Materials Compliance

Materials compliance is compliance with any laws, regulations and specifications that restrict or even prohibit the use of various substances and/or materials in products, including, for instance, environment-related legislation, international law, religiously motivated specifications and specifications by companies. As a manufacturer of industrial products, an indispensable requirement for doing business worldwide is compliance with regulations relevant to the environment and market access – such as Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), Restriction of Hazardous Substances (RoHS), and the Toxic Substances Control Act (TSCA) – as well as with legislation driven by international law and ethics, including Conflict Minerals legislation, the Dodd-Frank Act and Regulation (EU) 2017/821.

We are committed to provide our customers with the highest-quality supply chain that meets all established product performance standards and expectations. Our purchasing department maintains these high standards by continuously evaluating the performance of our established suppliers.

Comet's Supplier Code of Conduct (Supplier CoC) is based on the Code of Conduct of the Responsible Business Alliance (RBA) and sets out the basic requirements for our suppliers and external service providers regarding their responsibility toward their stakeholders and the environment. We reserve the right to amend the requirements of our Supplier CoC to reflect changes in our compliance policies.

In addition to supplier self-declaration in the form of the signed Supplier CoC, we work with third-party supply chain specialist Assent Compliance Inc. The Assent platform collects the data required to comply with REACH, RoHS, Conflict Minerals and TSCA. This solution provides assurance that our suppliers are compliant with all relevant laws and regulations. Suppliers who do not submit data to Assent are contacted directly by us and requested to provide the necessary documentation. When appropriate, we work together with our suppliers to identify actions to achieve improvement. However, we reserve the right to terminate the business relationship with the supplier subject to applicable laws if the supplier fails to comply with the code, and we reserve the right to take legal action against the supplier.

The responsibilities for the processes are mapped in the Comet Group management system. Essentially, the specifications for materials compliance are made at the Group level by the Vice President of Global Operational Excellence (VP GOE), who reports directly to the CEO. The VP GOE defines the compliance regulations together with the Group legal experts. The responsibility for implementation in the regions rests with the divisions, and accountability for it lies with the respective country general managers. Materials compliance activities are coordinated worldwide within the Quality & Excellence Board.

Environmental Management System and Compliance

The principle of sustainability is an integral part of Comet’s corporate culture. We strive to offer our customers high-quality products and services while avoiding environmental risks and producing in a resource-conserving manner. The principles of this approach are set out in the Comet Group’s Quality, Environmental and Safety Policy, with supplementary information in the Code of Conduct.

While all our production and research and development sites are certified to ISO 9001:2015, only Yxlon International (IXS division) in Hamburg has designed and implemented an environmental management system in accordance with ISO 14001:2015. Smaller entities with only sales and marketing activities are not certified. To ensure compliance with environmental regulations, however, internal audits, customer and certification audits, benchmarking and best-practice applications are conducted at regular intervals at all production sites.

Comet plans to achieve one single Group-wide ISO 9001 and ISO 14001 certification by 2023. As most of Comet’s major sites will be due for recertification in 2023, that year will be a natural opportunity to unify the quality management systems and achieve single certification.

The Vice President of Global Operational Excellence (VP GOE) is responsible for the performance of the Comet quality management system, including the process framework and architecture. The VP GOE drives the definition, implementation, and improvement of Group-wide processes in close cooperation with the divisions. Among other responsibilities, the VP GOE sets minimum standards for non-financial KPIs and ensures certification and compliance with ISO standards. In this function, support comes from various boards and councils, such as the Operations Council and the Quality & Excellence Board, which includes the Q&E heads of the divisions. Accountability for environmental compliance lies with the country general manager of each country, while responsibility for this topic lies with the division country manager. In the year under review, the Comet Group did not face any ongoing or completed proceedings for non-compliance with environmental laws or regulations. Likewise, no fines were imposed on the company.

Successful recertification of IXS

Two external auditors audited the management system of IXS in a total of 36 hours of audit meetings. IXS achieved recertification to ISO 9001:2015 and ISO 14001:2015. The certification has great importance for the division, as customers prefer to work with reliable partners who both operate according to a standardized management system such as ISO 9001 and are exemplary in terms of sustainability, compliance with environmental regulations, and resource-efficient systems and services (ISO 14001).

ISO certification of new production site in Penang, Malaysia

Comet has established a manufacturing operation for the PCT division in Penang, Malaysia, which was successfully certified under ISO 9001:2015 in September 2021.

Energy Management and Carbon Emissions

All steps of the Comet value chain involve energy consumption and associated greenhouse gas emissions. Electricity consumption dominates in the production and use phases of the products. Energy consumption and emissions in the upstream chain are also significant, especially in the production and transport of raw materials and semi-finished products.

Thus far, Comet has focused on energy management in its production and has adopted a decentralized approach, setting division- and site-specific environmental targets, providing the appropriate resources and structures, and regularly reviewing target achievement. With this annual report 2021, Comet has consolidated and reported Group-wide environmental KPIs for its production (Scope 1 and 2) for the first time.





Environmental metrics 1)


Energy consumption (total)






Electricity (total)



of which renewable



Heating (total) 2)



Natural gas






Fuels (total)












Greenhouse gas emissions (total) 3)

tCO 2 e





Greenhouse gas emissions (total)



Scope 1 (total)

tCO 2 e



tCO 2 e



tCO 2 e


Scope 2 (total)

tCO 2 e


Electricity 4)

tCO 2 e





Resource efficiency metrics 1)


Waste (total)






Water consumption

m 3


1) Scope covers all of Comet’s companies excluding Comet Solutions Taiwan Ltd., Comet Technologies Japan KK, Comet Technologies Korea Co. Ltd., and Object Research Systems (ORS) Inc.

2) Does not include Comet Technologies USA, Inc., Shelton, and Yxlon X-Ray Equipment Trading Co. Ltd., Beijing.

3) Calculations in accordance with the WRI/WBCSD Greenhouse Gas Protocol guidelines. Scope 1: GHG emissions from own sources, e.g., boilers and fuels. Scope 2: GHG emissions stemming from the production of electricity and district heating. Sources for emission factors: Defra & IEA.

4) With the exception of Flamatt, greenhouse gas emissions associated with the production of electricity were accounted for in accordance with the 'location-based approach' under the Greenhouse Gas Protocol Scope 2 standard. No emissions stem from electricity consumption in Flamatt, as the site runs entirely on renewable electricity.

We are fully committed to developing a roadmap for our Group-wide production to become more energy-efficient and increase the share of green electricity in our energy mix. In a broader context, we also started to further refine the Group’s approach to energy management and emission reduction.

For energy management and carbon emissions, the same management approach with the same roles and responsibilities is followed as described in the section on the material topic of “environmental management systems and compliance”.

In order to achieve sustainable ongoing improvements in our electricity consumption and thus our environmental performance, we launch several projects each year to increase our energy efficiency.

Innovative HVAC design at Comet's Swiss headquarters 

In November 2021, Comet and external project manager Alain Escher of Eicher+Pauli AG were announced as winners of the “4th Building Award”, organized by the Swiss foundation for the promotion of young engineers in civil engineering, in the “Young Professionals” category. The award recognizes outstanding engineering achievements in the construction industry. As part of the 2018 expansion of the Flamatt site by the addition of a second building with an area of 18,000 square meters, a holistic, forward-thinking, cross-site HVAC energy concept for heating, ventilation and air conditioning was developed. As a result, Comet achieved greater flexibility of utilization, increased use of renewable energy and exhaust heat, and thus an all-round economical solution.


Beyond an overall reduction of 350 MWh in electricity consumption per year, Comet gained improved production reliability and better redundancies to ensure security of process cooling. In addition to the environmental benefits of the project, Comet supported a young building process engineer in the person of Alain Escher who is highly motivated to contribute to achieving the energy targets set by the Swiss government.

Certified renewable energy

In Flamatt, Switzerland, we have decided to rely exclusively on electric power from renewable sources. In 2020, we received a certificate from our electricity supplier, Group E AG, stating that it sources 100% renewable energy from European hydropower plants. The certificate is valid for the years 2020 to 2022. With this decision, we contribute to the conservation of natural resources and set a concrete example of a conscious approach to the environment.