WACKER CHEMIE AG

WACKER

WACKER CHEMIE AG is an innovative chemical company supplying solutions for sustainable growth and quality of life worldwide.

Lobbying Activity

Wacker Chemie urges Chips Act support for raw materials

25 Nov 2025
Message — Wacker Chemie requests that the Chips Act 2.0 cover the entire value chain, including upstream raw materials. They argue for unrestricted access to silicon metal and affordable, predictable electricity prices.12
Why — These measures would ensure the profitability and sustainability of their energy-intensive production sites.3
Impact — External suppliers face reduced demand as Europe works to decrease its dependency.4

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and

4 Nov 2025 · Overview of the Commission's Single Market Strategy.

Meeting with Christian Ehler (Member of the European Parliament) and Bundesverband Öffentlicher Banken Deutschlands eV

2 Oct 2025 · General exchange

Meeting with Christine Schneider (Member of the European Parliament)

25 Sept 2025 · Chemical Industry

Meeting with Amaryllis Verhoeven (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

2 Sept 2025 · Possible Forced Labour in the Solar Panel Industry

Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

30 Jun 2025 · Presentation of Wacker Chemie AG and EU tech agenda

Meeting with Christian Ehler (Member of the European Parliament) and ASD-Eurospace

11 Jun 2025 · General exchange

Wacker Chemie Urges EU to Simplify Biotech Regulatory Approvals

4 Jun 2025
Message — Wacker Chemie requests simpler authorization for products equivalent to conventional versions. They advocate for subsidies on raw materials used in fermentation processes. They also want to exempt certain products from GMO labeling.123
Why — These changes would lower costs and speed up the delivery of biotech innovations.45
Impact — Transparency advocates lose visibility because certain GMO-linked products would avoid labeling.6

Meeting with Oliver Schenk (Member of the European Parliament)

2 Apr 2025 · Chemische Industrie in Europa

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič)

1 Apr 2025 · U Safeguard Investigation Siliziummetall - Case SAFE010 Alloys

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and EVONIK INDUSTRIES AG

17 Mar 2025 · Ongoing safeguards investigation into alloying elements (SAFE010)

Wacker Chemie urges mandatory cost-sharing for drinking water chemicals

28 Feb 2025
Message — The company requests a mandatory cost- and data-sharing mechanism for substance re-evaluation under the Drinking Water Directive. They propose adopting principles from REACH to facilitate industry collaboration. This ensures that essential materials remain available for water networks.12
Why — Mandatory sharing reduces individual re-evaluation costs and prevents competitors from free-riding on expensive studies.34
Impact — Water infrastructure projects and EU resilience goals suffer from supply shortages and uncertainty.567

Meeting with Oliver Schenk (Member of the European Parliament)

7 Feb 2025 · Chemical industry in the EU

Response to List of net-zero technology final products and their main specific components

5 Feb 2025

WACKER is a global producer of polysilicon and the world market leader in terms of purity and quality. In fact, WACKER is the only polysilicon producer in Europe. Polysilicon is the main raw material, as it provides the necessary properties as a semiconductor element. We welcome your draft list of net-zero technology final products and their main specific components, as it includes PV-grade polysilicon. Omitting polysilicon would run counter to the ambition of the Net-Zero Industry Act as well as recent commitments to clean tech manufacturing in Europe, for example in the President's Political Guidelines or most recently in the Competitiveness Compass. The inclusion is warranted due to the following three reasons: Firstly, our understanding is that polysilicon and ingots/wafers fall under the same NACE code (NACE 20.1.3 - Manufacture of other inorganic basic chemicals and PRODCOM 24.13.11.53 - Containing by weight not less than 99.99 per cent of silicon) (HS code reference: 2804.61). Second, the vast majority of polysilicon is used by the PV industry. Global demand for solar grade polysilicon is approximately 1,500,000 tons, while demand for semiconductor polysilicon is approximately 40,000 tons. (Bernreuter Research (2024), The Polysilicon Market Outlook 2027, p. 45.) Third, polysilicon production is a sophisticated chemical production process with many chemical transformations. N-type and perovskite solar technologies require ready-to use polysilicon with specified bulk and surface parameters. Those unique properties of polysilicon are created during the manufacturing process in the distillation, deposition and crushing process.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

5 Feb 2025

WACKER is a global producer of polysilicon and the world market leader in terms of purity and quality. In fact, WACKER is the only polysilicon producer in Europe. Polysilicon is the main raw material, as it provides the necessary properties as a semiconductor element. We welcome your draft list of net-zero technology final products and their main specific components, as it includes PV-grade polysilicon. Omitting polysilicon would run counter to the ambition of the Net-Zero Industry Act as well as recent commitments to clean tech manufacturing in Europe, for example in the President's Political Guidelines or most recently in the Competitiveness Compass. The inclusion is warranted due to the following three reasons: Firstly, our understanding is that polysilicon and ingots/wafers fall under the same NACE code (NACE 20.1.3 - Manufacture of other inorganic basic chemicals and PRODCOM 24.13.11.53 - Containing by weight not less than 99.99 per cent of silicon) (HS code reference: 2804.61). Second, the vast majority of polysilicon is used by the PV industry. Global demand for solar grade polysilicon is approximately 1,500,000 tons, while demand for semiconductor polysilicon is approximately 40,000 tons. (Bernreuter Research (2024), The Polysilicon Market Outlook 2027, p. 45.) Third, polysilicon production is a sophisticated chemical production process with many chemical transformations. N-type and perovskite solar technologies require ready-to use polysilicon with specified bulk and surface parameters. Those unique properties of polysilicon are created during the manufacturing process in the distillation, deposition and crushing process.
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Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and

29 Jan 2025 · REACH revision

Wacker Chemicals urges ETS rules protecting biocarbon and CCUS investments

9 Jan 2025
Message — Wacker requests that switching to biocarbon does not reduce its free emission allowances. They want definitions to include biocarbon and captured emissions to avoid being penalized for decarbonizing.12
Why — Retaining free allowances would help offset the higher costs of switching to cleaner raw materials.3

Meeting with Christian Ehler (Member of the European Parliament)

3 Dec 2024 · Net-Zero Industry Act

Meeting with Christian Ehler (Member of the European Parliament)

8 Oct 2024 · Industrie- und Energiepolitik

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

Wacker Chemie would like to submit its views. Our detailed comments can be found in the attached document.
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Meeting with Angelika Niebler (Member of the European Parliament)

31 Jan 2024 · EU chemical policy

Response to Measures to reduce microplastic pollution

16 Jan 2024

As an industry, we welcome initiatives to minimize the unintentional loss of plastic pellets. Any approach to reduce pellet loss should be effective, but also needs to be economically feasible. Comparison of EU and UN data The proposed regulation estimates that between 52 kt and 184 kt of pellets were lost to the environment in the EU in 2019. The target of the proposed regulation is to reduce the pellet losses within the EU in the range from about 25 140 kt annually so contributing about 1/4th to the Commissions microplastics reduction target of 30 % by 2030. On the other hand, a UN study from 2018 (Mapping of Global Plastics Value Chain and Plastics Losses to the Environment: With a Particular Focus on Marine Environment (unep.org)) estimates a total loss of plastic pellets during upstream plastic production with 30 kt worldwide. The combined portion for Western-, Central Europe and CIS is 17 %, resulting in 5,1 kt. Nevertheless, the impact of mismanaged (non-pellet-) waste treatment (3870 kt) or loss of plastic from littering (800 kt) is several orders of magnitudes higher, based on the UN report. According to the commission, net costs for the participants of the affected industry to implement the regulation are between 376 471 Mio per year. These numbers are already corrected by an estimated economic gain of 25141 Mio due to avoided loss of pellet material. If the figures from the UN report are taken into consideration, these savings might not be realized, which means that the costs for industry will be even higher than expected. Clear definition is required The regulation typically refers to plastic pellet losses. As this description is legally and scientifically very unclear, we would propose to sharpen the plastic-pellet-definition, e. g. regarding a more specific definition of use for plastic manufacturing and physical properties or chemical composition of the affected polymer pellets. Certification Threshold and use of existing certification schemes proposed A third-party certification should not be required for SMEs and industries producing/handling these polymer pellets under 10 kt/a. This number is more reasonable considering the usual SME-output of plastic pellets than the proposed 1 kt/a and would help to implement the regulation more effectively. Such certifications typically come along with a high bureaucratic effort and can easily overstrain smaller companies. As most non-SME industry participants have already implemented certifications like ISO 14.001 or EMAS, it should be the most effective way to achieve certification of conformity also under those existing, third-party-certified schemes. Avoid increasing bureaucracy We urge to consider a more pragmatic but still effective approach to ensure global competitiveness of the affected European companies. Therefore, the costs should be kept at a minimum (current estimate 376 471 Mio per year for additional staff, 3 858 full-time equivalent as per COM). Requirements listed in paragraph 3 and 4 of the regulation should be reduced, which would be in line with the commitment of the COM-President to reduce reporting requirements by 25 %. Quantities of Synthetic Polymer Microparticles (SPM, Commission Regulation (EU) 2023/2055) released to the environment, which cover also all pellets that fulfil SPM definitions (which is likely the largest part), already need to be reported.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Meyer Burger Technology AG

15 Jan 2024 · International trade; solar energy.

Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

10 Nov 2023

We are a chemical company that manufactures raw materials, intermediates, and additives for various applications, including those in contact with drinking water. Hence, our comments are mainly legislative proposals concerning starting substances. We welcome the recast of the Drinking Water Directive (DWD) as a step towards ensuring high quality and safety standards for materials in contact with drinking water in the EU. However, we would like to raise some concerns and suggestions on some aspects of the new regulation, that we would like to bring to your attention: Substance registration process, data requirement, protection and cost sharing: The data packages required for registration should be harmonized with other data requirements for related legislation like food contact material legislation in the spirit of the One Substance One Assessment principle. The coherence and consistency of the different regulations should be ensured and enhanced, avoiding conflicting or overlapping requirements and facilitating the mutual recognition and acceptance of the data and the assessments. We propose that the Commission and ECHA adopt appropriate measures to safeguard the confidential business information of companies and to facilitate the data- and cost sharing among applicants in line with the principles and practices of REACH. Implementation of the measures should consider the practical feasibility and the technical and economic implications for the users of the materials in contact with drinking water. Test Methods: Proposed detection limits ensure a high quality of the product and safety for the consumer but also constitute challenges to manufacturers, suppliers of raw materials and laboratories. The availability and standardization of analytical methods should be taken into account. The assessment of the materials in contact with drinking water, raw materials or precursors should be feasible and cost-effective for the users and avoid unnecessary testing. Definitions: The definitions of terms should be clear, consistent and unambiguous, avoiding multiple and contradictory interpretations to avoid confusion and ensure effective implementation. We would appreciate further harmonization of the definitions of these terms with other relevant EU legislation, such as Food Contact Materials, etc. Deadlines: We are aware that the revised DWD sets ambitious deadlines for the adoption and implementation of the European positive lists and the related measures. It should be ensured, that all deadlines can be met after the regulations come into effect. We are concerned that these deadlines may not be achievable, considering the timelines for notification, availability of data, testing labs, involved authorities, etc Guidance Documents: We would appreciate guidance documents to each delegated act or implementing act that clarify the responsibilities and obligations of the different actors in the supply chain, such as manufacturers, suppliers of raw materials or precursors, etc. We hope that our input will be taken into account and contribute to the improvement of the regulation of drinking water contact materials in the EU.
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Meeting with Matthias Ecke (Member of the European Parliament)

1 Nov 2023 · Meinungsaustausch Energie- und Industriepolitik

Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič), Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and

11 Sept 2023 · Restriction proposal on silicon

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

26 Jul 2023 · Present their concerns on POP nomination

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur)

5 Jul 2023 · Exchange on Forced Labour Ban Regulation

Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur)

5 Jul 2023 · Forced labour

Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur)

19 Jun 2023 · Forced labour

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur)

1 Jun 2023 · NZIA

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur) and FoodDrinkEurope

1 Jun 2023 · Forced Labour

Meeting with Michael Bloss (Member of the European Parliament) and Sunfire GmbH

4 Apr 2023 · Erneuerbare Energien Industrie

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

4 Apr 2023 · Net Zero Industry Act

Meeting with Mohammed Chahim (Member of the European Parliament)

20 Mar 2023 · PV, Clean Tech and State Aid

Meeting with Kadri Simson (Commissioner) and

7 Mar 2023 · Exchange on the needed regulatory support to promote the deployment and manufacturing of the solar power in the EU and the EU’s support for the solar energy so far.

Meeting with Jens Geier (Member of the European Parliament)

13 Feb 2023 · Exchange on the Industrial Plan and electricity market design (staff level)

Meeting with Henrike Hahn (Member of the European Parliament)

1 Jul 2022 · Entwicklungen in der EU-Umweltpolitik

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

23 Jun 2022 · To discuss the urgent actions needed to secure a resilient industrial base for solar manufacturing in Europe.

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

3 Jun 2022 · Solar strategy ; raw materials

WACKER CHEMIE supports F-gas rules with technical exemptions

19 Apr 2022
Message — WACKER supports the proposal's balance between higher ambition and justified exemptions. They want to maintain exemptions for refrigeration systems where no alternatives exist.12
Why — This allows WACKER to avoid extreme costs for converting their specialized refrigeration systems.3
Impact — Other sectors may face stricter quotas to compensate for these specific industrial exemptions.4

Meeting with Kadri Simson (Commissioner) and

30 Mar 2022 · Discussion on Solar Power Europe views on how to boost the manufacturing and deployment of solar PVs in the EU.

Response to European chips act package – Regulation

17 Mar 2022

WACKER is a world leading and Europe’s only producer of polysilicon which is the key raw material and first step in the value chain of semiconductors (and PV). WACKER’s electronic-grade polysilicon is a hyperpure material (99,999999999%) used for the manufacturing of wafers and chips and thereby an enabler of all silicon-based semiconductor application. The continuous development of new digital end-devices and applications that are smaller and more sensitive to contaminants – such as high resistivity wafers for 5G and 6G, 300 mm wafers for 2nm design rules, and wafers for CMOS image sensors – will thereby be dependent on having access to polysilicon that can meet the higher technical requirements. To this end, WACKER is currently planning a new etching line in Germany for producing “next generation polysilicon” (8000t/a) and is developing the project as part of the IPCEI Microelectronics. Against this background, WACKER welcomes the renewed commitment by the EU Commission to rebuild the semiconductor industry in Europe. The “European Chips Act” is essential to attracting investments in new advanced production facilities in order to safeguard the EU’s security of supply and supply chain resilience of semiconductors. WACKER would like to highlight the following concrete recommendations for the Chips Act Regulation: 1) Recognize and qualify semi-grade polysilicon for fast-tracked funding under the Regulation: - Electronic grade polysilicon must be recognized as an integral part of the semiconductor value chain and clearly included in the definition for the two types of facilities that are eligible to fast-tracked funding and construction/operation permits (“Open EU foundries” and “Integrated Production Facilities”). This would significantly help to secure the necessary funding for new projects, as polysilicon is a very capital-intensive segment, and allow prioritized access to setting up pilot lines or approval of State Aid under Art. 107(3) TFEU. Such funding opportunities should be eligible in parallel to already ongoing initiatives, such as IPCEI. 2) Allow OPEX-support to energy-intensive manufacturing for national State Aid - Besides being capital-intensive, polysilicon production is also very energy intensive. Electricity accounts for approx. 30% of total production costs and are much higher in Europe than in comparison to key competing regions, such as the U.S. or China. The price of electricity is therefore a crucial factor for determining the risk and profitability of new production after the initial CAPEX investment has been made. The Chips Act Regulation should therefore explicitly allow OPEX support to be part of State Aid schemes granted by Member States for new pilot lines, when it can be proven that uncompetitive OPEX costs (=electricity costs) are hindering new investment and the economic feasibility of new semiconductor projects. This would establish regulatory certainty both for Member States and for operators, when designing schemes and granting national state aid under Art. 107(3). 3) Push for a quick adoption to ensure first-mover-advantage / avoid further falling behind - Finally, we urge policymakers to swiftly pass the Regulation in order to stimulate additional investments into the semiconductor industry. The time window for securing “first-mover-advantage” is closing quickly due to a dynamic global market and investment agendas.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and EUROGAS and Wirtschaftsvereinigung Stahl

25 Nov 2021 · RED III

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

13 Sept 2021

Overall - Industry has achieved significant reductions in energy consumption due to efficiency improvements. Switching to low-carbon technologies such as process electrification or hydrogen will however significantly increase the industrial final energy demand. Absolute targets for measuring energy efficiency must not turn into “absolute caps on energy consumption” which could end up disadvantaging energy-intensive products and disincentivize investments into electrification. In detail - The proposed increase of the energy efficiency target for 2030 is in line with achieving the EU’s climate targets. The revision should thereby closely look at the different energy saving potential in sectors: The most cost-effective measures can be achieved in the building sector, especially by increasing annual renovation rates. - Industry has already achieved large reduction in energy consumption by constantly improving technological processes. The final energy demand is however set to significantly increase, if industry is to decarbonize through large-scale electrification of processes. This inevitable and politically supported trend generally conflicts with how energy efficiency is defined by the directive, namely through absolute reduction targets. - The policy incoherence between energy efficiency and decarbonization must be addressed for the long-term by making sure that energy efficiency targets o don’t prescribe mandatory targets for industry o don’t counteract investments into industrial electrification by putting a “cap on growth”; o don’t take a punitive approach towards energy-intensive production or products in particular in light of their essential role for reaching a climate-neutral economy.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

13 Sept 2021

Overall: - The access to ample and cheap renewable electricity is a precondition for decarbonization, in particular for industry which will have to achieve large-scale CO2-reductions via process electrification. The accelerated deployment of renewable energy, in particular wind and solar, is welcoming and should be supported with ambitious targets of at least 40% by 2030. However, as long as the access to globally competitive renewable electricity and feedstock cannot be guaranteed, binding targets should not be implemented for the industrial sector. This could introduce additional cost burdens on sectors at risk for carbon leakage, if supply cannot sufficiently cover the growing end-use demand in all sectors. In detail: - Achieving a 40% share of renewable energy in the EU’s final consumption is an ambitious target that needs to be prioritized. In particular the access to renewable electricity will be crucial in order to cover for the growing demand in all sectors, not the least through electrification of industrial processes or for the production of RFNBOs. - The multiple (sub-)sectoral targets for buildings, transport and RFNBOs will significantly increase direct and indirect demand for renewable electricity. Depending on the deployment rate, final market prices might not decrease in line with the falling costs of renewable electricity generation. In this scenario, export-oriented and energy-intensive industry will naturally be the last sector in the “price merit order” due to the cost competition from global markets. - WACKER therefore considers binding targets for renewable energy and feedstock use as generally not suitable for exporting industry as long as the market cannot guarantee globally competitive price levels for renewable energy and feedstock. This is the case for the proposal of introducing a 50% share of RFNBOs for overall hydrogen which does not consider potential negative impacts on competitiveness. o In a parallel procedure, the criteria for “eligible hydrogen” under Art.27 should be developed in a manner that considers the challenging circumstances of inland regions in meeting requirements on additionality, geographical and temporal criteria for the supply of renewable energy. - New system of “labelling of green industrial products” must be developed together with industry in order to avoid methodological incompatibilities.
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Response to Updating the EU Emissions Trading System

13 Sept 2021

Overall: - The ETS-proposal suggests a significant acceleration in the reduction of CO2-emissions by 2030 for industry, underpinned by a higher overall target of -61% and increased LRF of 4,2%. However, this is not followed through by an equivalent increase in protection against carbon leakage. According to the proposal, exposed sectors would see their free allocation reduced through updated benchmarks, new conditionalities introduced and higher cost insecurities imposed under the CBAM-regime. Weakening carbon leakage protection remains non-negotiable. Rather, financial incentives for CCU or via introducing Carbon Contracts for Difference will proactively help industry switch to low-carbon technologies and reduce emissions. In detail: - Existing carbon leakage protection measures, notably free allocation and indirect cost compensation, remain existential pillars for the competitiveness of exporting industry and cannot be reduced in light of increasing CO2-prices and reduction efforts. WACKER explicitly rejects: o updating the benchmarks for free allocation, as there has been no technological since the last update and it would cause legal uncertainty and financial harm for installations during 2021-2025; o the introduction of additional conditionalities for receiving free allocation in the form of investment obligations coupled to the energy audit under Art. 8 EED; o Phasing-out free allocation for sectors under the CBAM will shift the carbon leakage risk further down the value chain. As it provides no protection for exports, it is not an adequate instrument for replacing current mechanisms, as it cannot ensure EU competitiveness in global markets. - The proposal strikes an acceptable level of ensuring a fair-burden sharing between the ETS and non-ETS sectors in order to reach the -55% climate target. WACKER explicitly supports o the introduction of a CO2-pricing mechanism for emissions from road transport and buildings that is separate from the EU ETS. - The introduction of more financial incentives and funding for industry will proactively help companies switch to low-carbon technologies. o the recognition of CCU-technologies by not having to surrender certificates for CO2 permanently stored in products; o the increased budget for the Innovation Fund, however notes that this should not be financed from free allocation; o the introduction of Carbon Contracts for Difference under the Innovation Fund as a means to finance new projects;
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Response to Carbon Border Adjustment Mechanism

13 Sept 2021

Overall: - CBAMs do not offer any carbon leakage protection for European exports, as the instrument only focuses on imports within the EU single market and is therefore not fit to replace current mechanisms under the ETS. In particular export-intensive sectors such as polysilicon will suffer from a major loss of competitiveness in global markets, if free allocation and indirect cost compensation would be phased-out. Overall, risks outweigh opportunities, as there are many open question marks relating to practical implementation and compatibility, vulnerability to fraud and effect on global emissions. In detail: - The proposal suggests the introduction of a CO2 border tax for imports, with the objective of creating a level-playing field between EU and non-EU producers in the Single Market. However, as it does not include a rebate for exports, it does not provide any protection for EU producers competing in global markets and thus cannot be regarded as an adequate replacement for current carbon leakage protection mechanisms under the ETS. - A CBAM will also indirectly affect sectors that are not included in the scope by increasing the costs for imports and basic materials. This will shift the carbon leakage risk further down the value chains and decrease the competitiveness of end-products in global markets, further weakened by the stepwise cancellation of free allocation. - The proposal leaves many questions unanswered in terms of practical, legal and cross-border feasibility, not yet clarified by the proposal. This increases uncertainty for directly and indirectly affected sectors. Unpredictable and unwanted consequences embedded in the model contribute to the assessment that risks clearly outweigh the opportunities for EU exporting sectors, such as o the acceptance of CBAMs as non-protectionist and conform with WTO rules; o deteriorating trade relations following potential retaliation measures which disproportionally affect exporting sectors; o trade diversions to circumvent CBAMs and thus weakening the desired effect of reducing global emissions; o incomplete, bureaucratic and fragmented implementation due to difficulty of including and verifying all embedded emissions; - Carbon leakage protection and supporting the competitiveness of EU industry should rather be implemented BEHIND borders, such as by introducing an industrial electricity price. This would enable energy-intensive industry to compete on global terms while transitioning to climate-neutrality, without endangering trade relations.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Wacker Chemie AG (WACKER) is a leading specialty chemical company active in the silicone, polymer, life sciences and hyperpure silicon markets, with a strong manufacturing base in Europe. The hyperpure silicon, for which WACKER remains the only European manufacturer is supplied to the photovoltaics and semiconductor industries. With an energy consumption of 9.3 TWh (thereof 4.8 TWh electricity) in 2019 and about one million tons CO2 regulated under the EU ETS, WACKER remains reliant on European carbon leakage protection mechanisms to uph WACKER recommends the Commission to consider the following three aspects for the revision of the EEAG guidelines: 1. Objectives: Revision of the EEAGs must consider the global perspective of industrial competitiveness - The EEAG must extend its scope to include eligible measures aiming at addressing the competition distortions happening on a global level as a result of the growing ambition gap in terms of climate policy vis-a-vis third countries. Especially Europe’s energy-intensive sectors, such as the base material industry (e.g. chemicals), will need to undergo an internal transition from a fossil to largely renewable-based production within less than 30 years, while maintaining their competitiveness on global markets. It is safe to conclude that state aid will be needed to a much larger extent than before to manage the climate-neutral industrial transition. Existing industrial policy and carbon leakage measures alone will not be enough. 2. Compatibility criteria: Include support schemes for industrial decarbonization - Industrial decarbonization needs to be recognized as an eligible area for promoting the EU’s common environmental objectives. For this purpose, Member States should be able to adopt targeted, proportionate and limited support schemes on a national level. - Measures promoting industrial decarbonization should be defined in a technology-neutral way and focus on scaling-up technological routes via direct/indirect renewable electrification by making operational costs competitive in comparison to fossil production. This requires first of all the access to cheap and competitively priced renewable electricity. -National support schemes for promoting industrial decarbonization should be allowed to cover both CAPEX & OPEX expenses. This could be done via promising and already established instruments, such as (carbon or power) contracts for difference or power purchase agreements, where a public authority is involved in the financial set-up. 3. Energy-intensive users: More support needed to ensure access to low-cost renewable electricity - Current measures do not give enough incentives for direct or indirect electrification, as this technological route still shows much higher operational cost in comparison to fossil routes. As a primary focus for the decarbonization of energy-intensive users, the EEAG guidelines should therefore prioritize a secure framework that allows national measures to grant access to renewable electricity at competitive prices. This inevitably includes OPEX-aid. - It is noteworthy to point out that both volume and price of renewable electricity will be instrumental to address under national schemes, in order to adequately support energy-intensive industry: Access to volume guarantees the technological CO2-reduction, while access to low prices guarantees the global competitiveness. - A promising measure that should be considered for this purpose is the introduction of industrial electricity prices (figure 1). This model is based on the energy-intensive user concluding a contract for difference with a public authority, for which the strike price is agreed with respect to relevant global competition. The physical electricity delivered should preferably be generated by renewable installations. For this purpose, PPAs with solar utility parks or wind parks could be added as an element. Please find more information in the two-pager attached to this contribution.
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Response to Review of EU rules on fluorinated greenhouse gases

31 Jul 2020

WACKER is the world market leader and the only European manufacturer of high-purity polysilicon – the basic material for photovoltaic cells and semiconductor chips – and thereby holds a strategic position in the industrial value chains for enabling the green energy and digital transition in Europe. In line with the company’s own sustainability strategy SustainaBalance® and within the scope of its possibilities, WACKER actively supports the reduction of climate-damaging emissions from its production, including fluorinated greenhouse gases. Refrigeration systems with safety refrigerants [F-gases] are an integral part of the production process of polysilicon. These safety refrigerants have been carefully chosen to reduce the potential hazards in the systems, in particular with regards to flammability and explosivity. WACKER continues to work on improving its performance and has over the last years made significant financial investments and technical adjustments to reduce the environmentally harmful effects of F-gases. This includes conversion measures of its refrigerant systems by using refrigerants with a global warming potential below the limit of 2500, thereby replacing refrigerants with higher, above the limit GWP. For more information on how WACKER recommends to maximize safety, while focusing on replacing high GWP refrigerants and protecting state-of-the-art technology, please consult the attached consultation contribution.
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Response to 2030 Climate Target Plan

14 Apr 2020

WACKER welcomes the renewed climate efforts of the European Commission under the Green Deal. As Europe’s only manufacturer of hyper-pure polysilicon, the strategic raw material and first step in the solar panel value chains as well as for semiconductor devices, WACKER is already a significant contributor to the decarbonization of the energy sector and to the electrification of other sectors. A successful decarbonization must be defined under the premise that European industry stays globally competitive, thus avoiding relocation/substitution of production or investment leakage at a maximum level. The pathway to a climate-neutral industry 2050 is extremely challenging, but can be technologically feasible under the right conditions. As shown by many studies, electrification is one of the most promising technology routes with the highest potential of reducing emissions. However, to enable a higher rate of electrification that is economically viable in a global environment, the study identifies two inevitable prerequisites: 1) considerable volumes of emission-free electricity from renewable sources; 2) permanently low industrial electricity prices. To incentivize a higher rate of electrification in the energy-intensive sectors, both aspects need to be addressed. WACKER recommends that current carbon leakage instruments are complemented by introducing schemes for an industrial electricity price combined with an obligation to increase share of electricity produced via renewable sources. Such models should specifically aim at alleviating the competitive pressure arising from the significantly different levels of energy-related costs currently observed between global industrial regions. By using Contracts for Difference (CfD), it could guarantee a competitive price of electricity for European energy-intensive producers (Figure 2, see attachment). Additionally, if combined with mandatory Power Purchase Agreements (PPA) between renewable energy producers and industrial customers, an industrial electricity price could effectively contribute to ensuring that beneficiaries decarbonize in a predictable manner and enable a market-based integration of solar and wind energy. While the mechanism could be implemented and financed on the national level, the actual price level would be coupled and adapted on a regular basis to the respective price level developments of global key competitors. In order to be compatible with EU state aid, the Commission should include such national electricity pricing schemes aiming at decarbonizing industry in the upcoming revision of the Guidelines on State aid for environmental protection and energy. Please consult the attached paper for more information.
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Response to Carbon Border Adjustment Mechanism

31 Mar 2020

Summary of recommendations by Wacker AG: 1) The Commission should follow up on its recent commitment to strengthen existing carbon leakage instruments (free allocation and indirect cost compensation). As a minimum, current level of support must be guaranteed for the upcoming EU ETS phase 2021-2030. These measures have been recognized by the Commission to be effective in sustaining industrial competitiveness and they are compatible with international frameworks. 2) Existing carbon leakage instruments should be complemented with a European industrial electricity price, alleviating the energy cost pressure. Such a model could be based on Contracts for Difference (CfD) and implemented on a national level under the approval of EU state aid guidelines. If designed in combination with Power Purchase Agreements (PPA) for renewable electricity, an industrial electricity price could effectively contribute to decarbonizing energy-intensive industries and enable a market-based integration of solar and wind energy. 3) Due to uncertainty of legal and technical feasibility as well as practical difficulties of implementation, carbon border adjustment (CBA) mechanisms are not effective in replacing the existing instruments of carbon leakage protection in place under the ETS. It is thus of major importance that prior to any decision, the Commission conducts thorough impact assessments to substantiate its claims and provide sufficient evidence on the effectiveness of such measures. Please see te attached file for a more detailed version of the recommendations above and Wacker's position. ---------------------------------- WACKER is a technological leader in the chemical industry and manufactures products for all key global industries. It is active in the silicone, polymer, life sciences and polysilicon markets.
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