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We are pleased to present our Activity Report, taking a look back at our activities in 2022.

As highlighted by our President, we are living in an extraordinary time, full of challenges and opportunities alike. Throughout 2022, we faced a post-pandemic world filled with geopolitical uncertainty, a challenging macroeconomic environment exhibiting itself primarily through the increasing energy costs, high inflation and continued supply chain disruptions.

Despite this, EGMF has responded to the challenges and has adapted to a new competitive landscape, embraced new ways of working and never stopped innovating!

In our review you can find out all about the work that has kept us busy, including markets surveys, and new and ongoing regulatory and advocacy activities.

This was also a very special year as we celebrated our 45th anniversary!

Download the Activity Report.

As a special highlight from our General Assembly meeting held in Brussels on 23 November, we are delighted to welcome Kärcher as a new member of EGMF.

Kärcher is the world’s leading provider of cleaning technology. The family-owned enterprise employs 14.400 people in 80 countries and 150 subsidiaries. More than 50.000 service centres in all countries ensure continuous and comprehensive supplies to customers all over the world. 

You can find out more about them here.

In September, EGMF, together with several other industry organisations, signed a joint industry statement that urges the EU institutions and Member States to ensure consistency within the New Legislative Framework (NLF) terminology. The NLF is important to industry as for over a decade it has provided a comprehensive regime for market surveillance, improved the quality of conformity assessment, and enhanced regulatory certainty and ease of compliance.

This joint statement focuses in particular on the proposed regulation establishing harmonised rules on artificial intelligence, the Artificial Intelligence Act (AI Act). The AI Act builds on the legal architecture of the NLF for products while adapting it to its specificities. The NLF represents a blueprint for a range of product legislations and EGMF supports the incorporation its principles into the AI Act. However, it is essential that this is done in a coherent way by policy makers and that additional layers of AI-specific requirements, and in the future other product-specific legislation, do not affect the good functioning of the NLF. Promoting alignment of the AI Act with horizontal and sectoral legislation is also a means of encouraging legal clarity in regulatory compliance.

More concretely, the statement aims to provide high-level recommendations to policy makers in the European Parliament, currently drafting compromise amendments to the AI Act, and to raise their awareness of the requirements of NLF legislation.

The joint statement was shared with policy makers in late September.

EGMF, together with 30 other industry organisations, provided the downstream users perspective on the potential inclusion of lead metal in REACH Annex XIV. Before proceeding with the inclusion of a widely used and critical substance such as lead, we strongly recommend to the EU Commission and ECHA to first launch an deep and detailed impact assessment and figure out the normative requirements that reference to REACH Annex XIV. This is critical to decide if the benefits from adding lead to REACH Annex XIV would outweigh all the consequent impacts.

EGMF also published a position paper regarding the potential consequences for garden, landscaping, forestry and turf equipment manufacturers, since lead in alloys is essential for the reliability and durability of garden and outdoor power equipment.

To read our recommendations in full, please download the EGMF position paper and the joint industry document.

EGMF, together with 10 industry associations, published a joint statement on the EU Emission Trading System (ETS) and carbon border adjustment mechanism (CBAM).

Under the Commission’s ETS and CBAM proposals, manufacturing goods in the EU will incur additional costs that are not necessarily faced by third country manufacturing industries who produce the same goods. This will impact our sectors’ competitiveness on domestic and non-EU markets and may incentivise carbon leakage in manufacturing industries.

Therefore, we call on the Commission, Council, and European Parliament to take the necessary steps to assess the competitiveness impact of CBAM on downstream users of goods that will be subject to this measure to help prevent carbon leakage from EU manufacturing to outside Europe, before the financial impact of CBAM harms EU industry.

Read the full statement here.

EGMF, together with 30 other industry organisations, acknowledges the proposal on essential uses in the Chemicals Strategy for Sustainability (CSS) and welcomes the policy debate that has arisen regarding the Essential Use Concept (EUC). It is encouraging to see that suggestions in the ensuing policy debate point to creating a framework for applying the EUC, rather than simply a black and white listing of uses, and that its application will require a case-by-case assessment. However, even with such a framework and case-by-case approach, we have concerns that introducing the EUC could adversely affect regulatory efficiency and negatively impact safe uses of articles and overall sustainability. In this paper, we outline our thinking about a scope of application of the EUC that would account for some concerns.

The clarification of the scope of application is especially important as the Montreal Protocol, which inspired the ongoing policy debate, has a much narrower scope and addressed unacceptable risks (not simply hazard). The initial proposal of the Commission in the CSS was to apply the EUC purely on a hazard-basis, i.e. to all ‘most harmful chemicals’ and to ban their consumer (and professional) uses, except essential ones, regardless of whether they present a risk.

To read our recommendations in full, please download the document.