A Year in Review
Focus on EU Regulations and Initiatives
Relevant to our sector.
From the ETS Chlorine benchmark to State Aid, electrification and PFAS, this year's regulatory agenda bears directly on the cost base and the licence to operate of every Chlor-Alkali site in Europe.
EU Emissions Trading System (ETS) Chlorine Benchmark 
Priority action
What is at stake?
Carbon costs under the EU ETS remain a priority concern for Euro Chlor members. As the Commission prepared for the broader ETS revision, it was tasked with proposing benchmark values for the 2026-2030 allocation period. This includes those related to indirect Carbon costs. However, a Commission communication in December 2025 suggested that there were no plans to revise existing benchmarks, including the Chlorine one, focusing instead on newly eligible sectors.
The current Chlorine benchmark is based on Oxygen Depolarised Cathode (ODC) technology, which accounts for less than 1.5% of EU production and does not reflect the energy performance of mainstream membrane technology; the sector's most representative and efficient process when all three co-products are considered.
Over the past twelve months, Euro Chlor has continued to actively engage with the Commission, providing additional supporting material and tools to show the significant, sector-wide impact of the current benchmark, and requested an urgent correction to align with the recognised Best Available Technique (BAT) for Chlor-Alkali.
In parallel, Euro Chlor also worked with Fraunhofer ISI (who led the previous benchmark revision process for the Commission) to obtain a third-party technical assessment of what a representative Chlorine benchmark should be, based on current European production data and benchmark-setting methodologies. The potential impacts of these activities are expected in late-2026.
State Aid instruments Priority action
Potential energy cost relief for our sector.
To help offset the impact of high energy costs, several EU State Aid instruments have become available to energy-intensive sectors, including Chlor-Alkali. These instruments are not automatic as their implementation depends on individual Member States. As such, Euro Chlor encourages its members to liaise directly with their national authorities to explore eligibility and access. There are several interconnected files related to these instruments:
The Affordable Energy Action Plan (AEAP) (February 2025) and Accelerate EU (April 2026) are the Commission's overarching strategic and crisis-response frameworks, providing the political impetus for the complementary State Aid instruments below, which Member States can deploy.
Clean Industrial Deal State Aid Framework (CISAF): adopted in June 2025 and valid until end of 2030, CISAF aims to restore the investment case for European industry. It includes temporary electricity price relief for energy-intensive industries exposed to international competition (which Chlor-Alkali Hydrogen might be eligible for), capping aid at 50% of the average wholesale price and covering at most 50% of total consumption, with a minimum effective price floor of €50 per MWh. Separately, Chlor-Alkali Hydrogen may qualify under CISAF support for low-carbon fuels if it meets the applicable low-Carbon Hydrogen criteria, including the 70% greenhouse gas reduction threshold and the relevant electricity-sourcing conditions. At least half of any aid received must also be reinvested in the decarbonisation or modernisation of assets.
Middle East Crisis Temporary Framework (METSAF): adopted in April 2026 and valid only for the remainder of the year (until 31 December 2026), METSAF raises the aid intensity ceiling from 50% to 70% of eligible electricity costs, with no additional decarbonisation requirement. For energy-intensive industry electricity price relief, METSAF operates as a temporary add-on to CISAF.
These instruments can be cumulative as long as they respect the eligibility and conditionality requirements. While the Commission encourages full use of available frameworks, it cannot compel Member States to act. This means that the pace and ambition of deployment are up to national governments.
With the support of Cefic, Euro Chlor continues to engage with authorities at both European and national level for action on energy prices.
Several EU State Aid instruments are available to energy-intensive sectors, but the pace and ambition of deployment of these tools are up to national governments.
EU Electrification Action Plan Priority action
What it could mean for our sector.
The EU Electrification Action Plan aims to accelerate the shift from fossil fuels to clean electricity, targeting 32% of final energy consumption from electricity by 2030, and reducing Europe's exposure to volatile oil and gas prices.
For energy-intensive industries like ours, the plan could offer a valuable opportunity to secure more affordable, stable electricity through fairer taxation and funding rules, as well as major investment in energy storage and grid infrastructure.
This plan could become an important tool to help our sector restore its long-term competitive position in Europe. One to watch!
The Critical Chemicals Alliance (CCA) Priority action
Launched in October 2025 as part of the European Chemicals Industry Action Plan, the CCA is a Commission-led platform bringing together industry, Member States and stakeholders to safeguard chemicals critical to Europe's economy and industrial sovereignty. It operates through four working groups, covering critical molecules and sites, trade, modernisation and investments, and lead markets. Cefic (and through it, Euro Chlor) is an active member.
Of particular interest to our industry is that, under the CCA's current methodology, a molecule qualifies as ‘critical’ by combining high economic importance with supply vulnerability, typically measured through import dependence. Euro Chlor has worked, via Cefic, to test the methodology and has provided feedback on this to ensure that the method is as robust as possible and reflects the unique production and trade conditions of Chlor-Alkali.
The Alliance is expected to conclude much of its work by October 2026 with policy developments as of early next year.
A molecule qualifies as 'critical' by combining high economic importance with supply vulnerability, typically measured through import dependence.
EU Renewable Energy Directive (RED) review Priority action
Renewable Hydrogen back into sharp focus.
The delegated acts on Renewable Fuels of Non-Biological Origin (RFNBOs), which set out the conditions under which Hydrogen can be classified as renewable, are expected to be part of the EU RED review. In response to implementation issues, the Commission has fast-tracked this review, with a revised Delegated Act expected before year-end, potentially easing some of the most burdensome requirements.
Euro Chlor is engaging with the Commission to ensure a well-calibrated revision of the Hydrogen rules that acknowledges the specific characteristics of electrochemical industrial processes and avoids imposing compliance burdens disproportionate to the decarbonisation gains achieved. This will help the sector contribute meaningfully to Europe's clean energy objectives whilst preserving its industrial viability.
The Universal PFAS Restriction Priority action
Preparing our members for compliance.
In March 2026, the European Chemicals Agency (ECHA) launched a consultation on the Socio-Economic Analysis Committee (SEAC) opinion of the Universal Per- and Polyfluoroalkyl Substances (PFAS) restriction. Alongside the opinion of ECHA's Risk Assessment Committee (RAC), these serve as the basis for the European Commission's draft legislative proposal likely to be released in 2027.
Euro Chlor is therefore developing a dedicated PFAS Compliance Task Force to help its members and ensure they are well prepared for the restriction requirements. The remit of the Task Force is under discussion but is expected to include support with meeting the formal deadlines, engaging in substitution research, anticipating the building of compliant infrastructures and keeping pace with parallel legislative developments.