Consultation
Module 3 of the Guidelines
Module 3 of the Guidelines
Once again:
Chem-X request for feedback
Environmental Sustainability and Circularity Guidelines, Module 3 (additional metrics added to v2.0)
Background
Chem-X is the key to a transparent and circular chemical industry. With Chem-X, we want to address the need for a seamless exchange of product information in the value chain across industries. Thereby, we want to enable compliance with different regulatory requirements, support circular business models and increase competitiveness.
Within the chemical industry, we want to help companies creating a Digital Material Passport (DMP). A Digital Material Passport (DMP) captures information on chemicals which constitute a final product that is regulatory required to have a Digital Product Passport (DPP).
To lay the foundations for a chemistry DMP, we have been working on six guidelines as published in Publication.
We are now glad to share with you, in draft, the Module 3 of the “Environmental Sustainability Guideline” and “Circularity Guideline”, dealing with a few additional metrics. For this added scope, we want to invite public feedback to ensure the inclusion of a wide range of perspectives, and ask for your contribution to an enhancement of the Guidelines.
The guidelines
The consultation comprises the following two guidelines, tailored for the chemical industry.
Only the sections indicated below are up for consultation.
The exact chapters open for consultation are also indicated on the Guideline documents themselves and in the Feedback tables.
Environmental Sustainability Guideline
Provides a methodological framework for assessing the environmental impacts of chemical products.
Module 3 of the Guideline – up for review – covers the following impact categories:
- Resource Use, Minerals and Metals (Chapter 6)
- Land Use (Chapter 24)
- Ecotoxicity, freshwater (Chapter 15)
- Human toxicity (Cancer & non-cancer) (Chapter 16)
- Normalisation, weighting, single scoring in LCA (Chapter 17)
- Glossary (Chapter 18)
- Appendix (sections related to the chapters above) (Chapter 21.X)
Previously published metrics in the Environmental Sustainability Guideline (Modules 1 & 2):
- Product carbon footprint (TfS PCF Guideline 3.0)
- Resource use fossil
- Acidification potential
- Water use (water scarcity)
- Ozone depletion potential
- Photochemical ozone creation potential
- Eutrophication (terrestrial, freshwater, marine)
- Particulate matter
- Ionizing radiation
Circularity Guideline
Defines harmonized metrics for measuring circularity in chemical products.
Module 3 of the Guideline – up for review – covers the following metrics:
- Material Accounting (Chapter 7)
- Annex III
Previously published metrics in the Circularity Guideline (Modules 1 & 2):
- Biogenic/ Renewable/ Renewable energy derived/ Recycled/ Reused content metrics definitions and formulas
- Chain of custody definitions and indicators
- CO2-based content (CCU)
- Waste disposal metrics
Consultation process
Currently, the guidelines are working documents. Chem-X invites public feedback to ensure the inclusion of a wide range of perspectives. The broad consent collected will support future adaptations, maximizing value for all stakeholders.
Consultation period: October 06, 2026 to October 27, 2026.
How to participate:
- Review the guidelines (use DOWNLOAD links above).

- Provide your comments separately for the two guidelines using the FEEDBACK TABLES below each guideline (use DOWNLOAD links above).

- Once you have completed your feedback, please send the completed table(s) to consultation@chem-x.de
What you should also know:
- The consultation period will remain open until October 27, 2026. Late feedback will not be considered.
- In case we are not sure how to interpret your feedback while reviewing it, we will reach out to you via e-mail (via the e-mail used for its submission).
- Please provide only answers that reflect your company’s point of view. We cannot consider inconsistent or contradictory feedback from one company.
- We appreciate your feedback and your contribution to a pre-competitive, publicly funded project. To avoid misunderstandings, we would like to point out that your feedback is voluntary, and you cannot make any copyright claims from these contributions and/or register Intellectual property.
