Consultation No. 2
Once again:
Chem-X request for feedback
Environmental Sustainability and Circularity Guidelines, Module 2 (additional metrics added to v1.0)
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 2 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 in bold below are up for consultation.
The exact chapters open for consultation are also indicated on the Guideline documents themselves and in the Feedback tables.
Please note that the guidelines are working documents. We will continue to develop the guidelines and add further content.
Environmental Sustainability Guideline
Provides a methodological framework for assessing the environmental impacts of chemical products.
The Module 2 of the Guideline – up for review – covers the following impact categories:
- Eutrophication (terrestrial, freshwater, marine)
- Particulate matter
- Ionizing radiation
Previously published metrics (Module 1):
- Product carbon footprint (TfS PCF Guideline 3.0)
- Resource use fossil
- Acidification potential
- Water use (water scarcity)
- Ozone depletion potential
- Photochemical ozone creation potential
Circularity Guideline
Defines harmonized metrics for measuring circularity in chemical products.
The Module 2 of the Guideline – up for review – covers the following metrics:
- CO2-based content (CCU)
- Waste disposal metrics
Previously published metrics and guideline (Module 1):
- Bio/ Renewable/ Recycled/ Reuse content metrics definitions and formulas
- Chain of custody definitions and indicators
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: April 20 to May 08, 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.

- 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 May 08, 2026. Late feedback will not be considered.
- In case we are not sure how to interpret your feedback, we will reach out to you via e-mail.
- 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.
