Environment, health and safety
Here you will find the key current topics of our advocacy work.
Subject Overview
Biodiversity is a globally emerging topic alongside climate issues. For example, the World Economic Forum has estimated that over half of the world’s GDP depends on nature. In the fall of 2022, at the UN Montreal-Kunming Biodiversity Conference, it was decided to protect 30% of the Earth’s surface by 2030, along with other measures to strengthen declining biodiversity. In connection with the EU Green Deal, the EU’s biodiversity strategy was published, with the goal of restoring European biological diversity by 2030 for the benefit of people, the climate, and the planet. Biodiversity is now playing a new role in EU decision-making and may affect, for example, permits for chemical industry companies or raw materials. Nationally, biodiversity has also become a pressing issue and is reflected in legislation, such as the recently revised nature conservation law, which includes voluntary ecological compensation.
The Goal of the Chemical Industry
The goal of nature-positive, carbon-neutral chemistry by 2045 was set as the first milestone in biodiversity work in August 2022. During the spring of 2022, the role of the chemical industry in relation to biodiversity was examined, leading to an action plan and a timeline similar to a climate roadmap. Through impact assessments, we also gain a better understanding of how the chemical industry should engage in advocacy issues related to biodiversity. Another important goal is to increase awareness among companies regarding biodiversity, such as through training and guides provided to businesses. The aim is for 70% of chemical industry member companies to set biodiversity goals in their strategies by 2025. In addition, the chemical industry actively participates in the development of global terminology.
We influence by:
- Contributing to the development of the ISO SFS Biodiversity standard.
- Raising awareness on the topic in Cefic.
- Highlighting the nature-positive perspective in our national advocacy and statements.
- Internally, through a Biodiversity ad hoc group composed of representatives from member companies.
- Sharing best practices through the Responsible Care program.
We monitor:
- The EU Business and Biodiversity platform.
- The ICC Biodiversity working group.
- EU-level discussions in the Commission and Parliament.
Current Situation and Timeline
The goal has been set. Next, we will raise awareness among companies, participate in the development of the ISO Standard, share best practices, and advance nature-positive, carbon-neutral chemistry!
Additional information:
The 2022 Montreal-Kunming agreement
EU Biodiversity strategy 2030
The national implementation of the CER directive approved by the EU is underway. The directive pertains to the resilience of nationally important companies in the face of disruptions. A Finnish legislative proposal is expected to be ready for review by the end of 2023. The law is set to come into effect on October 18, 2024, pending approval by the parliament in the spring of 2024. Together with the NIS2 directive, the CER directive forms the basis for preparedness against security threats.
It is not yet known which companies will fall under the scope of the law. The law will categorize companies it applies to as either essential or important. Essential companies will be required to report in advance to the authorities. Important companies will be inspected by the authorities based on their own schedules. In general, the categorization of companies will follow the NIS2 directive.
The law’s requirement for companies to prepare for various security threats is broad and challenging to implement because it is unknown what kinds of threats criminal entities may pose to companies in the future. The successful implementation of the law requires strong cooperation between companies and authorities. Authorities must first conduct a national risk assessment. Based on national risk assessment companies falling under the scope of the law will conduct company-specific risk assessments. Due to these risk assessments and the resulting actions, it is likely that the law will have long transition periods.
Kemianteollisuus ry (Chemical Industry Federation of Finland) is monitoring the progress of the law’s preparation through stakeholder events, organizing information seminars for member companies, and communicating the perspectives of the chemical industry to the lawmakers.
The revised Dangerous Substance Transport Act (Vaarallisten aineiden kuljetus, VAK Act, in Finnish) came into effect on September 1, 2023, and it now forms a comprehensive framework for requirements in all four modes of transportation – road, rail, maritime, and air transport. The goal is to streamline regulations, eliminate ambiguity, and address deficiencies. Finland’s national VAK Act is now more aligned with international regulations. Above all, the law aims to enhance transportation safety in Finland.
The VAK Act is extensive and covers a wide range of activities. In addition to the VAK Act and its related regulations, more detailed guidance will be needed from the Finnish Transport and Communications Agency on how operators should proceed in specific situations. Furthermore, the regulatory oversight responsibility will shift to the authority (Traficom). These changes emphasize the growing involvement of the authority in transportation safety and increased collaboration between businesses and authorities.
The law establishes uniform standards for the temporary storage of dangerous substances. Emergency plans and safety assessments prepared for this purpose enhance the ability of both businesses and authorities to respond to hazardous situations and, most importantly, help prevent them. However, this also requires more effort and resources from all parties involved.
The law places significant emphasis on the chemical and safety expertise of both drivers and companies responsible for transportation. The role of safety advisors in companies becomes more crucial.
Subject Overview
The purpose of renewing legislation on batteries and accumulators is to modernize the legal framework to better align with a new operational environment. The regulation was published on January 20, 2023, and it replaces the previous battery directive. This regulation is part of the European Green Deal and includes various targets to be implemented in different years, such as those related to the collection, recycling, and labeling requirements for batteries.
The Goal of the Chemical Industry
The development and production of batteries are crucial growth factors in Europe, and significant investments are planned for the near future. The goal is to develop the entire battery value chain within the EU, covering sustainable mining and refining of materials, battery cell manufacturing, and recycling business. The objective is to promote the business activities of Finnish companies in the battery industry throughout the entire value chain.
Subject Overview
In the fall of 2020, the Commission released a sustainability-focused chemicals strategy (Chemicals Strategy for Sustainability). The goal of the chemical strategy is to enhance chemical safety and support the production, innovation, and investments in chemicals aligned with sustainable development. The core of the strategy consists of around 60 different legislative proposals related to REACH registrations, expanding the control of substances of concern, restrictions based on substance properties, and new chemical classifications. Some of the proposals have already been implemented as regulations, and the target timeline for the full implementation of the strategy is by the year 2024.
Objective of the Chemical Industry
The industry’s concerns revolve around the predictability of regulations and adherence to the principles of better regulation. Pushing through dozens of legislative proposals within a tight schedule, as outlined in the strategy, requires substantial resources both from the Commission and national authorities. Especially, the assessment of the proposals’ impacts may remain superficial, as well as ensuring the cost-effectiveness and scientific basis of the proposed actions and demonstrating their safety-enhancing effects.
It is also important to initiate actions that support innovation, maintain strategic value chains and production within the EU, provide funding for the promotion of safe and sustainable products, and invest in skills development. In the implementation of the numerous legislative proposals of the strategy, the focus should be on those that can genuinely enhance safety. Resources within companies, authorities, and EU institutions are limited. Therefore, the preparation and implementation of proposals should be prioritized and phased to adhere to the principles of better regulation. The strategy includes various framework terms, such as essential uses, safe and sustainable by design, and a general risk-based approach, which need to be defined before they are applied in regulations.
The actions of the chemical strategy should support the goals of the EU’s Green Deal and attract investments for the green transition within the Union. The EU will continue to need safe chemicals, for example, for solutions related to the hydrogen economy, battery technologies, and the circular economy.
Subject Overview
The EU’s Industrial Emissions Directive (IED) is one of the fundamental documents for environmental permitting, and its revision has an immediate impact on companies’ environmental licensing obligations. The revision of the directive has been prepared at the EU Commission for a couple of years and is based on the EU Green Deal’s objectives of Zero Pollution, Climate Neutrality, Biodiversity, and a cleaner, more Circular Economy. The Commission published the draft revision of the directive in the spring of 2022. The Industrial Emissions Directive serves as a background directive for Best Available Techniques (BAT) reference documents, which provide regulations on the best available technology for different industries and activities across Europe.
The Goal of the Chemical Industry
The Industrial Emissions Directive is one of the most significant directives guiding the operation of chemical industry facilities. The directive applies to over 80 chemical industry facilities in Finland.
In early summer 2022, a survey was conducted among member companies of the Chemical Industry Association regarding the Commission’s proposal for changes to the EU Industrial Emissions Directive. Generally, companies saw the proposal as quite challenging, partly increasing costs or being impractical without significant or yet nonexistent innovations. On the other hand, there was a perception that the proposal increased bureaucracy, prolonged permit processing times and costs, but still allowed operations to continue, and the costs incurred were somewhat reasonable in relation to the requirements. Companies are most critical of the requirement to apply the strictest possible emission limit values in the permitting process, to the extent that it is feared to negatively impact profitability. Additionally, in line with the nature of the chemical industry, it is simply not possible to push all parameters to the lower limits. For example, if the purification of a certain emission is increased, energy consumption may rise. The Commission’s growing demands for the disclosure of various information have also raised significant concerns within the chemical industry, especially regarding the confidentiality of information, particularly related to business secrets.
Only the promotion of innovations was clearly seen as a positive new opportunity, although there are still uncertainties associated with its key elements, which is why no company was certain about utilizing this opportunity. To enable companies to truly seize the opportunity and promote the emergence of new innovations, the proposal should be further refined. The development of new technology always entails the risk of failure, and this should be addressed in the proposal in a more encouraging rather than discouraging manner.
The Industrial Emissions Directive will expand its scope in many areas. From the perspective of the chemical industry, key decisions concern the battery value chain and hydrogen plants.
The chemical industry has been an active member of the national background group and continues to follow the trilogue negotiations.
Current Situation and Timeline
The European Commission’s proposal for the revised Industrial Emissions Directive was released in April 2022. During the summer of 2023, both the Council and the Parliament reached their general positions. In the fall of 2023, the trilogue phase is expected, which is anticipated to lead to the approval of the directive by early 2024 at the latest. National implementation will begin in early 2024, and member states will have two years to incorporate the directive proposal into their national legislation. In Finland, this largely concerns the Environmental Protection Act.
In connection with the Industrial Emissions Directive, the latest BAT conclusion for waste gases in the chemical industry was published in the fall of 2022. This BAT is currently the most significant BAT for a large portion of chemical industry facilities.
We influence by:
- Participating in the work of the Ministry of the Environment’s national background group.
- Promoting our messages in Cefic working groups.
Additional Information and Materials
Overview of the Industrial Emissions Directive on the European Commission’s website.
Council’s agreement on amendments to industrial emissions directive.
Download the draft proposal here.
The national implementation of the EU-approved NIS2 directive, which concerns cybersecurity, is underway. Finland’s national legislative proposal will be prepared for review during the year 2023. The law is expected to come into effect on October 18, 2024, so parliamentary approval should occur in the spring of 2024.
This law is an improved version of the old NIS directive. For the chemical industry, the new law is significant because it now falls under the directive’s scope. The law will categorize applicable companies to as either essential or important. Essential companies will be required to report in advance to the authorities. Important companies will be inspected by the authorities based on their own schedules.
The requirement for companies is to prepare for all cyber security threats. In practice, this is challenging and depends greatly on the types of threats that criminal entities may pose to companies in the future. The successful implementation of the law requires strong cooperation between companies and authorities. Additionally, inter-company information sharing is crucial to quickly identify threats.
Kemianteollisuus ry (Chemical Industry Federation of Finland) will monitor the progress of preparation of the law through stakeholder events, organize information seminars for member companies, and communicate the perspectives of the chemical industry to the lawmakers.
Subject Overview
The EU Commission has developed an action plan for Zero Pollution. The goal is to better prevent, manage, monitor, and report on the pollution of water, air, and soil. The aim is also to separate economic growth from an increase in emissions, strengthen the connection between environmental protection, sustainable development, and human well-being, and mainstream the Zero Pollution concept into all regulations.
The Zero Pollution plan serves as a starting point and a cross-cutting idea for future legislative projects. It impacts various initiatives in energy, industry, transportation, agriculture, biodiversity, and particularly climate issues and chemical strategy. Zero Pollution is a key part of the EU’s Green Deal.
The Zero Pollution package includes several draft directives or proposals for revisions, such as the revision of the urban wastewater directive, the drinking water directive, the healthy soil directive, and environmental targets related to water.
The Chemical Industry’s Position
The chemical industry is strongly committed to the principle of “preventing harm to humans and the environment” and continuously seeks to improve by reducing its emissions. This commitment can be verified through our Responsible Care indicators. The products and solutions produced by the chemical industry play a crucial role in achieving the Zero Pollution goal, which, according to the EU Commission, does not mean zero emissions but rather a balance between potential harm and benefits, with a net positive impact.
Crucial for the realization of the Zero Pollution goal is broad cooperation and open dialogue among various stakeholders to create an effective policy framework that enables the significant investments required to implement the Green Deal as a whole. This policy framework should build upon existing and proven legislation.
The chemical industry is closely monitoring the draft proposals for the urban wastewater directive and the directive concerning soil health.
Current Situation and Timeline
The EU Commission released its Zero Pollution Action Plan concept in May 2020. In October 2022, a new Zero Pollution package was published, addressing air quality, urban wastewater, and changes to the substance listings of the Water Framework Directive. In the summer of 2023, a proposal for a directive concerning soil health was published.
Additional information and materials:
Read more on the Zero Pollution Action Plan
SOIL
What This Is About
As part of the EU Green Deal, the EU released the Soil Strategy in 2021, with the vision that by 2050, all EU soil ecosystems will be healthy, requiring determined changes in this decade. As a measure to improve soil quality, the Commission released the Soil Health Directive in the summer of 2023. It includes elements such as regional monitoring of soil conditions, harmonization of soil sampling and analysis, continuous monitoring, principles for sustainable land use, identification of contaminated areas based on risk assessment, and the implementation of risk reduction measures.
The Chemical Industry’s Goal
The chemical industry emphasizes risk-based assessments and actions in various evaluations and activities related to soil. Through anticipation and strong environmental expertise, soil contamination is sought to be prevented using the best possible methods.
Current Situation and Timeline
The European Commission released the Soil Strategy as part of the Green Deal program in 2021. The Commission’s proposal is under consultation in the fall of 2023. The proposal will be discussed in the Parliament and the Council in the fall of 2023, but a more specific timeline is not yet available.
Additional Information and Materials
Commission’s proposal and consultation service.
Sami Nikander
Director, Responsibility +358 40 567 4413 sami.nikander(a)kemianteollisuus.fi Show infoSubject Overview
In the future, the chemical industry will require a huge amount of alternative raw material sources, to replace virgin fossil raw materials and energy. Alternative sources include all captured carbon dioxide, recycled/reused carbon (waste), and sustainable bio-based carbon sources. In addition, the chemical industry will need significant amounts of renewable and low-carbon hydrogen. On the inorganic chemistry side, there is a great need to find the best material solutions. A good example is the growing need of batteries and battery chemicals.
Reducing virgin fossil raw materials will often reduce also the dependence on imports and increase the level of raw material security.
The development processes for new raw materials have been going on for some time and new sources have been found and adopted whenever possible. The work, however, has been challenging as each new source must be carefully evaluated. Often restricting factors and/or other challenges are found during the evaluation.
In addition, the legislation does not support the alternative raw materials which slows down the transition and, at worst, completely prevent investments.
The Commission published a communication on industrial carbon management (ICM) and 2040 climate targets in February 2024. The ICM communication describes the role of carbon capture, storage and utilization in the future, as a part of the 2040 climate framework. The role of carbon cycles seems to be connected better in the climate policy framework and this is expected to be reflected in further discussions.
Objective of the Chemical Industry Federation of Finland
All alternative sustainable carbon sources should be favoured instead of virgin fossil raw materials, and legislation should support this principle. The EU therefore needs to ensure that sufficient comprehensive Circular Carbon Strategy will be prepared. This strategy should support all technologies that are need for circular economy and different carbon loops (chemical and mechanical recycling, (B)CCU technologies, bio-based carbon sources etc).
CO2 calculation rules in the emissions trading sector, effort sharing sector and land-use sector are currently inadequate. For example captured carbon or negative emissions are not properly accounted in ETS. The Commission has identified ETS as a key element in the future climate, but the calculation rules should be fixed so that technologies related to CCS/U would become more common and new raw material alternatives could become reality. In addition, the role of carbon removal certificates should be clarified. These certificates could be used to connect carbon removals to the ETS, which might solve some challenges related to calculation rules.
The legislative framework should favour the development of a hydrogen economy including green hydrogen as well as other emission-free ways of producing hydrogen and low carbon hydrogen. By-product hydrogen should be acceptable and comparable to renewable hydrogen.
Too strict technology guidance is not needed. In certain situations, however, it is justified to target legislation to promote certain new technologies or environmentally friendly products. For example, the double counting for the advanced biofuels category is justified in order to bring advanced fuels
into wider use. Otherwise, multipliers should be abandoned, and real emission reductions should be favoured.
It is important for the chemical industry that the sustainability rules for renewable fuels are kept unchanged to maintain the operational capability of current and planned investments. Long-term and predictable politics are essential for industrial investments.
The need for investment subsidies will be huge. However, it is important to maintain access to subsidies for all member states within the EU and avoid subsidy competitions between member states. For example, a “carbon bank” as a form of support could be justified from this perspective.
Competitive industry enables the raw material revolution and the implementation of carbon cycles. More precise information can be found from the CIFF 2040 onepager.
Our advisors:
Sami Nikander
Director, Responsibility +358 40 567 4413 sami.nikander(a)kemianteollisuus.fi Show info
