CEPE Challenges Critical Chemical Alliance’s Conclusions on Downstream Lead Markets 

 CEPE, the European Council of the Paint, Printing Ink, and Artists’ Colours Industry, is challenging the conclusions on downstream lead markets by the European Commission’s Critical Chemicals Alliance (CCA). CEPE supports CCA’s goal to strengthen Europe’s chemical industry, industrial competitiveness and the transition towards more sustainable products, but warns that these cannot be delivered without the full support of downstream industries. 

As an active participant in the CCA’s Working Group 4 on lead markets and market-pull measures, CEPE supports – wherever technically feasible and economically viable – the development and uptake of sustainable, low-carbon products and raw materials. However, it is concerned that the Working Group’s conclusions do not sufficiently reflect the diversity of views expressed during the process and that important questions remain unresolved. 

In particular, measures such as mandatory sustainable carbon content rules, levies or other schemes risk weakening downstream competitiveness and consumer affordability, and risk placing responsibility on companies that do not control upstream data or production. These impacts need to be assessed across the entire value chain, including their implications for SMEs, product performance, sustainable feedstock availability and the competitiveness of European manufacturers. 

Christel Davidson, Managing Director of CEPE said: “We regret that CEPE’s views were not better reflected in the outcome of the process. Given the pace of the exercise and the pressure to deliver conclusions, we do not believe that the necessary analysis and discussion have taken place to allow us to endorse the conclusions at this stage.” 

Downstream industries have practical experience with product performance, safety, regulatory compliance and market acceptance, and CEPE believes these need to be fully considered when designing future policy measures. Priority should be given to measures that increase the availability of sustainable feedstocks, reduce investment risks, support industrial scale-up, foster innovation and strengthen value-chain cooperation. 

Davidson concluded, “We remain committed to constructive engagement with the European Commission and stakeholders across the value chain to develop practical, proportionate and effective measures that advance decarbonisation while strengthening Europe’s industrial competitiveness.”