OpenLobby.EU
Explore

Solvay SA

Solvay SA is a Belgian chemical company with €4.9 billion in net sales, employing over 9,000 people across 45 industrial sites in 41 countries, specializing in soda ash, hydrogen peroxide, and essential chemistry for diverse industries.

Lobbying Activity

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships)

2 Dec 2025 · EU LATAM REE supply chains

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Unknown Organization and Unknown Organization

26 Nov 2025 · EU LATAM REE supply chains

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Nov 2025 · Rare Earths

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Stellantis and

18 Nov 2025 · EU – Latin America Supply Chains in critical raw materials

Meeting with Bart Groothuis (Member of the European Parliament)

14 Nov 2025 · Critical raw materials, industrial and trade policies

Solvay urges strict rules for foreign carbon price recognition

25 Sept 2025
Topic — Rules for converting carbon prices paid in third countries into CBAM certificates.
Message — Solvay wants a conservative approach to recognizing carbon prices paid in non-EU countries. They argue for calculating net costs by subtracting any local rebates or free allowances. The company also demands high transparency to ensure data is verifiable and not underreported.123
Why — A strict approach protects Solvay from competitors benefiting from hidden subsidies or weak carbon markets.45
Impact — Foreign importers using opaque or subsidized carbon systems would face significantly higher border taxes.67
Read full response

Solvay Urges Full Free Allowances for Exported CBAM Products

25 Sept 2025
Topic — Rules for adjusting carbon border mechanism certificates as free emissions allowances phase out.
Message — Solvay requests a CBAM benchmark methodology that replicates the EU ETS system. They specifically demand maintaining 100% free allowances for European products destined for export markets.12
Why — This would protect their international market share and ensure long-term decarbonization investments remain profitable.34
Impact — Foreign producers would face stricter verification requirements and reduced allocations when using green technologies.56
Read full response

Solvay urges CBAM focus on direct emissions and strict defaults

25 Sept 2025
Topic — This consultation defines the methodology for calculating embedded carbon emissions during the CBAM definitive period.
Message — Solvay recommends limiting the scope to direct emissions and heat generation. Electricity emissions should be calculated using fossil fuel intensity averages without exemptions. Default values should reflect the worst performing producers to prevent resource shuffling.123
Why — High default values and strict monitoring prevent foreign competitors from undercutting European industrial prices.45
Impact — Efficient foreign producers lose their competitive advantage if forced to use fossil-fuel averages.6
Read full response

Solvay calls for realistic industry 2040 climate targets

12 Sept 2025
Topic — The initiative amends the European Climate Law to include 2040 targets.
Message — Solvay requests that the 2040 climate target applies equally across all economic sectors. They urge the EU to change carbon market rules so industry reaches a 90% reduction by 2040 instead of zero by 2039. They also call for more financial aid and infrastructure for carbon capture technologies.123
Why — Aligning industry targets with other sectors would lower immediate compliance costs.45
Impact — Climate advocates lose as delaying industry targets risks missing broader neutrality goals.6
Read full response

Solvay Urges EU to Boost Compensation for Indirect Carbon Costs

5 Sept 2025
Topic — Technical updates to state aid rules for indirect EU Emissions Trading costs.
Message — Solvay calls for an EU-wide budget to ensure equal treatment for all industrial consumers. They request extending compensation to indirect electricity use and removing restrictive conditions.123
Why — Expanding aid intensity to 100% and reducing administrative burdens would significantly lower costs.45
Impact — Taxpayers and environmental progress lose if subsidies increase while green requirements are scrapped.67
Read full response

Meeting with Aurel Ciobanu-Dordea (Director Environment) and Orano and Alliance des Minerais, Minéraux et Métaux

9 Jul 2025 · Exchange of views on waste codes for permanent magnet waste

Solvay urges EU to reform Innovation Fund grant formula

8 Jul 2025
Topic — The consultation evaluates the effectiveness and financial operations of the EU Innovation Fund.
Message — Solvay wants the grant formula modified to stop deducting operational benefits from aid. This methodology currently fails to de-risk investments and creates a significant financial gap.12
Why — This change would allow Solvay to secure much larger grants for its investments.3
Read full response

Solvay urges EU to protect industry and delay emission caps

8 Jul 2025
Topic — Review of the EU Emissions Trading System and its market stability reserve.
Message — Solvay requests the maintenance of free pollution permits and financial compensation for electricity costs. They advocate for shifting the zero-emissions target from 2039 to 2050.12
Why — A slower reduction pathway would lower immediate costs and ensure industrial viability.3
Impact — Environmental groups lose as delaying zero-emission targets slows down climate action progress.45
Read full response

Meeting with Ana Maria Blass Rico (Acting Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

23 Jun 2025 · Substitution of SVHCs

Meeting with Ana Maria Blass Rico (Acting Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

23 Jun 2025 · Introduction to Solvay Substitution of SVHCs Regulatory outlook

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

17 Jun 2025 · EU Rare Earth and China

Solvay urges EU investment framework for small modular reactors

12 May 2025
Topic — This consultation maps investment needs across all stages of the European nuclear lifecycle.
Message — Solvay proposes a simplified licensing process and dedicated investment framework for modular reactors. They request that nuclear power receive the same financing and communication tools as renewable energy. Furthermore, they call for state aid and new funding instruments to support industrial decarbonization.123
Why — A supportive framework would lower decarbonization costs for energy-intensive industrial processes.4
Impact — Renewable energy industries may lose exclusive access to climate-related funding and state subsidies.5
Read full response

Solvay urges EU to prioritize industrial decarbonization funding

12 May 2025
Topic — Evaluation of operating rules for the Modernisation Fund regarding climate action.
Message — Solvay demands industrial decarbonization be formally recognized as a priority investment for lower-income states. They advocate for repurposing the Fund to support the Clean Industrial Deal.12
Why — This would secure essential co-financing for Solvay's biomass projects and protect its competitive position.3
Impact — National governments could face financial sanctions for failing to facilitate investments in industrial decarbonization.4
Read full response

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Deutsche Bank AG and

12 Mar 2025 · Meeting of the South America Critical Raw Materials (CRM) Coalition of the Willing – Dialogue with private and public sector stakeholders, and financial institutions on sustainable critical raw materials value chains in Latin America.

Solvay demands fair emission calculations for low-carbon fuels

25 Oct 2024
Topic — The consultation defines a methodology to certify greenhouse gas savings for low-carbon fuels.
Message — Solvay requests removing upstream natural gas emissions to ensure consistency across technologies. They also want to use specific electricity supply contracts rather than national averages.12
Why — These changes would allow the company to report lower emissions and avoid regulatory disadvantages.34
Impact — Renewable hydrogen producers would lose their current methodology-based advantage over gas-based low-carbon fuels.5
Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Oct 2024 · impact on the soda ash industry due to the monitoring and reporting of greenhouse gas emissions.

Solvay urges EU to scrap new soda ash emission rules

26 Jul 2024
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions under the ETS.
Message — Solvay requests the Commission maintain current reporting rules for soda ash production. They urge removing a paragraph that classifies process carbon as emitted by the producer.12
Why — This would avoid a 20% cost increase and preserve global market competitiveness.3
Impact — Climate regulators lose the ability to track residual emissions from downstream users.4
Read full response

Solvay urges inclusion of sodium carbonate in permanent carbon storage list

16 Jul 2024
Topic — Defining which products can permanently bind captured CO2 to avoid carbon emission costs.
Message — Solvay requests adding sodium carbonate to the list of permanent carbon binding products. They argue the compound is chemically stable and stores carbon for centuries.123
Why — This would lower compliance costs by allowing CO2 to be considered sequestered rather than emitted.4
Impact — Environmental groups lose if substances that release CO2 under heat are labeled as permanent.5
Read full response

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bulgarian Industrial Capital Association and Българска федерация на индустриалните енергийни консуматори

27 Feb 2024 · Energy transition and markets Also present: Monbat Group, Thracian Industrial Zone and the Bulgarian Association of the Metallurgical Industry

Solvay urges more flexible rules for free carbon allowances

2 Jan 2024
Topic — The Commission is updating rules for the free allocation of carbon allowances.
Message — Solvay requests maintaining higher free carbon allocations for process emissions and hydrogen by-products. They propose lower cost thresholds for mandatory energy audits to prevent financial strain. They also seek to keep climate-neutrality plans confidential to protect business strategy.123
Why — Solvay would avoid substantial carbon costs and safeguard its confidential business strategies.45
Impact — Transparency advocates lose access to information regarding how industrial companies plan to decarbonize.6
Read full response

Meeting with Milan Brglez (Member of the European Parliament, Rapporteur)

17 Nov 2023 · Water legislation

Meeting with Pascal Canfin (Member of the European Parliament) and AIR LIQUIDE and IKEA Foundation

27 Oct 2023 · Green Deal

Solvay seeks fair carbon reporting for bicarbonate production

23 Aug 2023
Topic — The European Commission is updating rules for monitoring and reporting industrial greenhouse gas emissions.
Message — Solvay wants carbon used for bicarbonate reported by the original source. They also request that users deduct emissions already accounted for upstream.12
Why — This would eliminate competitive disadvantages for companies producing both soda ash and bicarbonate.34
Impact — Stand-alone manufacturers would lose cost advantages gained from importing cheaper carbon dioxide.5
Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

23 Aug 2023 · - energy transition and decarbonization industry - PFAS

Response to European Critical Raw Materials Act

22 Nov 2022

Solvay welcomes the Commission's Critical Raw Materials (CRMs) initiative, including a legislative proposal, which will aim to strengthen the EUs resilience and security of supply as regards CRMs. The supply of CRMs, such as Nickel, Cobalt, Lithium, Magnesium, Palladium, etc. are essential for the chemical industry to sustain Europes economic and environmental ambitions. They are vital in high technology applications for automotive, semiconductors, renewable energy, defense, aerospace and other electronic appliances. However, the competition for these materials has intensified and is leading to increasing tensions across the CRMs supply chains. Global manufacturers are challenged to identify and respond to CRM requests across the globe and secure supply for plants. To meet the green and digital transitions objective and the consequently growing demand of CRMs, Solvay would like to provide actionable recommendations for the Commissions initiative in the document attached.
Read full response

Solvay Demands Scientific Clarity in New EU Chemical Hazard Rules

14 Oct 2022
Topic — Revision of the EU regulation on classification, labelling and packaging for chemical hazard classes.
Message — Solvay requests that endocrine disruption definitions focus on population-level impacts rather than individual organisms. They also recommend that mobility assessments use a broad evidence-based approach instead of simple screening values.123
Why — This would help the company avoid broad hazard classifications that they consider scientifically unjustified.4
Impact — Environmental protections for individual animals could be weakened by focusing only on population-wide harm.5
Read full response

Solvay urges focus on recycling over SF6 bans and quotas

29 Jun 2022
Topic — The EU is updating regulations to reduce climate-damaging emissions from fluorinated greenhouse gases.
Message — Solvay recommends focusing on gas containment and mandatory recycling instead of reducing production quotas. They also request a longer transition period for phase-outs, as alternative technologies are not yet industrially available.12
Why — This allows Solvay to maintain its manufacturing operations and avoid disadvantages against non-EU importers.3
Impact — Environmental groups lose as potent greenhouse gases remain in industrial use for longer periods.4
Read full response

Response to Revision of the Energy Tax Directive

18 Nov 2021

Solvay asks to foresee a transition period before any tax increase to enable the energy decarbonation Solvay is concerned by the impact on the competitiveness and long-term investments decisions which will be created by the general increase of the minimum taxation levels and the cancellation of most of the possibilities for exemptions and tax reductions in particular for energy intensive industries (EIIs). Industry needs time to invest for low or zero carbon fuel conversion and this before any tax increase would make the concerned industrial sites uneconomical to even consider their conversion. A moratorium concerning the increase of the fossil fuels tax base in the ETD proposal should be considered to allow for such reconversion and to prevent any investment leakage. Solvay proposes to maintain the current tax reductions and/or exemptions for fossil fuels during a transition period to start as of the expected implementation of ETD. This transition period could last at least 5 years before gradual implementation of the ETD changes on fossil fuels for EIIs. Solvay proposes setting a taxation ceiling for energy intensive consumers to retain investments in the EU Europe needs a strong and competitive industry enable to develop innovative sustainable technologies and products in order to meet the Green Deal targets. Therefore, the revision of the ETD should not create additional and unnecessary tax burdens. The main priorities of the ETD should be to give the long term signal to investors and industries and to safeguard the competitiveness of the European industry that competes globally. Industries exposed to international competition should keep the possibility to benefit from the current reduced tax rates and exemptions. The differentiation between business and non-business users should therefore be kept and with a clearer definition of EIIs. EIIs need a competitive and secured supply of decarbonized energy to speed up their reconversion and to succeed on global markets. Therefore, bioenergies (biomass, biogas…) ought not to be included in the ETD proposal. Moreover the current energy hierarchy proposal should not apply to EIIs. The current proposal might refrain industry willingness to invest in the decarbonation of the EU economy. Solvay recommends therefore setting a taxation ceiling for energy intensive consumers which would prevent Member States to introduce additional levies above the tax component. Mineralogical and electro-intensive processes must remain excluded from the scope Solvay is strongly concerned by the extension of the scope to “mineralogical processes” and to activities where electricity represents 50 % of the cost of the product, both previously excluded. Indeed, due to the exceptionally high proportion of energy content in the products of those EIIs, they might lose their overall competitiveness already undermined by the recent price spike of electricity. Moreover electrification should now be encouraged and not the reverse. ETD should not overlap with other EU legislation ETD is not meant to be an instrument to reduce ghg emissions for activities covered already by the ETS. The combination of energy and environmental taxation criteria in the proposal could lead to double taxation with the ETS. The ETD link with the definition of High-efficiency cogeneration given in the Energy Efficiency Directive (EED) can only be kept should the CO2 restrictions in article 2 (34) of the EED be removed. Finally, full energy taxation exemption for High Efficiency Cogeneration should remain a possibility, as it is a way to promote low carbon energy efficiency for industrial sites. Outsourced energy production must be treated equally with integrated utilities sourcing The taxation scheme should be independent of the plant set-up and should avoid distortion of competition between companies that perform the same activities. Outsourced activities should be treated in the same way as if they were internalized.
Read full response

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

1) Solvay would welcome a comprehensive additional instrument to ETS addressing all aspects of trade competitiveness related to carbon leakage Solvay welcomes the intent of the Commission to try safeguarding the international competitiveness of the relevant sectors in light of increasing asymmetric climate ambitions and policy implementation of the EU compared to the rest of the world. Unfortunately, the CBAM proposal comes as an alternative to free allowances and without provisions addressing the collateral impacts thereby possibly weakening the overall competitiveness of the relevant sectors. The current CBAM proposal, which would trigger the discontinuation of free allowances, contains no provisions to deal with the negative impact on EU export competitiveness neither on the likelihood of import substitution by the next “untaxed” step in the production chain nor on the resource shuffling of third countries. Moreover, should a comprehensive CBAM instrument be proposed for chemicals, we could consider bringing in that instrument an equivalent EU level compensation mechanism for the indirect emissions impact. The current CBAM proposal is therefore not appropriate for the chemicals sector considering its wide and complex product value chain and its sensitivity to competitiveness. 2) To maintain the production and value chain in the EU a “CBAM” for chemicals should come as an additional complement to free allowances, not as an alternative The tighter ETS objective (i.e. -61% vs -43%) will mean a stronger carbon price with higher production costs and a reduced support to international competitiveness through shrinking free allocations. We therefore need a more economical approach to the level of free allocation in order to face the rising asymmetric situation for emissions costs between domestic production and manufacturing outside EU. As the main objective is to safeguard EU competitiveness, any instrument like CBAM for the chemicals sector should only come as an additional complement to the remaining free allowances and not as an alternative to them. Replacing the existing ETS free allowances would de facto increase by the same amount the costs of EU chemicals without ensuring that the exact same costs would apply to imports. Moreover, the costs cascading through the value chain will mean that there will always be a stage of manufacturing escaping any CBAM, if even feasible. Under ETS, we are facing a decreasing cap of emissions coupled with a price to pay if emitting GHGs beyond a certain theoretical benchmark level, the aim being to drive down our emissions. Therefore a carbon border adjustment mechanism, if introduced as a complement to the ETS free allowances would then become a welcome tool to safeguard competitiveness for the part above benchmark that the current ETS carbon leakage measures are not providing. 3) A comprehensive CBAM should address the issue of our export competitiveness Solvay and the Chemicals industry, rely on its exports to keep production in the EU. In this regard, keeping the ETS free allocations based on genuine benchmarks is vital in particular to safeguard the production in the EU. A CBAM should therefore safeguard or even improve our ability to compete at export and not weaken it. 4) The CBAM should be designed to avoid circumvention through resource shuffling by non-EU producers The risk of circumvention, whereby exporters reduce their climate obligations by crediting low-carbon energy to supplies directed to European countries while allocating high-carbon energy to the domestic market or other markets with lower climate costs, must be mitigated. This risk is so far not accounted for in the Commission modeling exercise. Exporting low-carbon products to the EU would imply lowering the carbon costs these importers face undermining the carbon leakage protection which the CBAM provides, without leading to a decrease of global emissions.
Read full response

Response to Updating the EU Emissions Trading System

8 Nov 2021

Solvay has set itself an objective of carbon neutrality in 2040/2050 and we need an Emission trading System ( ETS) allowing us to succeed in our endeavor. The EU is leading the climate transition in the world and the ETS Directive is the essential tool for keeping at the same time our international competitiveness. This Directive should allow for ramping up gradually within the period till 2030 since many enabling technologies still need to be either implemented and/or their efficiencies confirmed. The Cross Sectoral Correction Factor (CSCF), which possibly reduces free allowances even for the best performers, must be abandoned to ensure the mere existence of an European industrial base. The increase of the LRF from 2,2% to 4,2%/year might trigger the CSCF which could jeopardize our industrial strategy of investments needed to implement our pathway towards climate neutrality. Indeed, it might reduce arbitrarily the free allowances allocation for our installations considered as best in class thereby compromising their future in the EU. Moreover the uncertainty surrounding the possible application of the CSCF adds an unbearable variable for such capital intensive investments. An alternative proposal to deal with the decreasing emission cap would be to adapt downwards the current auctioning fixed share of 57 % to avoid any application of the CSCF to the volume of free allowances. The Product benchmark calculation proposal using now an extrapolated performance system must be abandoned. While benchmarks should reflect reality and be technologically reachable to fulfil their defined role the proposal wants to base the calculation on an extrapolation over the next five years of the past performance. This system would be applied to benchmarks on top of an already strengthened update from 2021-on. Moreover a majority of the 10% best performers will end up receiving a volume of free allocations at a level lower than their actual emissions forcing them to purchase allowances. Not only would it contradict the aim of the Directive but it would risk penalizing strongly best in class industrial sites without any possible benefit for climate.. Biomass should not be taken into account for determining the Heat benchmark. The Heat benchmark will be impacted severely (-50%) due to the new reference feedstock being used which is biomass. This reference is not an industrial one as it was based on district heating which, moreover, is not exposed to international competition. The Commission wrongly assumed that this situation could be replicated for any industrial installation. Biomass differ in quality and available quantity with rising demand triggering a rising price, all of this making its cost and supply chain uncompetitive and/or not relevant notably when facing international competition. ETS heat consumers supplied by industrial installations using biomass should keep their right to benefit from free allowances It is important to keep all the incentives for triggering the energy transition particularly for fossil fuel installations investing into a biomass transition. The EU Commission should share more equally between ETS and non-ETS sectors the 2030 target recognizing the urgent need to create more demand. Compensation for Indirect emissions must be brought at pace with the electrification strategy of the society An increasing part of the solution comes from the electrification of the industry. Since the carbon costs influence negatively the attractiveness of electricity as an energy, a bolder framework of carbon leakage measures is needed to take into account this growing solution. For example, boosting the cap of financial support and enlarging the list of eligible sectors would constitute already a major breakthrough. Solvay believes that a low carbon industry needs innovation and process electrification. We do need a steady supply of competitive electricity based on renewables through long term contracts.
Read full response

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

We suggest amending the draft implementing regulation on sustainability criteria for forest biomass to explicitly exclude from the scope, all residues (shell, kernel, pulp) coming from fruits harvested in natural forests and whose harvest contributes to preserve it extent and does not impact negatively soil quality and biodiversity. We recommend modifying as follows article 2 of the regulation by adding a new sentence. The Regulation shall not apply to residues and by-products coming from the use of fruits harvested in natural forest.
Read full response

Response to Revision of EU rules on Gas

5 Mar 2021

Solvay answer. The new hydrogen and gas markets decarbonisation package needs to enable the supply of clean, competitive and secured gaseous energy 1) Competitive access to renewable gas and green hydrogen will be key to reach carbon neutrality in the EU Green hydrogen production will need to be competitive before becoming a viable alternative to conventional energy and should not bear high surcharges for industrial consumers. Moreover green hydrogen production, if issued from electrolysers, cannot come at the expense of electricity competitiveness. The availability of abundant, secured and competitive renewable gas will be necessary for processes for which electrification is not possible or not economically viable. This will require strong political support, timely development and financing of adequate infrastructure for energy generation, transport, energy import and adequate backup for compensating intermittency of renewables. 2)The transport of green hydrogen off-grid production must not harm the security and the quality of the current gas supply Security of energy supply is vital for the proper functioning of industrial activities. Injection into the gas network of renewable fuels generates significant fluctuations of the gas quality delivered to the consumers which is likely to disturb the production processes and lower their efficiency. Injection of hydrogen into the gas network is even more critical than biogas injection. Indeed, industrial consumers that used natural gas as feedstock for their industrial processes will be strongly disturb by this injection and will see dramatic increase of their operating costs. In addition, hydrogen injection will also disturb the combustion facilities of natural gas consumers that used natural gas as energy carrier. Tremendous investments will be needed to adapt industrial combustion facilities and prevent disruptions by the changing gas quality. It is the reason why a direct injection of hydrogen into the gas network must be in any case avoided. Hydrogen should be consumed in priority at the place of production or transported by other means than the existing natural gas networks. 3)Hydrogen and gas markets decarbonisation package must safeguard the European industrial competitiveness Generation costs of green hydrogen is four times more expensive than biogas. Mixing them together would not make economic sense. In addition, industry and in particular the chemical industry uses pure hydrogen as feedstock for specific processes. To decarbonize cost-effectively such uses, the regulation should promote the implementation of green hydrogen production facilities close to the hydrogen consumers. This would avoid expensive costs of transporting hydrogen from the generation locations to the consuming facilities. As a principle, the objective should be to not connect green hydrogen production facilities to any natural gas network at all in order to not jeopardize the competitiveness of industrial gas consumers. 4)New dedicated hydrogen infrastructure should be foreseen Should it be not possible to locate green hydrogen generation facilities close to the consumers, then dedicated hydrogen infrastructures (pipeline, storage…) fully disconnected from the current natural gas network should be built. The same regulatory scheme as for gas infrastructure should be implemented to ensure a full unbundling of generation, transport and storage activities. To optimize the costs for the end users, the current gas TSOs and DSOs could be allowed to have also in charge the management of the new hydrogen network. As a consequence, to ensure the unbundling of production and transportation activities, TSOs and DSOs should not be allowed to operate electrolyzers generating hydrogen from renewable electricity. Green hydrogen generation will most certainly need state aids and subsidies to allow its development and this new market is likely to remain highly regulated.
Read full response

Response to Updating the EU Emissions Trading System

26 Nov 2020

SOLVAY’s response to the Inception Impact Assessment on EU Emission Trading Scheme (EU ETS) EU ETS should remain the pivotal instrument of the European industry against the risk of carbon leakage for a successful transition 1) A new pull strategy to boost demand for low carbon products enabling a fair effort sharing Under the European Green Deal, the Commission is proposing a higher EU greenhouse gas emissions (GHG) reduction target of 55 % in 2030. We need to make a step change with a pull strategy. ETS sectors and non-ETS sectors should therefore be considered with different perspectives taking into account the already higher target challenge applied to ETS sectors. ETS sectors will need an enabling policy framework ensuring competitiveness and industrial transformation. The ETS reduction target should be defined on the basis of detailed analysis of the sources of GHG reduction of each ETS sub-sectors and should not go beyond the potential for cost-effective emissions. A pull strategy in non-ETS sectors rebalancing their contribution to the EU climate goal with the one of ETS sectors, till 2030 would trigger demand for low carbon products thereby stimulating investment, growth and jobs in the whole EU economy. 2) Consistency of the regulatory framework without any cliff edge phenomenon is needed We need a consistent, predictable and regulatory framework with a smooth pathway for deciding our long term industrial investments. The revision of the ETS Directive should not lead to any cliff edge phenomenon such as one on the ETS cap. Applying a one-off reduction on the ETS cap would not be in line with economic cycles and could severely disturb the market. Similarly, the inclusion into the ETS of other large non-industrial economic sectors, such as buildings or transport with highly different price elasticities, is a risk for industry strategy and competitiveness. 3) Maintaining global competitiveness of the EU industry during its transition is a top priority Asymmetry with climate policies of third countries distorts the level playing field, for existing installations, value chains and investment location decisions. At a minimum, safeguarding the industrial competitiveness of the EU requires to maintain the current measures against the risk of carbon leakage. Free allocations of EUAs and financial compensation of indirect emissions should be kept and allocated based on realistic best in class performances benchmarks without any arbitrary reduction factor. The current auctioning fixed share of 57 % should therefore be adapted downwards to avoid any application of the cross sectoral correction factor. 4) Strengthening funding for innovation and its market deployment Main disruptive technologies enabling to achieve climate neutrality are yet to be demonstrated at full industrial scale. Thus, the stronger climate goal must be backed by a strengthened Innovation Fund for piloting breakthrough technologies as well as by a new fund enabling their deployment in the industrial sector across the EU.
Read full response

Response to Sustainable Products Initiative

10 Nov 2020

Solvay welcomes the opportunity to provide feedback on the Commission’s Roadmap on Sustainable Products Initiative. The chemical industry is highly committed to bringing products to the market that are safe and have a low environmental impact, while maximising value for the consumers and the society. Innovation continues in search of more resource efficient and circular products. Chemical innovations in the design of materials can enable downstream users to supply the market with more sustainable and circular products. ‘Safe and sustainable by design’ is an innovation approach towards designing chemical products and technologies that deliver societal value, accelerating the transition towards a circular and sustainable society. Sustainability is one of the essential driving forces of the Solvay strategy. In Solvay we evaluate for each product/application both the impact of its production on the environment and the benefit or challenge to the planet and the society. Further to our internal assessment a sustainable solution is a product in a given application which brings higher social and environmental contribution to our customer performance and at the same time demonstrates a lower environmental impact in its production phase. For further information of our methodology, please refer to our website https://www.solvay.com/en/sustainability/sustainable-portfolio-management-tool. Alve-One® is a perfect example of how Solvay walks the talk. Alve-One® foaming solutions, launched 3 years ago, comes as a safe and efficient alternative to an existing SVHC blowing agent called azodicarbonamide (ADCA) used in thermoplastics. Alve-One ® solutions promote a safer plastics' recyclability which is key for a better circular economy and essential to make the EU Green Deal work https://www.solvay.com/en/brands/alve-one. For other sustainable solutions, please visit Solvay website https://www.solvay.com/en/
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Sept 2020

The Renewable Energy Directive needs to enable the supply of clean, competitive and secured renewable energy Key points: Access to competitive low carbon energy is key, Renewables should not harm the security and the quality of supply, All renewable energies like biogas must be promoted for industrial activities, RED must safeguard the European industrial competitiveness The EU Commission has issued an Inception Impact Assessment related to the RED and SOLVAY is asking to take into account: -Access to competitive low carbon energy is key to achieve the European targets: The availability of abundant, secured and competitive low carbon energy will be necessary. This will require strong political support, timely development and financing of adequate infrastructure for energy generation, transport, energy import and adequate backup for compensating intermittency of renewables. -Renewables should not harm the security and the quality of supply: Security of energy supply is vital for the proper functioning of industrial activities. The development of renewable energy could harm the reliability of the energy supply. Intermittent renewable electricity, like wind and solar, have huge impacts on the stability of the electrical network and thus on the reliability of industrial production. Injection into the gas network of renewable fuels, like biogas or green hydrogen generate significant fluctuations of the gas quality delivered to the consumers which is likely to disturb the production processes and lower their efficiency. -All renewable energies like biogas must be promoted for industrial activities: Due to technical constraints, electrification is not always possible to decarbonize industrial activities. Moreover, when possible, electrification might not necessary be the most efficient solution. Biomass, biogas and green hydrogen should also be contemplated. Those fuels should be considered as energy carrier enabling to reduce emissions in the production of heat or other processes. In particular, biogas should be promoted by recognizing it in the EU ETS scheme with a zero CO2 emission factor, whatever the way it is financially supported. It is of the utmost importance that all the pieces of regulation covered by the green deal are revised in a consistent manner. -Safeguard European industrial competitiveness: In any case, the main challenge for the European industry will be to safeguard its international competitiveness. To reduce the global cost of renewable energy for the community, a cost efficient support scheme should be implemented and promote in priority renewable energies that have the lower generation costs or that are the less intermittent. The development of renewables is usually financed by surcharges applied on top of energy market prices. The European guidelines on state aids should keep the possibility for Member States to exempt significantly energy intensive business competing globally and using high efficient technologies from those surcharges. Moreover, huge investment will be required to connect new renewable energy producers to electricity and gas networks,. This might increase significantly the energy transport costs charged to energy consumers. Therefore, to maintain the competitiveness of energy intensive businesses, partial exemptions of those costs should be foreseen for these activities.
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

15 Sept 2020

The Energy Efficiency Directive needs to avoid capping energy consumption and should focus on actual efficiency: • The EED must focus on actual efficiency keeping industry growth instead of capping energy consumption which would lead to a reduction of the manufacturing production. • The revised EED objectives should not come in conflict with the provisions of other related directives such as ETS or RED. • Any new EED provision must be assessed against its impact on industry competitiveness before adoption. Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of energy. The intent of the EU is to review the Energy Efficiency Directive (EED) by assessing its contribution to the higher EU climate ambition of reducing greenhouse gas emissions by 50 or 55 % in 2030. The EU Commission has issued an Inception Impact Assessment related to the EED and SOLVAY is asking to take into account the following: 1) Avoid capping of energy consumption; focus on actual efficiency First of all, SOLVAY would like to remind that improving energy efficiency should not mean absolute reduction of energy consumption. Energy efficiency must be a reduction of energy consumed per output expressed for example in GJ/tproduct. Setting absolute caps on energy consumption will lead to a reduction of the production of the European manufacturing industry, triggering an increase of the imports from third countries with an increase of the European carbon footprint. Indeed, imported products are usually produced in a less efficient way with a more carbon intensive energy mix. All the key economic sectors should play their part in achieving the 2030 energy efficiency target. The level of ambition should be defined in regards of the reduction potential of the concerned sector. For decades, European chemicals industry has been improving its energy efficient (55% improvement between 1991 and 2017: CEFIC). It now operates its processes very often close to the thermodynamical limits. To possibly reach those limits, breakthrough technologies will be needed. Thus, the revision of EED should take into account those technical limits by setting only realistic targets. 2) Avoid conflicting regulations: The revised EED provisions should take into account both the evolution of the European energy mix as well as the consequences and the impacts of the other regulations. It should be revised in a consistent way with the other pieces of regulation in preparation like Emission Trading Scheme (ETS) or Renewable Energy Directive (RED). Some of their provisions could have a conflicting impact on the energy efficiency objective, e.g.:• Switching from fossil fuels to renewable fuels does reduce energy efficiency (a biomass-fired boiler has a lower efficiency than a natural gas fired boiler),• Mitigating emissions through for example Capture Carbon and Storage (CCS) increase by 15 to 20 % the energy consumption of the whole production chain,• The increasing share of intermittent renewable energies in the European energy mix may require more energy flexibility from large industrial energy consumers, with the consequence that Industrial processes might be not operate with the highest efficient 100 % of the time. 3) Safeguard European industry competitiveness: The energy cap introduced by this Directive, if maintained should not curtail European industry growth. Furthermore, the energy savings obligation should not apply to the energy supplied to ETS activities: Indeed, those activities are already facing a linear reduction factor of their carbon emissions which affect directly their energy consumption. Industry should not be faced with a situation where it has no choice than to invest in none profitable energy savings technologies, thereby leading to a loss of its competitiveness. Any reduction of the production due to the EED energy cap would affect the profitability of such unit possibly leading to their closure.
Read full response

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

1. Solvay welcomes the EU intent to safeguard the competitiveness of EU industries. The EU wants to become the first continent carbon neutral in 2050 which involves a deep turnaround of all the sectors of the EU economy. New climate constraints will nevertheless mean a more severe greenhouse gas emissions (GHGs) reduction path with an increased risk of carbon leakage as underlined by the Commission. In this respect, Solvay welcomes the explicit recognition of the need to safeguard the international competitiveness of EU industries in light of asymmetric increasing climate ambitions in EU compared to the rest of the world. However, considering the recent Communication of the EU Green Deal, we believe that an impact assessment is needed on the different options envisaged to create a carbon border adjustment mechanism that would fulfil this objective. 2. A carbon border adjustment mechanism must come in addition to the ETS carbon leakage measures not as an alternative The EU Emissions Trading System (ETS) has been reinvigorated for the next period 2021-2030 with tighter mechanisms leading to fewer emissions and a stronger market price although with a reduced support to international competitiveness through shrinking free allocations. Considering those shrinking allocations, driven notably by lowered benchmarks, we will no longer be able to rely only on them to face the rising asymmetric situation for emissions costs between domestic production and manufacturing outside EU. As the objective is to safeguard EU competitiveness, a carbon border adjustment mechanism should come as an additional complement to the ETS carbon leakage measures for chemicals and their value chains. Unfortunately and somewhat confusingly, the Green Deal is only considering such a carbon border mechanism as an „alternative“ to the ETS carbon leakage measures (see European Green Deal 11.12.2019 COM(2019) 640 final- page 5 para 4) which would then weaken the industry competitiveness. Chemicals are intricated in complex value chains with multiple stages each exposed to international competition and for which weighting carbon content is beyond feasibility. Removing the existing ETS carbon leakage measures would increase the chemicals costs as well as the value chain costs at stages for which a carbon border adjustment mechanism is also not feasible. This mechanism, if introduced as an “alternative” to ETS, would thereby fail to safeguard the international competitiveness of chemicals and its whole EU value chain. 3. Imported emissions should be captured in Europe’s efforts to mitigate GHG: under ETS, we are facing a decreasing cap of emissions coupled with a price to pay if emitting GHGs beyond a certain theoretical benchmark level, the aim being to drive down our emissions. Imports are nevertheless not submitted to ETS and therefore are gaining an increasing competitive advantage particularly when facing lower or even non-existent domestic price for their emissions. Therefore a carbon border adjustment mechanism, if introduced as a complement to the ETS carbon leakage measures, would then become a welcome tool to safeguard competitiveness for the part above benchmark that the current ETS carbon leakage measures are not providing. Such a mechanism, as described just here above, would also help motivating third countries to implement similar ambitious climate policy as in the EU. Policy makers must indeed ensure to level the playing field with other economies that do not comply nor pay for their emissions the way the EU does. 4. EU exports competitiveness must be ensured:As for the whole European chemical industry, Solvay relies also on its exports to keep production production in the EU. In this regard, keeping the ETS free allocations based on genuine benchmarks are vital in particular to safeguard the production of soda ash in Europe. Any new additional carbon border mechanism or ETS measures should therefore safeguard or even improve our ability to compete.
Read full response

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and ArcelorMittal and

22 Nov 2018 · taxonomy and EU IFRS

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

2 Oct 2018 · Social dialogue

Meeting with Stephen Quest (Director-General Taxation and Customs Union) and Vodafone Belgium SA and

13 Mar 2018 · Discussion on CCCTB (also with representatives from BP and Wolters Kluwer)

Meeting with Pierre Moscovici (Commissioner) and Vodafone Belgium SA and

13 Mar 2018 · Discussion on CCCTB (also with representatives from BP and Wolters Kluwer)

Meeting with Jos Delbeke (Director-General Climate Action)

18 Jul 2017 · Batteries

Meeting with Miguel Arias Cañete (Commissioner) and

17 Jun 2015 · Commission Communication on Energy Union/ Climate change agenda to Paris COP21

Meeting with Jos Delbeke (Director-General Climate Action)

17 Jun 2015 · Commission Communication on Energy Union/ Climate change agenda to Paris COP21

Meeting with Frans Timmermans (First Vice-President) and Boerenbond vzw and

11 May 2015 · Better Regulation

Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

17 Feb 2015 · Corporate social responsibility