The European Council of the Paint, Printing Ink, and Artists’ Colours Industry (CEPE) has officially challenged the recent findings of the European Commission’s Critical Chemicals Alliance (CCA) regarding downstream lead markets. While the trade body expressed support for the alliance’s overarching goals of strengthening industrial competitiveness and facilitating a sustainable transition, it warned that these objectives are at risk if policy design excludes the practical realities of downstream manufacturers.
The dispute centers on the conclusions reached by the CCA’s Working Group 4, which has been tasked with identifying market-pull measures to encourage the adoption of low-carbon products. CEPE, an active participant in these discussions, argues that the final report fails to adequately represent the diverse range of technical and economic concerns raised by industry representatives during the deliberation process.
According to CEPE, the proposed measures—such as mandatory sustainable carbon content rules and potential industry levies—could inadvertently stifle growth. The organization cautioned that such policies might weaken the competitiveness of European manufacturers and compromise consumer affordability. Furthermore, CEPE highlighted a significant accountability gap, noting that these regulations risk placing the burden of sustainability compliance on downstream companies that have little to no control over upstream production processes or raw material data.
“We regret that CEPE’s views were not better reflected in the outcome of the process,” said Christel Davidson, Managing Director of CEPE. “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.”
The association stressed that downstream industries possess unique, hands-on expertise regarding product performance, safety standards, and market acceptance. They argue that any future policy must account for these factors to avoid unintended consequences, particularly for small and medium-sized enterprises (SMEs) that may struggle with rigid mandates.
Rather than punitive or overly prescriptive measures, CEPE is calling for a policy shift that focuses on structural support. The industry body advocates for measures that prioritize the increased availability of sustainable feedstocks, the reduction of investment risks, and the active support of industrial scale-up. By fostering innovation and strengthening cooperation across the entire value chain, CEPE believes Europe can achieve its decarbonization goals without sacrificing its industrial strength.
Despite the current friction, CEPE maintains that its departure from the CCA’s current consensus is not a rejection of progress. Davidson emphasized that the organization remains dedicated to working with the European Commission and other stakeholders to refine these strategies. The goal, she noted, is to develop “practical, proportionate and effective measures” that reconcile the urgent need for environmental sustainability with the imperative of maintaining a robust and competitive European manufacturing sector.
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