Polish Confederation Lewiatan
Lewiatan
The Polish Confederation Lewiatan (Lewiatan) is an influential Polish business organisation.
ID: 819446791825-58
Lobbying Activity
Response to Advanced Materials Act
13 Jan 2026
The Advanced Materials Act (AMA) responds to the real and well-diagnosed challenges facing the European Union industry, in particular in the context of the competitiveness and resilience of supply chains. As entrepreneurs represented by the Polish Confederation Lewiatan, we fully support the direction of action proposed by the European Commission, especially in terms of shortening the time to market of innovative materials, strengthening research and development facilities and improving the conditions for the implementation of industrial solutions with high added value. The role of advanced materials in the design of food contact packaging is of particular importance, which must simultaneously meet the requirements of the PPWR regulation, be recyclable and ensure adequate protection, barrier properties and food safety. Achieving this balance is not possible without intensive research into new materials and packaging structures that combine functionality comparable to multi-material packaging with the ability to be efficiently recycled in existing waste streams. In this context, the AMA can play a key role in removing the regulatory and technological barriers that currently slow down the implementation of such solutions. Strengthening the role of science in the identification, assessment and regulation of high-risk chemicals, in particular PFAS referred to as 'forever chemicals', should also be an important element of the initiative. Research into safe alternatives to these substances needs to be supported, while ensuring that new solutions are reliably verified for their impact on human health and the environment. Only a science-based approach and a life-cycle assessment of materials will avoid unintended substitution effects and ensure a high level of consumer protection. We support activities aimed at developing innovations in the area of circular economy, efficient use of materials and sustainable development. Advanced materials should not only offer new or improved functional properties, but also be designed to reuse, recycle and minimize the use of virgin raw materials. In particular, the development of materials with properties similar to multi-materials and at the same time recyclable on an industrial scale should be supported. At the same time, attention should be paid to the growing problem of importing materials from markets outside the EU, which declare compliance with EU standards only at the formal level. An example is recycled PET imported from outside the EU, which in practice turns out to be a "virgin" material. This material competes on price with recycled material from EU deposit schemes, thus increasing the maintenance costs of these schemes. This situation undermines market confidence, weakens European producers and threatens the development of a genuine circular economy in the EU. The AMA should support solutions that ensure a level playing field and effective and reliable verification of the compliance of materials with EU requirements. We also strongly support the simplification of regulatory and administrative procedures, while maintaining a high level of health and environmental protection. Shortening approval processes, developing regulatory sandboxes and better coordination of sectoral regulations are key to accelerating the deployment of innovations and increasing the EU's investment attractiveness. A key element of the initiative's success will be to increase research and innovation capacity in the EU, including funding research infrastructures and programmes to support entrepreneurs in testing and scaling new material solutions. Of particular importance are instruments addressed to entrepreneurs, enabling pilot implementations, industrial tests and market validation of advanced materials. Only by combining regulatory ambitions with real financial and organisational support will it be possible to build a strong, innovative and sustainable ecosystem of advanced materials in the European Union.
Read full responseResponse to Circular Economy Act
6 Nov 2025
We support the EU Commission ambition to accelerate the transition to a circular economy, while ensuring EU-wide harmonization and simplification. We encourage the EC that the Circular Economy Act (CEA) focuses on: (i) simplification and harmonization of EPR minimum requirements and reporting; (ii) measures to increase supply of high-quality secondary raw materials and (iii) development of the EPR one-stop shop (EPR OSS). The table below presents a summary of our key recommendations for the CEA. More detailed in the attached file: 1. Extended Producer Responsibility (EPR) EU-wide harmonization of EPR minimum requirements, by focusing on management of EPR by producers, transparency in fee setting, and harmonized eco-modulation primarily based on recyclability. State-run Producer Responsibility Organisations (PROs) should not be permitted. Simplification EPR reporting by mandating an EU-wide reporting format for EPR declarations and creating an EU portal where economic operators can access and fill in the EPR declarations for all Member States. 2. EPR one-stop shop (EPR OSS) Establishment an online platform to register and access national EPR schemes (i.e., available for all EU-Member States); Reduce EPR fragmentation. 3. Waste handling Improve collection, sorting, and recycling infrastructure, and enable new recycling capacities and technologies fit for different waste streams. Ensure agile and harmonized EU waste shipment rules including green-listing of non-hazardous plastic waste and streamlined procedures for recycling trials. 4. Construction sector Promote circularity in construction by reducing use of virgin materials and maximizing reuse and recycling of construction and demolition waste. Utilize existing technologies for glass, mineral wool, and gypsum recovery to commercialize circular solutions and achieve economies of scale in closing material loops. 5. Demand measures Leave the setting of demand measures (recycled or bio-based targets) to the appropriate EU product legislation (e.g. ESPR, PPWR, ELVR, CPR, etc.). 6. Supply of secondary raw materials Set up an ex-ante assessment of the compatibility of national technical regulations with the Single Market through a revision of the EU Directive 2015/1535 (Single Market Transparency Directive), Define a technology-neutral mass balance methodology Speed up up the establishment of EU-wide end of waste criteria Directive). 7. Recycling technologies and feedstocks Recognize the complementary role of diverse recycling and feedstock technologies mechanical, physical (solvent-based), chemical (e.g. pyrolysis, gasification), organic (biogasification, composting), and biotechnology-based processes. Support scale-up of alternative feedstocks (bio-based, recycled, CCU-based) through stable long-term legislation, flexible mass-balance crediting (ISO 22095 / DIS 13662), and industrial symbiosis within EU Circularity Hubs.
Read full responseMeeting with Maroš Šefčovič (Commissioner) and
28 Oct 2025 · Priorities of the EU’s trade agenda
Response to Heating and cooling strategy
9 Oct 2025
Position Paper of the Union of Private Energy Sector Employers, member of Polish Confederation Lewiatan, on the new Heating and Cooling Strategy. We welcome the intention to adopt a new European Unions Heating and Cooling Strategy and the launch of the consultation process by the European Commission. As the Commission rightly notes, consumption for heating and cooling accounts for half of the EUs energy consumption, and the energy transformation of this sector is progressing much slower than in the case of electricity. Therefore, it is very important to support the sector in decarbonisation efforts. Poland perfectly understands this perspective: the country has a high demand for final energy in heat, a strong industrial sector and developed district heating, which supplies heat to approximately 15 million consumers. Most of them are households. The high share of fossil fuels in heat production in Poland makes the transformation of the sector a huge challenge for the country. The change in the production mix is progressing: district heating companies are conducting investment processes in the field of decarbonisation. Many of them have submitted Climate Neutrality Plans, in which they declared to achieve the emission reduction target for 2030 and subsequent years. However, the transformation is not proceeding in a systematic and uniform manner across the country: some enterprises, especially SMEs, struggle with limited access to capital and low profitability indicators, which limits their investment potential. We also see the need to revise the existing Heating and Cooling Strategy, which will take into account: significant regulatory changes adopted in recent years, changing market conditions and the availability of new technologies and business models in district heating. We agree with the important thesis contained in Directive (EU) 2023/1791 on energy efficiency (EED), according to which high-efficiency cogeneration and the use of efficient district heating and cooling systems have significant potential for primary energy savings in the Union. In this regard, we see the need to emphasize that increasing energy efficiency has been and continues to be one of the pillars of the climate and energy policy of EU countries, so support for projects serving to improve energy efficiency should be provided as a priority. The energy-efficient district heating systems distinguished in the Directive are equally important: they provide stable and economically optimal heat supply for many consumers. Following the revision of the EED, the requirements for efficient systems increasingly take into account the EUs environmental objectives, which makes them widely treated as a signpost for district heating. However, in the current regulatory and market realities, the implementation of the set goals at the assumed pace carries the risk of stranded assets, a sharp increase in heat prices and deepening the energy poverty. Therefore, below we present proposals which, in accordance with our best knowledge, could lead to achieving climate goals at an optimal pace, without excessively burdening end consumers with the cost of transformation. Full position in the attached file.
Read full responseResponse to General revision of the General Block Exemption Regulation
6 Oct 2025
W załączeniu przekazuję uwagi zebrane wśród członków zrzeszonych w Konfederacji Lewiatan, dotyczące: 1. rozdziału 1 GBER (w zakresie obowiązku ewaluacji, zasad przyznawania pomocy przedsiębiorstwom w trudnej sytuacji, efektu zachęty), 2. rozdziału 3 GBER w części dotyczącej regionalnej pomocy inwestycyjnej (kwalifikowalność wydatków na wartości niematerialne i prawne) 3. rozdziału 3 GBER w części dotyczącej pomocy na ochronę środowiska (wymóg wyliczania kosztów pomocy w oparciu o scenariusz alternatywny, pomoc na środki wspierające efektywność energetyczną w budynkach, pomoc na efektywne gospodarowanie zasobami, wsparcie inicjatyw Clean Industrial Deal) 4. rozdziału 3 GBER w części dotyczącej pomocy na infrastrukturę szerokopasmową (ustalanie cen dostępu hurtowego na dotowanych sieciach szerokopasmowych, dodanie pomocy na rzecz odporności sieci szerokopasmowych, dodanie wsparcia na cyfrową odporność przedsiębiorstw).
Read full response8 Jul 2025
Abbreviated position of the Association of Private Energy Sector Employers on the revision of the EU ETS The Association of Private Energy Sector Employers organises the biggest private entities in energy, energy efficiency and heating sectors in Poland. Some of our installations have been included in the ETS 1 system for years. We have invested in renewable energy sources, however, we are still affected by sudden fluctuations in the price of emission allowances. Therefore, as part of ongoing consultation, we provide our position on the ETS revision. 1. Introduction of an EUA price corridor (with a floor price and a cap price) with dynamic regulation of the supply of allowances. When the EUA price starts to approach the upper threshold, an additional pool of emission allowances will go to auction from the reserve. When the EUA price approaches the lower limit, some allowances will be diverted from the market to the reserve. This will protect consumers and producers from sudden price shocks and limit speculative practices. 2. Continuation of the transition with additional free allowances for district heating until 2035. An additional 30% of free allowances should be granted subject to the submission of further Climate Neutrality Plans (CNPs). This will encourage an increase in the investment potential of companies. In a broad perspective, it will contribute to improving energy efficiency in the district heating sector while fulfilling the principle of a just transition. 3. Extending the implementation of the investments included in the Climate Neutrality Plans until 2032, i.e. the deadline for the second performance audit of the implementation of the CNP. This will significantly reduce the risk of some investments not being realised within the currently required timeframe. At the same time, it will increase the number of efficient district heating systems in Poland. 4. Leaving the current capacity threshold for stationary installations included in the ETS 1 scope at 20 MWt, which will reduce the administrative and financial burden for, among others, small heating plants that will be included in ETS 2 anyway. 5. Mitigating the negative effects of ETS 2 implementation by: delaying the implementation of the scheme until 2035, leaving the price cap in place for the entire duration of the scheme and granting free emission allowances to efficient district heating systems. This will better protect consumers from sudden increases in energy prices, promote efficient district heating systems and encourage decarbonisation of the inefficient ones. 6. Reducing the impact of the ETS on waste-to-energy installations the system as it stands is inadequate to the particular features of these installations, so WtE plants should not be covered at all. Alternatively, WtE plants could be considered for inclusion in the ETS from 2035 onwards, but only on the condition that landfills are also included in the system and that regulations supporting the waste hierarchy, such as extended producer responsibility, are implemented. This is particularly important for countries such as Poland, where the total installed capacity of WtE plants is insufficient to meet the objectives of a closed-loop economy too much waste is directed to landfills. 7. Introducing an obligation to report on which purposes and activities funds from the sale of allowances by Member States are spent on. This will increase the effectiveness of the requirement in the ETS Directive that 100% of the funding should go towards energy transition. 8. Extension of the Modernisation Fund until 2035. This will allow some of the funds from the sale of allowances to continue to be spent efficiently in countries where the transition challenges are hardest to overcome. 9. Allowing for the calculation of negative emissions of biomethane for district heating systems in the EU ETS, provided that the emission rate indicated in the proof of sustainability is below zero.
Read full responseResponse to Critical Medicines Act
27 Feb 2025
We fully support the work on the Critical Medicines Act. Our organization's position is attached.
Read full response