Senior Europa
Senior Europa, operating under the commercial name "Kveloce", is an international consultancy specialising in research, development, and innovation.
ID: 897470052201-15
Lobbying Activity
Response to Advanced Materials Act
13 Jan 2026
We welcome the opportunity to provide feedback to the evidence collection supporting the preparation of the upcoming Advanced Materials Act and appreciate IAM-Is role in structuring industry input on key regulatory bottlenecks. Overall, we consider the proposed orientation highly relevant and timely. In addition to the technical, industrial and regulatory challenges already identified, we would like to emphasise the importance of further strengthening the integration of Social Sciences and Humanities (SSH) perspectives within the future regulatory framework for advanced materials. In particular, a more systematic inclusion of stakeholder engagement mechanisms throughout the policy cycle including industry, SMEs, public authorities, end-users, civil society organisations and regional actors would enhance the effectiveness, legitimacy and implementation of the regulation. Early and continuous stakeholder involvement can help anticipate unintended effects, improve regulatory coherence across value chains and support smoother market uptake of advanced materials, especially in strategic and sensitive sectors. Particular attention should be also given to education and workforce challenges and needs, where the participation of relevant stakeholders is of paramount importance. Moreover, we believe that the impact assessment framework underpinning the upcoming regulation should adopt a truly holistic approach. While environmental performance and circularity aspects are rightly prioritised, impact assessments should also consistently address economic and social dimensions, in line with the Commissions Better Regulation principles. In this context, the systematic application of Life Cycle Costing (LCC) and Social Life Cycle Assessment (S-LCA) alongside environmental LCA within a Safe and Sustaineble by Design (SSbD) perspective would allow for a more comprehensive evaluation of policy options and regulatory measures. Such an integrated assessment approach would support a better understanding of cost structures, competitiveness implications, investment risks, social impacts on employment and skills, regional effects, and overall societal acceptance of advanced materials technologies. It would also help identify potential trade-offs between sustainability objectives and industrial competitiveness at an early stage, thereby contributing to more proportionate, evidence-based and future-proof regulation. Finally, we consider that reinforcing SSH integration, stakeholder engagement and multi-dimensional impact assessment within the SSbD current paradigm would not only improve the quality of the regulatory framework but also support the broader EU objectives of strengthening industrial resilience, fostering innovation, and ensuring that the green and digital transitions are socially fair and economically viable. We therefore encourage IAM-I and the Commission to explicitly reflect these aspects in the design and implementation of the upcoming Advanced Materials Act. Documents: A report on a workshop implemented with more than 80 registered participants on the current challenges and opportunities to strengthen Social LCA within the implementation of SSbD.
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