charging capacity should also be defined for plug-in hybrid vehicles. • We propose to lower the power output target per vehicle, taking into account the special needs and development levels of countries. • We also propose reduced ambition for publicly accessible recharging points on the TEN-T core network and TEN-T comprehensive network, taking into account the special needs and development levels of countries. • In those countries with a more mature market, lower targets will still allow the additional market-based development of the infrastructure on its own. However, in lower income countries, overly ambitious targets would leave the infrastructure unused, and technologically outdated by the time the penetration of electric vehicles reaches the needed rate.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The green transition can only take place if the required industrial and economic changes do not impose a disproportionate burden on society. The revised Energy Taxation Directive accompanied with some other elements of the package (Emissions Trading System for transport and buildings = additional carbon tax; Renewable Energy Directive) will directly and exponentially increase energy costs of households (raising energy taxation levels, removing exemptions) before competitively priced, low-carbon options would be available. Taxation is one of the best tools to pass the political signal to consumers. The benefits and impacts of energy taxation measures on households and industry shall be assessed together with other elements of the package. It is crucial that the transition would leave no one behind, as this would put a risk of losing public support for the low-carbon transition, especially in lower income member states. Please find attached our proposals for a well-designed ETD, which, with the necessary flexibilities, could contribute to the creation of a meaningful signal for investments in low-carbon energies.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The green transition can only take place if the required industrial and economic changes do not impose disproportionate burden on society. The revised RED III accompanied with some other elements of the package (Energy Taxation Directive and Emissions Trading System for transport and buildings = additional carbon tax) will directly and exponentially increase energy costs of households (raising energy taxation levels, removing exemptions) before competitively priced, low-carbon options would be available. It is crucial that the transition leaves no one behind, as this would put a risk of losing public support for low-carbon transition, especially in lower income member states. Continuous public support is essential i) for decision makers to set predictable regulatory environment and ii) for companies to invest in the future. Some of the provisions of the Commission’s proposal may impose disproportionate burden and excessive obligations also on industry, including energy producers and system operators (and through industry indirectly also on the population), for example by forcing costly, uneconomical investments prematurely. Capital-intensive and high-risk investments may jeopardize operations and in extreme cases may even lead to closures and energy supply disruption. MOL Group proposes the below and attached detailed recommendations on the Renewable Energy Directive (REDIII), to create a flexible, gradual and consistent regulatory environment to support the green transition, while minimizing societal burden and disruption risks: 1. Renewable targets in transport need to allow flexibility for Member States and obligated parties to achieve greenhouse gas (GHG) emissions reductions a. Sub-targets for renewable fuels of non-biological origin (RFNBO) in transport and in industry should allow for more flexibility, as they pose a huge burden on industry and society and require a large amount of renewable electricity within a short period of time b. The limited contribution of used cooking oil (UCO) towards the biofuel target is not justified, more clarity is needed in rules of classification of feedstock in Annex IX. c. The role of recycled carbon fuels (RCF) will be important in the future for the recovery of non-recyclable waste streams 2. The objective of renewable hydrogen use in industry should not apply to the amount of hydrogen generated as part of the process 3. Consistency with other proposals 4. Biogas contribution to renewable targets through green certificates
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030, for which energy efficiency policies and continuous energy efficiency improvements in operations are key. The green transition can only take place if the required industrial and economic changes do not impose a disproportionate burden on society and do not threaten the competitiveness of EU businesses. We would like to highlight that some of the provisions of the revised Energy Efficiency Directive (EED) may force uneconomical and unprofitable investments prematurely, while excluding energy savings in industry and households that could be more economical savings in a shorter timeframe, while other innovative solutions become economical for a wider range of consumers. Specifically, we believe that: • The EED should encourage savings in final energy consumption regardless of the technology used, including fossil and renewable energy technologies. • If saving obligations increase, the type of projects that are accountable for energy saving obligations should not be reduced, as this will make the achievement of such obligations difficult and less impactful. Please find attached our detailed recommendations to ensure a more flexible, gradual and consistent regulatory environment to support the green transition.
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Response to Export and import of hazardous chemicals – amendment of annexes

16 Nov 2021

We welcome the opportunity to comment on the draft delegated regulation amending Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals. We support the aims of the regulation to prevent unwanted imports and ensure that information on hazards, risks and safe handling is always provided when hazardous chemicals are exported. However, we would like to raise concerns regarding recital (12) of the draft regulation, and the corresponding entry in Annex I on "Benzene as a constituent of other substances in concentrations equal to, or greater than 0,1 % by weight". Please find our concerns and proposals attached.
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Response to Carbon Border Adjustment Mechanism

8 Nov 2021

MOL Group has a strong ambition to make improvements in its operation that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. Hence, MOL Group welcomes the European Commission’s proposal for the introduction of a Carbon Border Adjustment Mechanism (CBAM). Nonetheless, CBAM can only provide adequate protection for the European industry under the right design. After the first assessment of the CBAM proposal, MOL Group would like to make the following remarks: MOL Group consider the introduction of the Carbon Border Adjustment Mechanism (CBAM) to be a good direction. However, this “protection” does not solve all the problems and the current proposal needs further adjustment. The final proposal ensure that importers pay the same amount of carbon credits after the products covered by the provision as the EU producers of these sectors. We support this principle. However, due to precisely the WTO rules the mechanism does not provide support for the export of the European producers, thus European producers are still at a competitive disadvantage in export markets due to the cost of carbon and other climate policy measures. In addition, there may be a risk of WTO compliance and of retaliation by third countries, which could lead to restrictions on exports of EU products due to the lack of a consistent interpretation of the relevant rules in GATT-WTO dispute resolution procedures. Therefore, it would be important that the Commission be able to provide a guarantee that there is no risk of retaliation. We propose the Commission to set aside a compensation fund to cover the damage caused by a potential retaliation by non-EU countries. Another issue to be addressed is the imports of products, that contain the substances covered by CBAM, are not regulated, thus the risk of carbon leakage continues to increase in case of many products further up the value-chain. One good example for such situation is the automotive industry, where steel (raw-material) is covered by the system, but car with steel parts is not. By installing the car industry outside the EU, the manufacturers can avoid significant costs. Hence, we also recommend that complex, downstream products be included in the scope of the regulation. CBAM is also expected to be reflected in many areas of the economy by using products covered by CBAM. Some examples: (i) reflection in domestic electricity prices in those EU countries which are connected with non-EU grids, (ii) construction costs may increase due to rising prices for steel products as well. Regarding the increasing indirect carbon costs, it is essential that the CBAM addresses indirect emissions at the calculation of embedded emission of a product. CBAM can only provide efficient carbon leakage protection if the indirect emissions are taken into account. Overall, we consider that the introduction of such a system is inevitable, but in its current form it does not maintain the competitiveness of the European industry. In case of the appropriate design of CBAM, MOL Group would support the introduction of the CBAM on fuels as well as on petrochemical products imported into the European Union from third countries, given that the exposure of the European chemical industry is significant in this area, and distance is not a deterrent factor proven by the large-scale import of plastic raw material from non-EU countries.
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

Please find attached MOL Group's proposal for introducing an extended LULUCF felxibility.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The green transition is absolutely necessary, but it can only take place if the required industrial and economic changes do not impose a disproportionate burden on society and do not threaten the competitiveness of EU businesses or endanger thousands of jobs. It is crucial that the transition to sustainable technologies does not disproportionately hamper economic growth or lead to mass closures and job losses in Europe, as this would potentially change public opinion about transition. It is essential for the transition that no one left behind and public support to tackle climate change and move towards net zero remain strong in all Member States. Such a continuous support is essential for decision makers in order to set predictable regulatory environment and for companies investing in the future. Certain changes proposed in the revision of European Union Emissions Trading System (EU ETS) threaten the competitiveness of the European industry by imposing a disproportionate burden and obligations to comply within a very short time. To achieve higher ambition by the end of the decade, the EU needs a viable and solvent industry to lay the technological and infrastructural foundation of a net zero economy. In order to EU industry could successfully meet the challenges greater than ever, it is crucial to maintain an effective carbon leakage protection thus preserve the industry’s competitiveness and liquidity by avoiding the drastic decrease of the share of free allocation. The EU ETS should also support decarbonization and circularity in every possible way, including the compensation of the increasing indirect carbon cost which is halting electrification, and creating a level playing field for waste recycling. Please find attached MOL Group's recommendations after the first assessment of the ETS revision under the Fit for 55 package.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

26 Jul 2021

MOL Group supports the the goals of the Paris Agreement and the Green Deal’s ambition for climate neutrality in 2050. We welcome the opportunity to provide input to the public consultation on this implementing regulation which we deem important as an enabler to provide the necessary lower carbon fuels needed to help to reduce the GHG emissions from the transport sectors in line with the Green Deal targets. To avoid confusion and to provide a predictable regulatory environment for the future investments in low carbon fuel technologies we would like to make following recommendations for amendments to the implementing regulation: In Annex IV on Minimum requirements on the method for certifying waste and residues we have noticed that not all the wastes and residues included in Annex IX of the Directive RED are included in Annex IV of the regulation. The regulation stated that: “When deciding if a substance can be considered as residue or waste, both economic operators and auditors must use the list set out in this Annex, which is based on the substances/materials included in the revised list in Annex IX to Directive (EU) 2018/2001” To avoid confusion and to be consistent with the Regulation we are asking for the inclusion of the wastes and residues listed in Annex IX of RED II. in Annex IV. of this regulation and in particular we strongly support the inclusion of Saw dust, biomass fraction of wastes and residues from forestry and forest-based industries, namely, bark, branches, pre-commercial thinnings, leaves, needles, tree tops, cutter shavings, black liquor, brown liquor, fibre sludge, lignin and tall oil.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

28 May 2021

MOL Group is committed to help the EU reach its objectives under the Paris Agreement and has already started an evolution along different low-carbon pathways. There are many examples of ongoing innovative R&D and early deployment projects illustrating how the industry could evolve whilst mitigating climate change risks. MOL Group welcomes the new EU Taxonomy proposal, and also the new rules on corporate reporting, which could lead to a more transparent reporting scheme, however we are on the opinion that the chosen methodology setup for non-financial disclosure does not impose inappropriate burden and administrative costs on the industry as well as on consumers. • We are in the opinion that the reporting obligation should be established only after all environmentally sustainable economic activities are clearly stated and the methodologies for their calculation are approved and published. If a company is forced to report incomplete 2021 figures for its sustainable activities, it will significantly damage the company in the eyes of investors and will result in real economic losses. We also believe that the requirement in Article 9, Nr. 3 that requires non-financial undertakings to disclose the key performance indicators covering the previous five reporting periods to be overly burdensome. This additional information is readily available to those interested in the prior-period reports. Therefore we are not supporting that the reporting template includes the datas from the previous five years. • The proposed granularity of disclosures, in particular those with respect to capital expenditures, will very likely require preparers to publish information that is commercially sensitive and presents valuable information for competitors. Many companies listed in the EU capital markets compete on a worldwide basis with competitors that are located and listed in jurisdictions outside the European Union that do not have comparable disclosure requirements. These proposed disclosure requirements would put companies in the European Union at a competitive disadvantage. • We found it very hard to measure how much of the electricity we consume is from renewable source, and it is also depends on the electricity mix of the given country, which could give Central and Eastern europe countries significant competitive disadvantage. • At point 1.1.2.1 we would like ask for clarification. Additions according to IAS 23 – Borrowing cost shouldn’t be included in the list of cost which shall cover CapEx? • At point 1.1.3.1 we would like to ask for clarification. Does this point covers direct employing costs or related tax fees? • The taxonomy-related disclosures should be implemented according to existing accounting standards including the concept of materiality as defined by the conceptual framework paragraf 2.11 and the companies’ accounting policy, in order to keep the additional burden for companies to a minimum. To conclude, non-financial reporting requirements should be clear, harmonized, proportional to the size of the company and coherent with the EU acquis.
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Response to Enhancement of European policy on critical infrastructure protection

8 Apr 2021

MOL Group’s draft input to critical infrastructures roadmap consultation: Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach. We welcome the revision of the ‘Directive on the identification and designation of European critical infrastructures and the assessment of the need to improve their protection’ (2008/114/EC), as we can see some areas where improvement is possible. • As an example, we would like to mention the problem of duplication of administrative burden: there are installations which fall under Seveso Directive (2012/18/EU) and thus have to comply with administrative tasks, for example preparation of emergency plan and safety report. We believe that if an ECI installation falls under Seveso Directive as well, it should not be required to prepare an ECI plan in addition, with the same content (all additional requirements could be included in a complementary annex). We can also see some room for improvement in developing better guidance to improve harmonized interpretation of the Directive. • We can see from the proposed text that waste water treatment facilities are under the regulation. Based on the same principles, we are asking for the inclusion of waste management facilities. • We are in the opinion that regarding the selection and recruitement processes (e.g. setting criteria for vetting of staff – we think such details should be left for the competence of companies) • In respect to the Green Deal and the outlined direction in respect to energy industry, it might also worth defining the output of energy producers which would be under the Directive as the Green Deal and respective revisions of the energy directives count on some degree of decentralization of energy production (e.g. ”prosumers”) or smaller non-critical installation where such measures would not be viable. • Alignment of respective directives in respect to the Directive on the resilience of critical entities and the Communication the EU Security Union Strategy. As the goal of the revision is an update do to developmental advancement and lessons learnt, we believe that the revised Directive should reflect on cross sectorial approach as well, and therefore including the field of circular economy and respective sectors. Also, the recent crisis showed us that security is not just about security of energy supply and transportation but also in respect to supply of vital chemicals, protective materials, etc.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

MOL Group, being amongst the top ten polymer producers in Europe and the biggest in Central Europe, is committed to helping the EU in reaching its circular economy objectives and welcomes the initiative’s aim to modernise EU rules on food contact materials. We support the goals to ensure food safety and a high level of public health protection, while at the same time encouraging innovation by promoting safe reusable and recyclable solutions. Our position is outlined in the attached file.
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Response to Updating the EU Emissions Trading System

25 Nov 2020

Please find attached MOL Group's position on the consultation.
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Response to Revision of the EU Emission Trading System Directive concerning aviation

28 Aug 2020

MOL Group’s answers to the public consultation MOL Group welcomes the European Green Deal and its direction to tackle climate change and make Europe the first climate neutral continent and appreciates the possibility to contribute to the IIA of ETS revision concerning aviation. As general remarks concerning the emission reduction potential and different regulatory options for the European aviation sector and other sectors linked to the aviation sector through different services, in particular the aviation fuels sector, we believe that: • along the objective of reducing GHG emissions, the preservation of a global level playing field and the global competitiveness of the European aviation industry should be the driving principles; • the impacts of all different European initiatives recently launched for the aviation sector should be assessed in combination. As an example: imposing increased burden through the ETS, together with a new carbon tax under the Energy Taxation Directive would substantially worsen the already extremely difficult situation of the aviation sector and could seriously hamper its recovery from the impacts of the COVID-19 pandemic. Aviation is an important global sector, where the best way to address a global challenge is a global approach. From this perspective we support the CORSIA initiative and welcome the Commission’s proposal to take it into account when regulating the European market. In the context of CORSIA we encourage the Commission to further advocate for setting a well-functioning, obligatory, global scheme. Such a global scheme should fully ensure a level playing field for the European aviation sector and all other sectors supplying aviation, in particular the aviation fuels sector. Therefore, regarding the options outlined in the Commission IIA document, we prefer option 3 (CORSIA only), which ensures compliance with the key principles highlighted above, in particular having a global initiative and thus minimising resistance from players outside of Europe. In case - for whatever reason - a global arrangement cannot be reached, we believe that option 5 (ETS-CORSIA „mix”) could also contribute sufficiently to the global GHG reduction efforts and still take into account the competitiveness of European industry, therefore it is MOL Group’s 2nd choice. Regarding the EU ETS, we think that the long-term goal should be to converge to a single carbon price in the economy and to merge the EU ETS with any future aviation ETS scheme. Nevertheless, if an ETS-like scheme is to be used for kick-starting low-carbon investment and achieving effective emission reductions, merging sectors with significantly differing carbon abatement costs under the same cap-and-trade scheme is neither cost efficient nor effective, and would result in cross-financing of new technologies between such sectors. The cost of carbon abatement technologies available for the aviation sector are at a different scale than those available for power generation and energy intensive industries. Therefore, even if regulated by a cap-and-trade system, in the short/medium term aviation should not be brought under the EU ETS, and certainly not before 2030. The carbon abatement costs (carbon prices under the various cap-and-trade schemes), however, are desired to converge, along with the prospect of later merging the various sectoral schemes. Regarding the share of auctioning volumes for aviation under an aviation sector specific cap-and-trade scheme, we are of the opinion that option 4 would ensure harmonisation of processes among different sectors, therefore we support this option. This option provides sufficient graduality and predictability for the aviation sector and other sectors connected to it and would target a similar ratio of auctioning and free allocation than the EU ETS. This would possibly make the future merger of the schemes easier.
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Response to Enhancement of European policy on critical infrastructure protection

7 Aug 2020

MOL Group’s input to critical infrastructures roadmap consultation Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach. We welcome the revision of the ‘Directive on the identification and designation of European critical infrastructures and the assessment of the need to improve their protection’ (2008/114/EC), as we can see some areas where improvement is possible. As an example, we would like to mention the problem of duplication of administrative burden: there are installations which fall under Seveso Directive (2012/18/EU) and thus have to comply with administrative tasks, for example preparation of emergency plan and safety report. We believe that if an ECI installation falls under Seveso Directive as well, it should not be required to prepare an ECI plan in addition, with the same content (all additional requirements could be included in a complementary annex). We can also see some room for improvement in developing better guidance to improve harmonized interpretation of the Directive. The IIA outlines 4 options for the potential revision, however, the information provided in the inception impact assessment (IIA) is not sufficient for us to understand the exact content of the four options. At this conceptual depth we can see the relevance and the added value of option 4’s shifting focus on the essential services. However, we would need more information to understand this concept clearly, and there are some other elements of this option as well, which raise concerns for us (e.g. setting criteria for vetting of staff – we think such details should be left for the competence of companies). As a summary, on the basis of the information outlined in the IIA, we can see some benefits in all options. We would be happy to be consulted during the elaboration of the final option.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

CONTRIBUTION OF MOL GROUP MOL Group welcomes the objective of the initiative to establish a well-functioning market for secondary raw materials through fully harmonised rules on packaging while tackling negative impacts on environment and health from packaging and packaging waste. MOL Group shares the opinion that without changing the essential requirements for packaging “significant packaging waste prevention is not expected” to be realised. In addition to the measures listed in the IIA document it is proposed to add some additional elements, which are very important for strengthening the secondary raw material market: • when setting the new definition for “recyclable packaging” innovative new recycling technologies including dissolution (or solvent based) recycling, chemical recycling should also be included. These technologies could bring a solution to the challenge with current trends highlighted in the inception impact assessment regarding difficult-to-recycle packaging such as multilayer composite packaging. In our opinion therefore, new regulatory requirements should promote and encourage the introduction of new solutions and innovative technologies. • it is proposed to introduce harmonised requirements for marking techniques to be used for identification of different plastics in mixed waste streams during the operation of sorting technologies. • a more harmonised set of end-of-waste definition would contribute to reducing administrative uncertainty and barriers to free movement of secondary raw materials. • standardisation of methodologies for identifying recycled content of materials preferably through mass balance chain of custody solution would be needed to ensure cost efficient and transparent compliance with future targets for recycled content. Proposals to the impact assessment: When assessing the impact of measures for reduction of waste and simplified packaging MOL Group is on the opinion that particular attention needed on food safety, food contact materials as well as on food waste generation. • Food safety aspects became even more critical during the COVID-19 pandemic. This phenomenon is expected to stay with us in the future, consequently we propose to include in the assessment the feasibility of reduced food packaging, while at the same time the EU has to ensure food safety during similar circumstances. Based on our experience COVID caused un unexpected rapid and radical growth in food packaging. • It also needs to be taken into account what recycling technologies are in place or are under development which are able to handle different types of plastic packaging including complex materials containing several polymers. We consider it is important that the transformation be carried out in such a way as to maintain the benefits and achievements provided by the products concerned. The changes must not cause setbacks in the field of product safety or health protection either. As a company belonging to the European chemical industry we would like to be part of the transformation needed to make the economy more circular as this is the industry where we can use new, innovative solutions to extend the life cycle of products and turn waste products that cannot be reused into raw materials, i.e. bringing them back into the economy. The initiative of facilitating the market for secondary raw materials is important piece in achieving this.
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Response to 2019 Amendment to the Union Customs Code Implementing Act

21 May 2020

The amendment of Article 321 UCC-IA contains a new paragraph (6). This paragraph says ‘6. Non-Union goods shall be deemed to be in temporary storage from the moment the Union transit procedure has ended in accordance with point (a) or points (b)(i) or (ii) of paragraph 5.’. We are of the opinion that the goods transported via fixed installation are only to be deemed in temporary storage without physical storage in a temporary storage facility. Therefore it is only a legal fiction to extend the temporary storage to goods arrive in the EU via pipeline. For the sake of clarity we would like to be sure that no temporary storage facility is required and no guarantee shall be provided in this certain situation. In order to be clear we would propose to set out the paragraph as follows: 6. Non-Union goods shall be deemed to be in temporary storage, from the moment the Union transit procedure has ended in accordance with point (a) or points (b)(i) or (ii) of paragraph 5, without any customs formalities. If our proposal is not acceptable, we would like to ask to clarify this issue in the Guidance on Customs Formalities on Entry and Import into the European Union published on the Commission website.
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Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · COVID 19 economic impact on Energy intensive industries

Meeting with Thierry Breton (Commissioner) and

7 Apr 2020 · Potential issues in dealing with COVID-19

Response to Strengthening the principle of equal pay between men and women through pay transparency

31 Jan 2020

MOL Group supports the initiative of strengthening the principle of equal pay between men and women. Gender being one of the four strategic pillars of MOL Group’s Diversity&Inclusion strategy together with age, wellbeing and changed working capacity. Having clear commitments and KPIs in the recruitment/selection process, MOL makes concrete steps to ensure equal treatment and overcome any unconscious biases in selection and hiring process. The key pillar of MOL Group’s Strategy 2030, is that we put our people first and here is no differentiation between men and women when it comes to salaries or promotions/job applications. The gender pay gap is a complex issue with many root causes, which are often interrelated. Namely, certain professions, sectors are male dominant (e.g. Oil&Gas/Energy). Comparisons just men versus women can create misconceptions about pay equity and need detailed understanding. In our opinion to effectively measure and then tackle the inequalities between man and women clear and balanced methodology is needed in the upcoming legislation. The methodology on how to measure the differences should be market based and should take into account the sectoral differences, be clear about key definitions and consider local market practices as. The basis of the methodology should be a root cause analysis. When we are talking about transparency we need to consider data protection and sensitivity of pay strategies in the market competition. It has to be well considered what is possible and worth to publish and what mechanisms should ensure consistent use of the defined metrics. As in terms of daily process management within large companies with hundreds of job roles, job types, feasible needs to be built up focusing more on reporting and policy making.
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Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Michael Hack Politikberatung

6 Feb 2019 · Plastic Recycling

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

31 Jan 2019 · discussion on operations in Croatia

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

We support the circular economy concept aiming at the use of much more circular products, to identify those products which could be reused, repaired and recycled. It is especially important to extend EU regulation to these products, due to the increasing amount of waste produced in the EU, such as waste tyres. Reuse of tyre rubber as raw material could be a good method to reduce the amount of waste. However, we agree that the methods how to reuse tyres could be better harmonized across the EU. As an appropriate action we suggest adoption of EU standards on rubber bitumen, so that waste tyres are recycled in a sustainable way rather than landfilled. According to our opinion, suitability of crumb rubber produced from waste tyres should be separately assessed rather than considered to be restricted. There are certain rubber bitumen production processes (used for asphalt mix production and road construction) where technical, environmental and health aspects are not valid. Justification: 1. Crumb rubber can be produced by grinding of waste (used) tyres. Rubber bitumen can be manufactured using crumb rubber and can be used for asphalt mixture production. This asphalt mix can be used for long lasting and high quality asphalt road construction. In the manufacturing process of rubber bitumen, the crumb rubber and its components are embedded in the bitumen, consequently the crumb rubber and its components are fixed in the bitumen-matrix finally. As a result, the bitumen-matrix provides protection against the release of the components, like PAHs, contained in the crumb rubber. 2. The thickness of the asphalt pavements depends on the construction, typically 4-30 cm. The wheels of vehicles are in contact with the surface of the asphalt road causing abrasion both of the tyre tread and the surface layer of the asphalt road. Over a period of time, the amount of pollutants entering to the environment from tyre tread due to the wear off exceeds by several orders of magnitude the amount of rubber components that may release from the asphalt road surface as a result of its abrasion. 3. The crumb rubber contained in the asphalt road surface represents a minor fraction of total crumb rubber presents in the whole asphalt layer(s) (<0,5%). Contrarily, we recommend taking into account the environmental advantage together with road quality and durability benefits, which can be achieved by using rubber bitumen for asphalt mixture production and road construction. Bitumen as a primary raw material can be partially replaced by a secondary, waste-based material derived from waste tyres. Moreover, bitumen modifying agent of which production needs significant energy consumption and fresh base materials can also be replaced or partially replaced by the waste-based crumb rubber. In order to utilize large volume of rubber waste as material recovery, production of rubber bitumen and its use for road construction is one the best options based on the state of the art. In addition, it is possible to construct longer-lasting roads having less maintenance need resulting safer traffic than using conventional bitumen binders.
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Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

28 Nov 2017 · Meeting with Mr Marton Palmai

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

4 May 2015 · Presentation of activities, Central and Easter Europe