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Our principal executive office is located in Spring, Texas, U.S.
−Removed: We are a leading global manufacturer of carbon black products.
+Added: We are one of the largest global producers of Specialty and Rubber Carbon Black.
Carbon black is a powdered form of carbon that is used to create a variety of desired physical, electrical and optical qualities of various materials.
1 unchanged sentence
Our core competencies include the ability to engineer the physical properties of carbon black to meet the functional needs of our customers.
−Removed: The Company is one of the largest global producers of Specialty and Rubber Carbon Black.
We currently operate 14 wholly owned production facilities, excluding the under-construction facility at La Porte, Texas, in Europe, North and South America, South Africa, and Asia, and one jointly-owned production facility at Dortmund, Germany.
−Removed: In addition to our headquarters in Luxembourg, we have our principal executive office in Spring, Texas (U.S.), as well as offices in Frankfurt (Germany), Cologne (Germany), Shanghai (China), Seoul (South Korea), Tokyo (Japan), Sao Paolo (Brazil) and other locations.
+Added: Our headquarters in Luxembourg, we have our principal executive office in Spring, Texas (U.S.), as well as offices in Frankfurt (Germany), Cologne (Germany), Shanghai (China), Seoul (South Korea), Tokyo (Japan), Sao Paolo (Brazil) and other locations.
Our principal research and development (“R&D”) center is located in Cologne (Germany).
14 unchanged sentences
These parameters affect jetness, tinting strength, undertone, dispersibility, electrical conductivity and other characteristics.
−Removed: Carbon black is an additive that enhances the physical, electrical and optical properties of our customer’s end products.
+Added: Carbon black is an additive that enhances the physical, electrical and optical properties of our customers’ end products.
We have several post-treated Specialty Carbon Black grades for coatings and printing applications, as well as several high purity carbon black grades for the fiber industry and conductive carbon black grades for batteries, polymers and coatings.
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The diversity of our manufacturing processes allows for the creation of a wide range of Specialty Carbon Black grades with different structures and chemical properties, thereby allowing our products to impart unique characteristics to our customers’ products.
−Removed: Carbon Black for Polymers — We offer Specialty Carbon Black for polymers in a diverse range of end markets, including pipe (e.g., gas, oil, municipal water, sewage), construction, energy distribution (e.g., power cables), automotive, agriculture and
−Removed: consumer packaging.
−Removed: Certain products within this portfolio provide UV protection against polymer degradation for material such as pipe used for potable water, injection molding, agriculture films and cables.
+Added: Carbon Black for Polymers— We offer Specialty Carbon Black for polymers in a diverse range of end markets, including pipe (e.g., gas, oil, municipal water, sewage), construction, energy distribution (e.g., power cables), automotive, agriculture and consumer packaging.
+Added: Certain products within this portfolio provide UV protection against polymer degradation for material such as pipe used for potable
+Added: water, injection molding, agriculture films and cables.
Other products include standard- to high-performance grades designed and modified to provide electrical conductivity, antistatic and reinforcing properties to many different polymer applications, including high-voltage cables, film and high-pressure pipes.
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Our products, which are manufactured in different production processes, are differentiated by high purity, high conductivity, low moisture and easy dispersion, enhancing the performance, lifetime and safety of batteries.
−Removed: We are one of the largest global producers of Specialty Carbon Black.
+Added: Competition — We are one of the largest global producers of Specialty Carbon Black.
There are two other large global producers of Specialty Carbon Black.
−Removed: Besides that, there are regional Specialty Carbon Black producers, as well as technology specialists such as acetylene black producers.
−Removed: Orion differentiates by offering the broadest process technology portfolio and Specialty product portfolio to its customers.
+Added: There are also regional Specialty Carbon Black producers, as well as technology specialists such as acetylene black producers.
+Added: Orion differentiates itself by offering the broadest process technology portfolio and Specialty product portfolio to its customers.
Rubber Carbon Black
Our Rubber Carbon Black products are used in tires and mechanical rubber goods (“MRG”).
−Removed: Rubber Carbon Black are used to enhance the physical properties of the systems and applications in which they are incorporated.
−Removed: Rubber Carbon Black have traditionally been used in the tire industry as a rubber reinforcing agent to increase tread durability and are also used as a performance additive to reduce rolling resistance and improve traction.
+Added: Rubber Carbon Black is used to enhance the physical properties of the systems and applications in which they are incorporated.
+Added: Rubber Carbon Black has traditionally been used in the tire industry as a rubber reinforcing agent to increase tread durability and are also used as a performance additive to reduce rolling resistance and improve traction.
In MRG, such as hoses, belts, extruded profiles and molded goods, Rubber Carbon Black is used to improve the physical performance of the product, including the product’s physical strength, fluid resistance, conductivity and resistivity.
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Carbon Black for Mechanical Rubber Goods— We produce a wide range of carbon black products for a variety of MRG end-uses, including automotive production, construction, as well as certain food, consumer and medical applications.
−Removed: These grades have an exceptionally high purity and high consistency and satisfy special requirements needed for smooth surfaces and electrical resistance.
+Added: These grades have exceptionally high purity and high consistency and satisfy special requirements needed for smooth surfaces and electrical resistance.
These grades also disperse well in rubber compounds used in parts like window seals, automotive hoses, transmission belts, damping elements and electrically conductive and antistatic rubber goods.
−Removed: We are one of the leading global producers of Rubber Carbon Black.
+Added: Competition —We are one of the leading global producers of Rubber Carbon Black.
We compete with two other global companies and multiple regional companies.
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Specialty Carbon Black has a wide variety of end-uses and demand is largely driven by the growth and development of the coatings, polymers, printing and battery industries.
−Removed: Demand for Specialty Carbon Black in the coatings and polymers industries is mainly influenced by the levels of industrialization, automobile original equipment manufacturer (“OEM”) demand, infrastructure development, consumer spending and construction activity.
−Removed: Demand for Specialty Carbon Black in the printing industry is mainly influenced by developments in print media and packaging materials.
−Removed: Demand for Specialty Carbon Black in the batteries industry is driven by electric vehicle penetration, growth of consumer and industrial batteries business and energy storage systems use.
+Added: • Demand in the coatings and polymers industries is mainly influenced by industrial production, automobile original equipment manufacturer (“OEM”) demand, consumer spending and construction sector growth and activity.
+Added: • Demand in the printing industry is mainly influenced by developments in print media and packaging materials.
+Added: • Demand in the batteries industry is driven by electric vehicles penetration, growth of consumer and industrial batteries business and energy storage systems use.
Demand for Rubber Carbon Black is largely driven by the growth and development of the automotive tire, commercial tire and MRG industries.
−Removed: Demand for Rubber Carbon Black in tires is mainly influenced by the number of replacement and original equipment tires produced, which in turn is driven by (i) the number of miles driven and truck traffic, (ii) vehicle trends, including the number of vehicles produced and operated, (iii) demand for larger vehicles, such as trucks and buses, (iv) demand for high-performance tires, (v) consumer and industrial spending on replacement tires and on new
−Removed: vehicles, and (vi) changes in regulatory requirements.
−Removed: Demand for Rubber Carbon Black in MRG is mainly influenced by vehicle production and design trends, construction activity and general industrial production.
+Added: • Demand in tires is mainly influenced by the number of replacement and original equipment tires produced, which in turn is driven by:
+Added: ◦ number of miles driven and truck traffic,
+Added: ◦ vehicle trends, including the number of vehicles produced and operated,
+Added: ◦ demand for larger vehicles, such as trucks and buses,
+Added: ◦ local tire production trends,
+Added: ◦ demand for high-performance tires,
+Added: ◦ consumer and industrial spending on replacement tires and on new vehicles, and
+Added: ◦ changes in regulatory requirements.
+Added: • Demand in MRG is mainly influenced by vehicle production and design trends, construction activity and general industrial production.
Customer Contracts
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We sell carbon black under the following two main categories of contracts based on price adjustment mechanisms:
−Removed: • Contracts with feedstock adjustments (indexed contracts)— This category includes contracts with monthly or, in some cases, quarterly automatic feedstock and/or energy cost adjustments, which cover approximately 65% of our global volume;
+Added: • Contracts with feedstock adjustments (indexed contracts)— This category includes contracts with monthly or, in some cases, quarterly automatic feedstock and/or energy cost adjustments, which covers approximately 65% of our global volume;
• Non-indexed contracts— This category includes short-term contracts (usually shorter than three months) where sales prices of our carbon black products are not linked to carbon black oil market prices.
−Removed: Many of our indexed contracts allow for periodic price adjustments, while a small portion (by volume sold) allow for quarterly price adjustments.
+Added: Many of our indexed contracts allow for periodic or quarterly price adjustments.
These contracts have enabled us to reduce the impact of fluctuations in oil prices on our margins;
−Removed: however, rapid and significant oil price fluctuations have had and are likely to continue to have significant effects on our earnings and results of operations given (i) not all contracts contain price adjustment mechanisms and (ii) the value of our productivity improvements rises and falls with oil price movements.
+Added: however, rapid and significant oil price fluctuations have had and are likely to continue to have significant effects on our earnings and results of operations given that (i) not all contracts contain price adjustment mechanisms and (ii) the value of our productivity improvements rises and falls with oil price movements.
+Added: Sales prices under non-indexed contracts are reviewed on a regular basis to reflect raw material and energy price fluctuations as well as overall market conditions.
See “ Item 1A.
Risk Factors—Risks Related to Our Business”—We are subject to volatility in the costs, quality and availability of raw materials and energy, which could decrease our production volumes and margins and adversely affect our business, financial condition, results of operations and cash flows.
−Removed: Sales prices under non-indexed contracts are reviewed on a regular basis to reflect raw material and energy price fluctuations as well as overall market conditions.
Raw Materials
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Some carbon black grades are also produced from acetylene gas, an off-gas received from other chemical producers.
−Removed: Changes in our raw material supplier’s operating conditions and demand for their products could reduce the availability of such specialized feedstocks.
−Removed: Our business is generally not seasonal in nature, although our results of operations are generally weaker in the last three months of the calendar year.
+Added: Changes in our raw material suppliers’ operating conditions and demand for their products could reduce the availability of such specialized feedstocks.
+Added: Our business is generally not seasonal in nature, although our results of operations are generally weaker in the last quarter of the calendar year.
We enjoy a long-standing reputation within the industry for carbon black product and process technology, applications knowledge and innovation.
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The process development team works closely with our manufacturing and procurement teams to improve production processes, product quality and cost structure and advance the use of bio-circular feedstocks.
−Removed: Our Innovation function’s leading center of excellence is located in Cologne (Germany) to support and enhance our global innovation function as well as R&D activities.
+Added: Our Innovation function’s center of excellence is located in Cologne (Germany) to support and enhance our global innovation function as well as R&D activities.
This center includes applications technology laboratories and process development staff, co-located with our pilot process development facilities.
−Removed: Staffing in our Cologne technical center includes physicists, chemists and engineers who collaborate to create and analyze various carbon black properties with a goal to identify existing products or develop new products to meet customer requirements.
+Added: Staffing in our Cologne technical center includes physicists, chemists and engineers who collaborate to
+Added: create and analyze various carbon black properties with a goal to identify existing products or develop new products to meet customer requirements.
Common processes and information technology tools further enhance coordination and communication with our regional technical centers located in China, South Korea and the U.S.
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Our applications technology team brings together a deep knowledge of carbon black technology with an understanding of the key applications practiced by our customers.
−Removed: This team has access to extensive laboratory and testing facilities using similar formulations, processing and test methods employed by our customers.
+Added: This team has access to extensive laboratory and testing facilities using similar formulations, processing and testing methods employed by our customers.
Customer collaborations often include cooperative testing with customers’ staff in our facilities.
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Applications technology plays a supporting role in the process of new product launches by providing technical data and presentations, training and support, and establishing and monitoring quality targets.
−Removed: Our team works closely with customers to provide support during the qualification cycle, which can be long and may last over several years.
+Added: Our team works closely with customers to provide support during the qualification cycle, which may last for several years.
Our close cooperation decreases the likelihood of customers switching suppliers once a product has been approved.
Product quality test methods and applications testing are defined within the applications technology team.
−Removed: Methods are developed centrally and deployed worldwide to relevant production and applications laboratories to assure consistency in measurements and reporting.
+Added: Methods are developed centrally and are deployed worldwide to relevant production and applications laboratories to ensure consistency in measurements and reporting.
• Intellectual Property — We consider intellectual property development and management as a strategic competitive advantage.
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We sell our products under a variety of patents and trademarks we own, and we take reasonable measures to protect them.
−Removed: In connection with the separation of our business from Evonik Industries AG, Germany (“Evonik”) more than ten years ago, Evonik assigned to us its intellectual property that was exclusively used in its carbon black business and granted certain intellectual property rights that are still also in use in Evonik’s retained business in turn for us granting certain intellectual property rights to Evonik for fields outside of carbon black.
−Removed: Consequently, we may be restricted in leveraging intellectual property that we use on the basis of a license from Evonik or the intellectual property that is subject to grant-back licenses when expanding our business into fields outside of carbon black.
For additional information, see “ Item 1A.
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We strive to be an optimal employer for our employees, as well as a valued partner to our communities.
−Removed: We engage with our employees to provide a challenging, and dynamic work environment that supports each individual professional development, positive work environment, and long-term health and wellness.
+Added: We engage with our employees to provide a challenging and dynamic work environment that supports each individual’s professional development, work environment and long-term health and wellness.
We are committed to promoting a workplace of belonging where our employees are informed, engaged and enabled to do their best work and be their best selves.
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To ensure our employees are both motivated to do their work and equipped with the right tools and training to be successful, we start with listening.
−Removed: We regularly use employee surveys and feedback sessions to help ensure all the voices of our employees are heard.
−Removed: We continue to use the feedback to prioritize our human capital strategy and continue to upgrade our talent management programs, focusing on specific actions to improve learning and to promote employee development and career growth.
+Added: We regularly use employee surveys and feedback sessions to help ensure voices of all our employees are heard.
+Added: We continually use this feedback to prioritize our human capital strategy and continue to upgrade our talent management programs, focusing on specific actions to improve learning and to promote employee development and career growth.
Our talent programs are made up of several components:
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Orion is made up of approximately 1,639 employees with four innovation centers and 14 wholly owned plants, excluding the under-construction facility at La Porte, Texas .
−Removed: The company’s corporate lineage goes back more than 160 years to Germany, where it operates the world’s longest-running carbon black plant.
+Added: The company’s corporate lineage goes back more than 160 years to Germany, where it operates the
+Added: world’s longest-running carbon black plant.
Orion is a leading innovator, applying a deep understanding of customers’ needs to deliver sustainable solutions, offering the most diverse variety of production processes in the industry.
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To realize our commitments, we strive to:
−Removed: Enable a trusting environment so employees are free to share individual experiences to increase understanding.
−Removed: Promote an environment where each Orion employee owns the responsibility to exemplify inclusive behavior and treat others with respect, dignity and empathy.
−Removed: Require our leaders to drive a culture that enhances inclusiveness, fairness, the ability to hire people talent whatever their background may be and ensure accountability within the company.
−Removed: A focus on promoting from within has led to continued increases in internal fill rates for open positions and the involvement of business leaders across the organization in talent and succession planning reviews to assess employees on performance and future potential.
+Added: Enable a trusting environment so employees are free to share individual experiences.
+Added: Promote an environment where each Orion employee treats others with respect, dignity and empathy.
+Added: Require our leaders to drive a culture that enhances inclusiveness, fairness, the ability to hire talented people whatever their background may be and which ensures accountability within the company.
+Added: Our focus on promoting from within has led to continued increases in internal fill rates for open positions and the involvement of business leaders across the organization in talent and succession planning reviews to assess employees on performance and future potential.
These talent reviews continue to identify high potential employees, build bench strength, increase retention and help us identify our future leaders and innovators.
These reviews also allow us to identify gaps in our organization and the actions needed to fill those gaps.
+Added: Labor Relations
We uphold the freedom of association and fully recognize the right of collective bargaining.
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We value exchanging information and views with the local unions and works councils with the view to finding solutions to our common issues and ensuring success for both our employees and the Company.
−Removed: Labor Relations
−Removed: Our employees are represented by labor unions, industry groups and works councils in accordance with local law and practices.
+Added: A portion of our employees are represented by labor unions, industry groups and works councils in accordance with local law and practices.
Membership in employee labor unions varies in accordance with the business area, local practice and country.
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Our integrated global management system with established standards and processes is based on the principles of the Responsible Care 14001 for Environmental, Health, Safety and Security Management System, International Organization for Standardization’s (“ISO”) 9001 Quality Management System, ISO 14001 Environmental Management Systems and ISO 45001 Safety Management Systems.
−Removed: All of our operating sites are third-party certified to ISO 14001 and ISO 9001 standards.
+Added: Most of our operating sites are third-party certified to ISO 14001 and ISO 9001 standards.
Our global management system outlines our processes and procedures practiced in relation to environmental protection, occupational safety, industrial hygiene, security and quality management as well as sustainable compliance and product stewardship.
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In 2024, the EU Commission revised the EU measures addressing pollution from large industrial installations, as it was announced in the European Green Deal.
−Removed: The aims of the revision were to progress towards the
−Removed: EU’s zero pollution ambition for a toxic-free environment and to support climate, energy and circular economy policies.
+Added: The aims of the revision were to progress towards the EU’s zero pollution ambition for a toxic-free environment and to support climate, energy and circular economy policies.
This included the revision of the IED Directive that was issued and implemented in 2024.
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Environmental Protection Agency (“EPA”) has developed industry-specific National Emission Standards for Hazardous Air Pollutants (“NESHAPs”) for stationary sources classified as “major” on the basis of their hazardous air pollutant emissions.
−Removed: Under these, we are required to comply with Maximum Achievable Control Technology (“MACT”) standards.
+Added: Under these standards, we are required to comply with Maximum Achievable Control Technology (“MACT”) standards.
facilities are subject to MACT standards applicable to carbon black facilities, as well as MACT standards applicable to industrial boilers.
5 unchanged sentences
Greenhouse Gas Regulation and Emissions Trading— Our facilities emit significant volumes of CO 2 .
−Removed: In the EU, all of our production facilities (except for our manufacturing site in France) are subject to the European Emission Trading System (“EU ETS”) for CO 2 emissions.
−Removed: Industrial sites to which the EU ETS applies receive a certain volume of allowances in metric tons to emit greenhouse gases (“GHG”) and must surrender allowances in equivalent volume for each metric ton of greenhouse gas (“GHG”) emitted.
−Removed: Carbon black production is currently listed on the carbon leakage list, which allows receiving a certain quantity of needed emission allowances free of charge.
−Removed: From January 1, 2021, the EU ETS has stepped into its Phase 4 period running until 2030.
−Removed: However, as part of the EU Green Deal the EU has adopted a climate law enshrining its new climate targets of at least a 55% reduction in GHG emissions by 2030 compared to 1990 levels and net zero by 2050.
−Removed: The European Commission published its first part of the “Fit for 55” package in July 2021 to enable the EU to meet those targets.
−Removed: The actual EU ETS is expected to be subject to regular reviews and possible changes in order to ensure the way to achieve those climate reduction targets.
−Removed: These regular reviews are resulting in reduction of free emission certificates allocated to industrial installations in order to engage them meeting the reduction targets and being carbon neutral.
+Added: In the EU, all our production facilities (except for our manufacturing site in France) are subject to the European Emission Trading System (“EU ETS”) for CO 2 emissions.
+Added: Industrial sites to which the EU ETS applies receive a certain volume of allowances in metric tons to emit greenhouse gases (“GHG”) and must surrender allowances in equivalent volume for each metric ton of GHG emitted.
+Added: Carbon black production is currently listed on the carbon leakage list, which allows us to receive a certain quantity of emission allowances free of charge on an annual basis.
+Added: The fourth phase of the EU ETS began on January 1, 2021 with updated product benchmarks for our facilities in the EU.
+Added: As a result of revisions to the EU ETS program following the ETS Directive reform opted in May 2023 that increased the ambition of the EU ETS, the free allowances under the program will be phased out over time likely resulting in increased costs to the Company due to an increased need to purchase emission credits.
+Added: We are also evaluating the future potential applicability of the new carbon border adjustment mechanism (“CBAM”) program in the EU as an alternative to free allowances under the EU ETS and as a system complementary to the EU ETS.
+Added: See Item 1A., Risk Factors — Environmental, social and governance matters, including regulations requiring a reduction of or that impose additional taxes or fees on greenhouse gas emissions, could adversely affect our business, financial condition, results of operations and cash flows, and an increased awareness as well as adverse publicity about potential impacts on climate change by us or other companies in our industry could harm our reputation.
The design concept of the South Korean Emission Trading System is similar to the EU ETS.
−Removed: We may need to purchase emission rights for our South Korean plant to cover the shortfall where emissions exceed the quantity of free allowances, incurring additional costs.
+Added: We may need to purchase emission rights for our South Korean plant to cover the shortfall where emissions exceed the quantity of free allowances received, incurring additional costs.
In the United States, the EPA regulates GHG emissions under the CAA and has adopted rules that require reporting of GHG emissions by owners and operators of facilities in certain source categories, which include our facilities.
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RCRA is the principal federal statute regulating the generation, treatment, storage and disposal of hazardous and other wastes.
−Removed: RCRA and state-level hazardous waste regulations impose detailed operating, inspection, training and response standards and requirements for permitting, closure, remediation,
−Removed: financial responsibility, record keeping and reporting.
+Added: RCRA and state-level hazardous waste regulations impose detailed operating, inspection, training and response standards and requirements for permitting, closure, remediation, financial responsibility, record keeping and reporting.
Our sites have areas currently and formerly used as landfills that are subject to regulation under RCRA, and certain of our facilities have been investigated and remediated under RCRA.
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Any waste that is not recycled or reused is managed off site in compliance with local laws and regulations.
−Removed: Chemical Regulations— Some jurisdictions we operate in have established regimes to regulate or control chemical products to ensure the safe manufacture, use and disposal of chemicals.
−Removed: In the EU, the Regulation on Registration, Evaluation, Authorization of Chemicals (“REACH”) requires chemical manufacturers and importers in the European Union to register all chemicals manufactured in or imported into the EU in quantities of more than one metric ton annually.
−Removed: Registration has to be made with the European Chemicals Agency (“ECHA”), and the use of certain “highly hazardous chemicals” must be authorized by ECHA.
−Removed: Furthermore, REACH contains rules on bringing substances to the market that have been identified as substances of very high concern.
−Removed: In the United States, we are subject to federal and state chemical regulations.
−Removed: Under the Toxic Substances Control Act (“TSCA”), the EPA is required to maintain a list of each chemical substance that is manufactured or processed, including imports.
−Removed: This inventory plays a central role in the regulation of most industrial chemicals in the United States.
+Added: Chemical Regulations— Our products are subject to the chemical control laws and regulatory requirements of the countries in which they are manufactured or imported and distributed commercially.
+Added: These laws include the regulation of chemical substances and inventories under the Toxic Substances Control Act (“TSCA”) in the U.S.
+Added: and the Registration, Evaluation and Authorization of Chemicals (“REACH”) in the European Union.
+Added: Manufacturers or importers of these chemical substances are required to submit specified health, safety, environment, risk and use information about these substances.
+Added: Under the “Evaluation” portion of the REACH framework, the European Chemicals Agency (ECHA) and European Union Member States assess the information submitted by companies within registration dossiers and testing proposals to determine whether the associated substances are safe for use.
Carbon black is listed and maintained as an active substance in the TSCA Chemical Substance Inventory, and all our facilities are subject to chemical data reporting rules (“CDR”).
−Removed: Under CDR, we are required to submit basic exposure information to EPA every five years.
+Added: Under CDR, we are required to submit basic exposure information to the EPA every five years.
In California, we are subject to the California Safe Drinking Water and Toxic Enforcement Act, which imposes labeling and record keeping requirements.
5 unchanged sentences
Besides the Company, the following companies are members of the CB4REACH Consortium:
−Removed: Cabot Corporation, Cancarb Limited, Birla Carbon, Continental Carbon Company, Tokai Carbon CB Ltd.
−Removed: and Imerys Graphite & Carbon.
+Added: Birla Carbon, Cabot Corporation, Cancarb Limited, Continental Carbon Company, Imerys Graphite & Carbon and Tokai Carbon CB Ltd.
In addition, we are a member of the European Chemical Industry Council (“CEFIC”), a European trade association for the EU chemical industry.
3 unchanged sentences
Health, Safety and Security— The health, safety and security of our employees and customers is one of our highest priorities.
−Removed: We strive to continually improve and attain the top performance on occupational injury and illness rates as compared to the chemical industry.
−Removed: New employees and contractors working and visitors on site are given environmental, health, safety and security (“EHSS”) training, and we keep track of EHSS concerns and issues from our employees.
+Added: We strive to continually improve and attain top performance on occupational injury and illness rates as compared to the chemical industry.
+Added: New employees and contractors working at and visitors on site are given environmental, health, safety and security (“EHSS”) training, and we keep track of EHSS concerns and issues from our employees.
Employees are required to report incidents including “near misses” into our electronic EHSS management system.
−Removed: Our sites are required to implement and report EHSS leading and lagging indicators for EHSS performance.
+Added: Our sites are required to implement and report EHSS leading and lagging indicators for EHSS
Plant managers are required to track and monitor these leading and lagging indicators and take action as appropriate.
6 unchanged sentences
Based on IARC’s classification some regulatory jurisdictions now classify carbon black as a possible carcinogen.
−Removed: The Permanent Senate Commission for the Investigation of Health Hazards of Chemical Compounds in the Work Area (the “MAK Commission”) of the German Research Foundation ( Deutsche Forschungsgemeinschaft ), which uses a different rating system, classifies
−Removed: carbon black as a suspect carcinogen (Category 3).
−Removed: Any risk reclassification of our raw materials, intermediates or finished product could result in increased operating costs or affect product lines or sales.
+Added: On the basis of Orion’s long-standing experience with carbon black manufacturing, and in consideration of the conclusions from various studies with carbon black production workers showing no causal link between carbon black exposure and lung cancer mortality, Orion believes that carbon black is not carcinogenic to humans and does not present a health hazard when handled in accordance with good housekeeping and safe workplace practices as outlined in the corresponding safety data sheet for our products.
+Added: Any risk reclassification of our raw materials, intermediates or finished products could result in increased operating costs or affect product lines or sales.
The Community Rolling Action Plan (“CoRAP”) indicates substances for evaluation by the member states of the EU.
1 unchanged sentence
With ECHA's update of the CoRAP list in March 2016, carbon black was included in CoRAP for substance evaluation in 2018, though such evaluation has been postponed several times.
−Removed: With ECHA’s most recent December 2024 update, the carbon black substance evaluation is proposed to be further delayed to 2027.
+Added: With ECHA’s most recent March 2025 update, the carbon black substance evaluation has been be further delayed to 2027.
The substance evaluation for carbon black was proposed by France.
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.