The Association of Lithuanian Chemical Industry Enterprises
ALChIE
Assistance of the members in communication with the EU authorities on competitiveness issues.
ID: 490999041660-68
Lobbying Activity
Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
1 Jun 2021
The Association of Lithuanian chemical industry enterprises welcomes the opportunity to express views for REACH Revision Inception Assessment public consultation.
Chemical sector in the country is already facing a transition which comprise climate neutrality, digitalization, circularity objectives and implementation of the Chemicals Strategy for Sustainability. It should be noted that this will be a particular challenge for small and medium-sized enterprises. According to NACE2, more than 90% of the companies in the C20 group in the country are classified as small and medium-sized enterprises.
It is essential under these circumstances to reach the goals as well as to keep competitiveness of the companies. In this respect enforcement of existing regulation and enforceability and monitorability of new measures is essential. Enforcement does not only need better resourcing, but also better coordination within Member States competent authorities (customs, enforcement authorities) and between Member States and market actors. In fact, controls at the EU border need to be effective.
There are many definitions in the proposal which has to be clarified. Especially when it comes to the concept of essential uses concept:
- It has to be transparent and proportionate to the identified risk.
- It should be done on a case-by-case analysis of individual uses, without excluding entire industry sectors.
- Essential Use assessments must be subject to challenge and review after a period of time to accommodate changing societal needs and priorities;
- Decisions on Essential Use should be made by a politically accountable body set up by the European Commission that is empowered to take both decisions and responsibility for these decisions beyond existing scientific or regulatory committees not by local authorities.
- Decision-making has to be transparent and should involve representatives from across the stakeholder community, including industry and civil society, to ensure legitimacy of the process.
Still should be better explained definitions and practical implementation of:
- Registration of certain polymers and the appropriate control on the market. This expected to be a be new challenge for companies as well as for the authorities.
- Concept of the environmental footprint and parallel initiatives (e.g. carbon footprint)
- Mixture assessment factor.
EU has the strictest chemical legislation in the world. But it will only fully work to the benefit of people and environment, as this can be observed in the EU border country, if properly enforceable and enforced.
Read full responseResponse to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information
31 May 2021
The Association of Lithuanian Chemical Industry Enterprises supports the objectives of the European Green Deal. At the same time, adapting to changing conditions requires flexible solutions.
Energy intensive domestic sub-branches - fertilizer and plastics industries operate in complex value chains and are exposed to international competition. These activities involve large capital requirements, higher operating costs compared to many other industries. Maintenance of competitiveness require substantial investments which means access to finances is of the highest priority.
Flexibility for to adjust to changing reporting obligations.
In this regard we think non-financial reporting obligations for big companies should remain voluntary (IMPORTANT).
This can be regulated with the implementation of standards.
Realistic implementation timelines.
The proposed one year implementation period might present significant challenge. The availability and reliability of data should be taken into account first.
Greater clarity of key definitions.
The list of definitions is substantially extended and some of them should be clarified. Taxonomy Regulation does not clearly define the concept of “directly enabling other activities” (Article 16). Definition “do no significant harm” should be further explained as well. This can raise concerns for the companies with many cross-border operations since there is no commonly agreed international definition.
Balance with the actual value.
EU chemical industry is highly regulated, both at an EU and Member State level, it is important that the Better Regulation Guidelines are followed. Additional reporting requirements should remain in balance with the actual value of the information generated for stakeholders.
Read full response