This new research demonstrates how major European chemical companies and industry associations are strategically advocating against EU and US regulatory measures intended to reduce the impact of pollution on biodiversity loss.
None of the five European-headquartered chemicals companies engaged with under the Nature Action 100 and/or PRI Spring investor initiatives has advocacy consistent with policy pathways to deliver the Global Biodiversity Framework (science-aligned biodiversity policy). Three companies, dsm-firmenich, Solvay and Clariant, have advocacy that is partially aligned, and Bayer and BASF have misaligned advocacy.
The assessed companies have sought to weaken multiple European Union (EU) regulations intended to protect natural ecosystems from harmful pollution. Based on this assessment, it appears that chemical companies are particularly targeting the EU’s Registration, Evaluation and Restriction of Chemicals (REACH) Regulation, the Sustainable Use of Pesticides Directive (SUD), and proposed PFAS (also known as ‘forever chemicals’) restrictions. Industry efforts appear to have been successful, with plans to replace the SUD with the Sustainable Use of Plant Protection Products Regulation being scrapped, and the European Commission’s Chemical Action Plan proposing multiple simplification packages.
The European chemical sector also appears to be negatively engaging with US regulations targeting PFAS and pesticides. Industry actors have repeatedly used narratives downplaying the harmful impacts of these chemicals to oppose measures relating to the Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Multiple senior executives from the companies hold board-level positions in large sector-specific industry associations that are actively opposing biodiversity policy, such as the European Chemical Industry Council (Cefic) and CropLife International. Several companies are also members of CropLife America, and CropLife Europe. However, the quality of disclosure by the companies assessed in this briefing does not align with investor expectations, with none of them providing a detailed review of the biodiversity-specific advocacy activities or positions of their affiliated industry associations.
Meta-analyses of conservation scientists’ views have shown a scientific consensus that biodiversity loss due to human activity is occurring globally at unprecedented rates, faster than at any other time in human history, with 1 million species threatened with extinction. Previous research from InfluenceMap indicates that crucial biodiversity policy is being held back and delayed by vested corporate interests. Oppositional lobbying on biodiversity policy undermines the global goals set in the Kunming-Montreal Global Biodiversity Framework (GBF), resulting in continued ecosystem degradation.
Since its launch in 2015, investors have extensively used the LobbyMap platform to evaluate and engage with companies about their influence on climate-related policies. This issue is increasingly a concern for mainstream investors due to associated reputational, legal, and systemic risks. The platform supports initiatives such as the Climate Action 100+ Net Zero Company Benchmark, which engages 164 of the world's largest corporate emitters and has led many companies to improve their climate policy engagement and disclosure.
Investors are now turning their attention to lobbying on biodiversity and nature-related lobbying, which carries risks similar to those of oppositional engagement on climate change policy. This is the central focus of the investor engagement initiative PRI Spring and is one of the target areas of Nature Action 100.
The chemical sector plays a significant role in driving biodiversity loss. Chemicals are critical for manufacturing, infrastructure, waste management, and agriculture, but exposure to harmful chemicals, including pesticides, fertilizers, and PFAS (forever chemicals), can negatively impact ecosystem health. According to the 2019 IPBES Global Assessment Report on Biodiversity and Ecosystem Services, chemical pollution is one of the five direct drivers of global biodiversity loss. The IPBES report elevated the impact of pesticides and fertilizers on the global agenda, providing scientific evidence to inform policy guidance on chemical pollution. Specifically, the Kunming-Montreal Global Biodiversity framework (GBF), adopted at COP 15, included a target to halve the risks posed by pesticides and highly hazardous chemicals by 2030 to ensure that pollution does not negatively impact biodiversity.
InfluenceMap's methodology for assessing corporate engagement on biodiversity loss closely follows InfluenceMap's established methodology for assessing engagement on climate lobbying, the full details of which can be found here. A summary of the biodiversity methodology can also be found in the appendix.
This briefing covers the policy engagement of the five European-headquartered chemicals companies engaged with under the Nature Action 100 and/or PRI Spring investor initiatives. Industry associations have been selected to ensure key sector and regional coverage for the companies. Detailed information about indirect influence through other industry associations can be found on relevant profiles on LobbyMap.org
The Organization Score (0 to 100%) indicates how supportive or opposed an organization is toward biodiversity policy. None of the companies assessed has advocacy consistent with science-aligned biodiversity policy. Two companies, dsm-firmenich, Solvay, have direct advocacy that is partially aligned with science-aligned policy. Three companies, Bayer and BASF, and Clariant, have misaligned direct engagement, indicated by Organization Scores of 50 and below. These scores indicate increased opposition toward biodiversity-related policy. This contrasts with the generally positive high-level messaging on the science of biodiversity loss from these companies.
Engagement Intensities are high, largely driven by engagement with policies specifically targeting pollution, one of the five main drivers of biodiversity loss. Bayer has the highest engagement intensity, at 23%, followed by BASF and dsm-firmenich. Clariant is the only company that does not appear to be actively engaged on biodiversity policy.
The Relationship Score (0 to 100%) measures how supportive or opposed the aggregate of a company's industry associations is toward biodiversity-related policy. As shown in Table 1, companies have a range of Relationship Scores that reflect their memberships to different industry associations. Cefic appears to be the most relevant association for the sector, as all assessed companies have a direct relationship, and senior executives from BASF, Bayer, and Clariant hold board-level positions. Other relevant pesticide and fertilizer industry associations include the International Fertilizer Association, CropLife International, CropLife Europe, and CropLife America. All these associations have overall positions misaligned with the Global Biodiversity Framework, whereas Cefic’s positions are partially aligned. BASF and Bayer hold the strongest relationships to CropLife International, CropLife Europe, and CropLife America, resulting in the two companies having the lowest relationship scores.
The Organization Score and the Relationship Score combine to form the Performance Band (A to F), which represents the full measure of a company's direct and indirect engagement. InfluenceMap’s analysis often identifies a trend where companies have more positive scores than their industry associations, due to the ‘lowest common denominator’ effect. Consequently, companies with more positive scores, such as Solvay, have a larger misalignment between Organization and Relationship score. In contrast, companies with lower scores, such as BASF, appear more aligned with their industry associations' advocacy. Only Clariant has an Organization score that is lower than its Relationship Score. In combination with the lowest engagement intensity score, this may indicate that Clariant allows its industry associations to represent its biodiversity policy positions, rather than engaging directly.
Despite the companies' European headquarters, Bayer, BASF, and Solvay have significant engagement with US regulations. Bayer and BASF are also members of cross-sector US industry associations, the US Chamber of Commerce and the National Association of Manufacturers, respectively. These groups have engaged on a wider range of biodiversity-related policies across multiple drivers of biodiversity loss. Previous InfluenceMap research has demonstrated the power of influential cross-sector groups to delay and oppose both climate and biodiversity policy. Cross-sector associations can claim to speak for the entire economy, even when they may not reflect the full diversity of company views.
| Entity | HQ | Performance Band | Organization Score | Relationship Score | Engagement Intensity |
|---|---|---|---|---|---|
| DSM-Firmenich | Switzerland | C | 61% | 59% | 15% |
| Solvay | Belgium | C- | 60% | 52% | 13% |
| Clariant | Switzerland | D+ | 48% | 58% | 7% |
| Bayer | Germany | D | 49% | 44% | 23% |
| BASF | Germany | D | 45% | 43% | 17% |
| Industry Associations | Industry Association Scores | BASF | Bayer | Clariant | DSM-Firmenich | Solvay |
|---|---|---|---|---|---|---|
| FoodDrinkEurope | C- | |||||
| Cosmetics Europe | C- | |||||
| Cefic | C- | |||||
| BusinessEurope | D | |||||
| CropLife International | D | |||||
| CropLife Europe | D | |||||
| International Fertilizer Association | D- | |||||
| CropLife America | E+ | |||||
| BDI | E+ | |||||
| US Chamber of Commerce | E | |||||
| NAM | E- |
This section highlights industry engagement on three key EU policy areas and provides an overview of engagement on US policies. The narrative focuses on company engagement, as well as engagement by their primary European industry association, Cefic; for further information on industry association engagement, refer to profiles on LobbyMap.org.
REACH
The sector’s impact on biodiversity has prompted governments to adopt a range of policy responses. In the EU, the most comprehensive legislation on chemicals is the Registration, Evaluation and Restriction of Chemicals (REACH) Regulation, which applies to most chemical substances manufactured or imported into the EU, including PFAS. REACH intends to protect human health and the environment from the risks posed by harmful chemical substances. In July 2025, the European Commission announced its Chemicals Industry Action Plan, which outlines a revision to REACH. However, as of April 2026 the Commission has not set a date for the REACH revision proposal. Additionally, the European Commission’s 2026 work programme does not mention REACH. It remains unclear when a revision will occur and whether it will bring simplification or strengthening. However, it is clear that the industry has consistently advocated against strengthening the regulation.
BASF has been vocal in its opposition to the inclusion of Mixture Assessment Factors (MAFs) under REACH, which aim to ensure regulatory limits remain protective when accounting for the elevated risks of cumulative chemical mixture effects. In an April 2022 consultation response, BASF described generic MAFs as “disproportionate”, arguing that “protection against chemical hazards is already high.” BASF reiterated this claim in a February 2023 position paper.
In its April 2022 consultation response, Bayer advocated against the introduction of both MAFs and an essential use concept to phase out chemicals of high concern.
In an April 2025 LinkedIn post, Solvay CEO Philippe Kehren advocated for changing REACH to reduce regulatory burden and improve the industry’s economic competitiveness.
Cefic has directly engaged on REACH on over 40 occasions since 2021. Like BASF and Bayer, Cefic opposed including MAFs at a March 2025 Commission meeting discussing the REACH revision. In April 2025, Cefic submitted feedback on the proposed REACH revision that opposed strengthening the policy and claimed that “the intended changes of REACH as presented by the European Commission during CARACAL are out of sync with the idea of simplifying and reducing burden for the industry.”
Sustainable Use of Pesticides Directive (SUD)
The SUD is an important EU regulation that aims to minimize the risk and impacts of pesticide use on human health and biodiversity. However, the European Commission has acknowledged that regulatory gaps remain and, in 2022, proposed replacing the existing SUD with a regulation on the sustainable use of plant protection products (SUR). The SUR sought to set legally binding targets to reduce pesticide use, but was abandoned by the Commission in February 2024 following its rejection by the European Parliament. Oppositional narratives from industry appear to have been a critical factor in setting back the progress of EU pesticide regulation.
In its April 2021 SUD consultation response, BASF answered “strongly disagree” to the necessity of targets to reduce the risk posed by chemical pesticides and to reduce overall pesticide use. In a November 2022 interview, BASF advocated for less ambitious EU pesticide reduction targets, arguing that member states should have flexibility due to “the consequences for food security, farmers competitiveness, consumer prices and increasing imports.”
In April 2021, feedback on the revision of the SUD, Bayer advocated for the Commission to implement a weaker regulatory approach that focuses on the most environmentally harmful products and balances environmental protection with product effectiveness. Bayer has engaged on the topic of pesticides in multiple EU regulations. In its March 2022 feedback on the EU 2030 soil strategy, Bayer argued that any additional regulation of pesticides was unnecessary due to the existing SUD.
Both BASF and Bayer supported the EU’s October 2025 Food and Feed Safety Simplification Omnibus, and called for weakening regulations governing pesticide Maximum Residue Levels (MRLs), which are designed to prevent pesticide exposure in the environment from reaching harmful levels.
PFAS Legislation
PFAS, also known as forever chemicals, are harmful because their persistence leads to bioaccumulation in ecosystems, resulting in widespread exposure. Multiple EU regulations currently target PFAS, including REACH, but no comprehensive EU regulation currently exists. The Commission’s Chemicals Industry Action Plan outlines plans to introduce a universal PFAS restriction under REACH, and an EU-wide PFAS monitoring framework. However, these plans have not been finalized and are attracting strong opposition from industry. Consequently, further concessions may be advocated for in the upcoming ECHA consultation period.
Solvay has opposed an EU restriction on PFAS in multiple documents obtained from UCSF’s Industry Documents Library in March 2024. In a questionnaire response, Solvay claimed that restrictions would “severely undermine EU competitiveness.” Solvay also advocated against a REACH PFAS restriction proposal, and called for multiple exemptions to reduce the scope of the proposal.
Bayer and BASF appear less engaged on EU PFAS restrictions, but have also submitted oppositional positions. In a 2025 comment, Bayer advocated against EU PFAS legislation, raising concerns that it would excessively impact industry production. In a position paper, accessed in January 2024, BASF appeared to support PFAS restrictions but called for fewer restrictions or bans, arguing that there is a lack of suitable PFAS alternatives.
Cefic has repeatedly opposed any EU restrictions on the use of PFAS. In a January 2024 consultation presentation, obtained from UCSF’s Industry Documents Library, Cefic provided EU consultation response recommendations to its members to promote consistent advocacy in favor of continued use of PFAS. Cefic has also claimed that PFAS are crucial for “safeguarding Europe’s strategic economic and technological capabilities” in a January 2025 Euractiv article.
US Policy
The United States has multiple regulations targeting PFAS and pesticides, including the Toxic Substances Control Act (TSCA) and the federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). In line with the current administration's deregulatory agenda, the Environmental Protection Agency (EPA) released a September 2025 proposal to revise and narrow the scope of risk evaluations under TSCA. Many EU chemical companies also have operations in the US, and have repeatedly used similar arguments to advocate against US regulations.
EU companies have repeatedly engaged with TSCA. Since Q4 2023 BASF has consistently disclosed TSCA lobbying activity in its LDA filings, but has not disclosed any positions. In August 2023, Solvay advocated against the EPA's proposal to categorically exclude PFAS from eligibility for the Low Volume Exemption (LVE), which would prevent PFAS from bypassing some of the regulatory requirements for substances produced or imported in small quantities under the Toxic Substance Control Act.
European companies have also advocated for weakening proposals under FIFRA. In a September 2024 comment submitted to the EPA, Bayer claimed that pesticide exposure limits are “built upon highly conservative assumptions”, and advocated for offsets as an alternate solution. In August 2023 comments, BASF opposed an EPA plan to introduce more stringent pesticide restrictions under FIFRA to meet Endangered Species Act (ESA) obligations to protect vulnerable species.
There are also multiple instances of EU companies advocating against specific US chemical restrictions. Since Q3 2020, Solvay has consistently disclosed lobbying activity on PFAS in its LDA filings, but has not provided its positions. In May 2024, Bayer released a report downplaying the environmental harm caused by neonicotinoids in response to the EPA’s announcement of the most vulnerable endangered species, part of the EPA’s effort to prioritize these species and expedite Endangered Species Act consultations. In 2022, Bayer opposed a federal court ruling limiting the use of the pesticide glyphosate, and in 2023, it took legal action to challenge a ban on the pesticide dicamba. In a February 2024 press release, BASF also stated that it was “assessing its legal options” in response to the court ban of dicamba-based herbicides.
This section highlights the accuracy of the chemical sector’s disclosure on its direct and indirect engagement activities.
Overall, the quality of disclosure by the companies assessed in this briefing was not aligned with investor expectations, for example, the Global Standard on Responsible Climate Lobbying, which sets out 14 indicators covering disclosure, governance, and oversight processes to ensure alignment between a company’s climate policy engagement and delivering the 1.5°C goal of the Paris Agreement. These expectations are increasingly being translated into the biodiversity sphere, including by PRI’s Spring initiative.
Clariant, Solvay and dsm-firmenich had limited transparency on their direct engagement activities, meaning at most disclosure of top-line biodiversity positions without details of specific engagement with actual policies. BASF and Bayer had mixed transparency on their direct engagement activities, meaning some engagement activity was disclosed, but key instances were not included. None of the companies have disclosure on their biodiversity-related policy engagement that is aligned with InfluenceMap’s assessment of other data sources in the public domain.
BASF and dsm-firmenich have disclosed partial lists of their industry association memberships, but both exclude a significant number of memberships identified by InfluenceMap’s assessment. The others have disclosed at least a partial list of industry associations, but without further details on these groups’ advocacy activities or positions. Given the wide range of engagement activities undertaken by industry associations in the chemicals industry, this represents a likely governance oversight, and falls significantly short of investor expectations on corporate lobbying.
