EU initiative proposes criteria to identify “critical” chemical molecules and sites and proposes actions to ensure security of EU supply and of EU production. P4* is initially identified as a “critical molecule)., because of EU supply vulnerability (import dependency, logistics, exposure to energy and CO2 costs), and importance of the molecule for the whole chemical industry (value chain centricity) and for strategic industry sectors (electronics, defence and aeronautics, energy transition). ESPP, represented by Vincent van der Meijden (Filo Chemicals) has closely engaged with the Critical Chemicals Alliance (Working Group 1) and submitted P4 (elemental phosphorus) and Purified Phosphoric Acid (PPA) to the assessment methodology testing, with input from our network of industry experts. The CCA WG1 final report identifies P4 (termed Red Phosphorus) in a “non-exhaustive” draft list of 49 possible Critical Molecules”. Ammonia and potassium hydroxide and potassium chloride are also included in the list.
Critical Chemical Sites are identified as those producing a Critical Molecule, or those with specific vulnerability (last of a kind) or importance for strategic industry sectors.
To our understanding, Phosphate Rock cannot be a “Critical chemical molecule” because it is primary raw material. Both P4 (“Phosphorus”) and Phosphate Rock are EU Critical Materials. This is independent of this Critical Chemicals Alliance (CCA) process.
The CCA WG1 proposes that Critical Molecules should be supported by:
· EU monitoring
· Prioritise Critical Molecules for Trade Defence Instruments, including for derivates of Critical Molecules, and strengthen these instruments
· authorisation of State Aid to producers of Critical Molecules
· competitiveness protection by energy cost relief and ETS adjustments, providing long-term visibility on energy costs
· simplified permitting for Critical Chemical Sites
· Capex and Opex support for Critical Sites.
ESPP responded to these proposals by welcoming the quality achieved by the Alliance in a short time, under the very active leadership of the French Ministry for Economy. ESPP welcomes proposals to protect high embedded energy chemicals by e.g. CBAM (Carbon Border Adjustment Mechanism) to avoid undercutting by imports from countries with subsidised or cheap energy (and so offshoring of greenhouse emissions). ESPP also makes a number technical comments and proposals.
The CCA Working Groups 2, 3 and 4 have also published final reports, with policy recommendations for (WG2) improving EU trade defence, (WG3) investments and (WG4) developing lead markets. The WG4 proposals for lead markets centred on Product Carbon Footprint and the proposal to fix “minimum sustainable carbon content requirements” in end-markets, with tradable certificates, as well as possibly tariff modulation of EPR (Extended Producer Responsibility) levies on end-products.
Environmental organisations (ChemSec, EEB – European Environment Bureau) have criticised the CCA as being an industry platform, and the outcomes as defending energy-intensive chemicals. Chemsec and EEB also criticise that the CCA’s dfarft list of 49 possible “Critical Molecules” includes PVC (a halogenated polymer) and PTFE (a PFAS chemical) and a number of other hazardous chemicals.
Downstream users of chemicals (several federations joint statement here) have also criticised the CCA outcomes, in particular proposed mandatory content, carbon levies and similar, which would increase costs downstream, and impact both manufacturing and commerce in Europe and consumers.
The European Commission (Commissioner Séjourné) has announced that it will now work with JRC to identify by end 2026 a significantly smaller number of critical chemicals (than the CCA’s draft list of 49), in particular targeting defence, healthcare, clean technologies, and basic building block chemicals underpinning multiple industry value chains. The Commission promised action to protect critical chemical industries from unfair international trade, to develop “lead markets” and to define with JRC criteria for low carbon and sustainable chemicals.
The European Chemicals Industry (Cefic) has expressed full support for the CCA’s conclusions, asking that the European Commission implement the CCA recommendations rapidly through the Biotech Act II, Circular Economy Act, Industrial Accelerator Act and the ETS reform
* P4 is termed “Phosphorus” (as in the EU Critical Raw Materials Act (2024/1252), meaning white/yellow/red elemental phosphorus, the specific form of phosphorus today produced in dedicated furnaces, with no production in Europe, and the EU nearly entirely dependent on Kazakhstan and Vietnam. P4 is essential for a wide range of chemical processes, from doping silicon for PV panels to production of most organophosphorus chemicals (needed for all lithium battery electrolytes, fire safety, catalysts, pharmaceuticals …).
EU Critical Chemical Alliance Working Group deliverables (final reports, WGs 1-4) published on CircaBC : https://circabc.europa.eu/ui/group/cbc2bb9c-a86b-4d95-a1e6-9b03a6efe69f/library/4e31be6c-266b-429a-ae3b-0c8e97620419?p=1&n=-1&sort=name_ASC)