Environmental protection is one of the major global challenges of our time. Environmental regulations are becoming more and more complex. European and national regulations are increasingly overlapping. LANXESS is participating in the regulatory debates with the aim of finding joint solutions.

Approval procedure

Fast and legally compliant approval procedures are in the interest of both industry and the authorities. Digitization can help here. However, sensitive plant data must not be completely accessible on the Internet. This can lead to unintentional misuse. To speed up approval procedures, LANXESS has launched a pilot project in 2018 in cooperation with the North Rhine-Westphalia Ministry of Economics, the Cologne district government and the Chempark service provider Currenta. The approval period (new construction of a Fluorosulfonic Acid plant) was successfully shortened from 20 to 12 months. The permission for the early start of construction was granted after six months.

Emission control

The EU is continuously developing new emission reduction requirements for industrial plants. Increasingly strict limit values and detailed regulations apply. LANXESS is constantly pressing ahead with its own reduction projects, but is also seeking compromises that take into account both environmental protection and industrial production.

Water protection

Water protection is a central issue for LANXESS and is treated with care. Production cannot take place without discharge permits, and in order to obtain these, it must be demonstrated that the waters are managed sustainably and that the limit values are not exceeded.

Soil protection

Installations under a permit procedure may only be put into operation after a comprehensive "soil status report" has been submitted, which must also be updated regularly. In the field of soil protection, LANXESS is facing ever more stringent requirements, the national scope of which often exceeds European requirements and whose benefits are in some cases not apparent.

Plant safety

There must be an appropriate safety distance between industrial plants and residential or nature conservation areas and traffic routes. The protection of the population is the central aspect of plant safety, and LANXESS takes this into account at all times. However, the debate on distance regulations must not only consider industrial production, but also possible new developments outside the industrial site.

LANXESS is actively committed to a high level of chemical safety in order to protect human health and the environment in the long term. Compliance with legal requirements such as the REACH regulation is a top priority for us.

Successful registration of LANXESS products

LANXESS has successfully registered around 900 chemical substances under REACH and subjected them to a detailed safety assessment. In total, over 23,000 chemicals have been registered with the European Chemicals Agency in the EU. The EU thus has the world's largest and most comprehensive data set on chemical substances.

Transparency and legal certainty increase competitiveness

For a correct and conscientious implementation of legal requirements concerning chemicals, however, legal certainty is required. This is not given if one and the same chemicals is subject to a multitude of regulations with different, sometimes difficult to understand, evaluation standards.

This is why LANXESS is calling for transparent and predictable processes for the evaluation and regulation of chemicals based on uniform scientific standards and methods, particularly in view of the EU sustainability strategy for chemicals. This is the only way to ensure that the competitiveness and innovative capability of the chemical industry is maintained under the high safety requirements of EU chemicals legislation, which are high by international standards.

Fuel Emissions Trading Act (BEHG)

The amendment to the EU Emissions Trading Directive provides for a CO₂ levy obligation for the fuel supply (so-called ETS II) from 2027 and the inclusion of municipal waste incineration plants in the emissions trading system (ETS I) from 2028. At national level, political efforts are focused on ensuring the smoothest possible transition from the German CO₂ pricing system, which has been in place since 2021, to the European ETS II. However, the pricing of hazardous waste is expressly excluded in ETS II.

For hazardous waste incineration plants, this means that they will not be covered by either ETS I or ETS II. A “smooth transition”, as agreed in the coalition agreement, is therefore not possible for the incineration of hazardous waste. The costs and benefits of an independent national system for the pricing of hazardous waste alone are disproportionate and place an additional burden on the competitive situation of the chemical industry.

We therefore advocate that the German government should fundamentally reconsider the CO₂ pricing of hazardous special waste. These unavoidable and hazardous material flows from the chemical industry are rendered thermally harmless in central hazardous waste incineration plants. It is not possible to recycle this hazardous waste, which means that CO₂ pricing cannot have a steering effect. This increases the disposal costs of the chemical industry without any alternative.

EU emissions trading

As long as there is no international level playing field for CO₂ pricing, the allocation of sufficient quantities of free allowances must be ensured as a safeguard against carbon leakage. We consider the Carbon Border Adjustment Mechanism (CBAM) in its current form to be an unsuitable protective instrument, as it does not cover all stages of the diverse and highly complex chemical value chain.

Electricity costs

We are concerned about the high electricity costs in Germany. By permanently reducing the electricity tax to the European minimum level, the German government has taken important measures to stabilize electricity costs. However, not only the system and grid expansion costs resulting from the energy transition but also the market electricity prices have been rising for years and will continue to worsen the competitive situation in Germany in the future. The impending abolition of the reduced industrial grid fees will exacerbate this situation.

According to the Federal Network Agency's plans, relief will only be granted in future for electricity consumption that is adapted to volatile solar and wind power generation. As a specialty chemicals company, however, we are dependent on a consistent power supply, particularly at our Verbund sites, in order to maintain our closely coordinated chemical production processes. Flexibility in electricity consumption can only be achieved - if at all - in a coordinated group effort. For this reason, we are advocating generous transition periods, the consideration and observance of the limited flexibility potential in the chemical industry and consortium approaches in chemical parks across several companies in the upcoming reform of grid fees.

Furthermore, we call for relief from market electricity prices by reinstating all chemical sectors into the electricity price compensation scheme.