Materials Compliance

Materials compliance refers to compliance with certain standards and specifications in the selection and use of materials in products and processes. These standards can relate to various aspects, such as quality, safety, environmental sustainability, and health risks. For Comet as a manufacturer of industrial products, an indispensable requirement for doing business worldwide is compliance with regulations relevant to the environment and to 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.

Comet has a responsibility to its customers to provide a supply chain of the highest quality that meets all established product performance standards and expectations. Our purchasing department maintains high standards in its supply chain by continuously evaluating new suppliers, and also by regularly assessing the performance of established suppliers. This is all the more important as the careful selection and maintenance of relationships with suppliers who adhere to ethical and sustainable practices contribute significantly to Comet’s business success.

The purchasing group maintains a trust-based relationship with its suppliers and pursues long-term strategies and goals with them. It also creates an environment in which Comet and its suppliers can continue to develop without making even the slightest compromise regarding compliance with the Comet Group’s Supplier Code of Conduct for ethically sound and legally compliant behavior. The purchasing team also ensures that this code is practiced and adhered to by suppliers.

To supplement the suppliers’ self-declaration in the form of the signed Supplier Code of Conduct, we work together with the external supply chain specialist Assent Compliance Inc. The Assent platform collects the data required for compliance with REACH, RoHS, Conflict Minerals and TSCA. With this solution, we can ensure that our suppliers comply with all relevant laws and regulations. Suppliers who do not submit data to Assent will be contacted directly and asked to provide the required documentation. Where appropriate, we will work with our suppliers to identify measures for improvement. However, we also reserve the right to terminate the business relationship with suppliers under applicable laws if they do not comply with the Code or to take legal action against suppliers.

Comet imports individual raw materials and semi-finished products into Switzerland to manufacture its products, which are used in numerous industrial manufacturing processes in the semiconductor industry and in non-destructive testing. Only the metals imported by Comet in the reporting year under the designation “Other semi-manufactures and articles of tungsten” with customs tariff number 8101 99 00 pursuant to the Swiss DDTrO, annex 1, part B are subject to the provisions on due diligence and reporting obligations. Of these, Comet imported 684 kg of these metals in the reporting year and thus exceeded the exemption limit of 350 kg.

The purchased tungsten and its alloys are used mainly by the Industrial X-ray Modules division as anodes and cathodes in x-ray tubes. These materials are added in small quantities to form alloys used in electronic components or in turning and milling tools.

With regard to imported tungsten and tungsten alloys with tariff number 8101 99 00, Comet has largely implemented the obligations arising from the following legislation:

  • Regulation (EU) 2017/821 and its Delegated Regulation (EU) 2019/429
  • Dodd–Frank Wall Street Reform and Consumer Protection Act, Section 1502 on Conflict Minerals

Through the implementation of the obligations under Regulation (EU) 2017/821 and its Delegated Regulation (EU) 2019/429, Comet is exempt, as defined in DDTrO, article 9, from the due diligence and reporting obligations in accordance with DDTrO, annex 2, part A.

By strictly adhering to all aspects of materials compliance, we eliminate a wide range of risks that could have serious consequences. These include health risks to employees and customers, environmental damage caused by our products, and legal and financial consequences that may arise from non-compliance with existing laws and regulations. It is therefore in Comet’s interest that all employees involved in materials compliance receive regular training on this topic and understand both the underlying rules and any consequences of non-compliance.

We are committed to providing 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.

The responsibilities for the processes are mapped in the Comet Group’s 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 ways that conserve resources. If these principles are disregarded, the company exposes itself to considerable risks. We use an environmental management system as a tool for managing our environmental footprint. Accordingly, we will define environmental targets for the individual sites based on ISO 14001.

Without such targets, it would be difficult to measure the achievability of our climate protection goals. We would also expose ourselves to legal and financial risks that could jeopardize our competitiveness in the long term. 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, Comet Yxlon (the IXS division) in Hamburg has gone further by designing and implementing an environmental management system in accordance with ISO 14001:2015. Smaller entities that perform 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.

In 2023, Comet successfully achieved one single, Group-wide ISO 9001 certification. The Group-wide certification to ISO 14001 is to be tackled in stages over the course of 2024. 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, the VP GOE is supported by 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 rests with the respective country general manager, while responsibility for it lies with the division country manager. In the year under review, the Comet Group did not face any ongoing or completed legal proceedings for non-compliance with environmental laws or regulations. Likewise, no fines for environmental infractions were imposed on the company.

Energy Management and Carbon Emissions

All steps of the Comet value chain involve energy consumption and associated greenhouse gas emissions. Comet thus requires a stable and reliable electric power supply at its locations. Among the most significant risks are financial and operational risks from a possible power shortage, for which Comet was already preparing at the Flamatt site in the winter of 2022/2023, for example.

Energy consumption and emissions are also important in the upstream and downstream value chain, particularly in the production and transport of raw materials, semi-finished and finished products, as well as in the use of products by customers. In Comet’s carbon footprint, these parts of the value chain contribute by far the most to total CO2 emissions.

In the 2023 reporting year, Comet refined its environmental data collection process. This allows us to report consolidated Group-wide environmental KPIs for our production (Scope 1 and 2) as well as an initial quantitative estimate of Scope 3 emissions for the reporting year under CDP. As expected, Scope 3 emissions make up the lion’s share, at about 61,000 tons or 90% of total CO2 emissions.

Comet has developed a climate roadmap to meet short-, medium- and long-term CO2 emission reduction targets and to progress toward the net-zero emission ambition by 2050. This roadmap also includes measures to increase the proportion of electricity from renewable sources in its energy mix. A renewables share of 80% is targeted for fiscal year 2025. By 2030, Comet plans to operate its sites exclusively with electricity from renewable sources. We have also taken the first steps in eco-design to further improve the environmental footprint of our products and to identify measures for the development of a reduction pathway along the entire value chain in accordance with SBTi requirements.

Numerous measures need to be implemented in order to achieve the net-zero target. With the knowledge gained from the refined environmental data collection and improvements in energy management, Comet intends to develop these measures using a systematic approach and implement them over the coming years. Thus, through detailed analysis, we want to understand the physical and transition risks arising from climate change – such as damage to buildings, production disruptions due to natural events, or new regulatory requirements – and identify measures to avoid the former as well as ensuring the readiness to comply with the latter. This issue will be addressed through our activities around TCFD and SBTi in the coming years.

Disclosures in accordance with GRI 302-1, GRI 305-1, 305-2





Environmental metrics 1)

2023 2)


Energy consumption (total)








Electricity (total)




of which renewable




Heating (total)




Heating oil




Natural gas 3)




District heating




Fuels (total)




















Greenhouse gas emissions (total) 4)

tCO 2 e







Greenhouse gas emissions (total)




Scope 1 (total) 3)

tCO 2 e



Heating 3)

tCO 2 e




tCO 2 e



Scope 2 (total)

tCO 2 e



Electricity 5)

tCO 2 e



District heating

tCO 2 e



1) Scope covers all of Comet’s companies and locations

2) Figures 2023 were externally audited by Ernst & Young AG to obtain limited assurance regarding the compliance of the reported information with the GRI Standards

3) Restated for Malaysia in 2022: 3,023 MWh / 918 tonnes of CO2 / 652 tonnes of CO2 reported in 2022 Annual Report. See chapter "Basis of calculations and definitions"

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

5) With the exception of Flamatt, Hamburg, and San Jose 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, Hamburg, and San Jose, as the sites run entirely on renewable electricity. Considering only the location-based approach, electricity consumption across all sites would be responsible for 5,579 tonnes of CO2e emissions in 2023.





Resource efficiency metrics 1)



Waste (total)




Non-hazardous waste (total)




– Incineration




– Landfill




– Recycling




Hazardous waste (total)




– Incineration




– Recycling








Water consumption

m 3



1) Scope covers all of Comet’s companies and locations

Monitoring and reducing Scope 2 emissions is a key part of our strategy for achieving our short and medium-term emissions targets. For Comet, these emissions mainly consist of indirect greenhouse gas emissions that arise from the consumption of purchased electricity.

In the fiscal year under review, Comet recorded an increase in Scope 2 emissions, which was largely due to the expansion of our production activity in Penang, Malaysia. The expansion, although commercially beneficial, led to an increased environmental impact for the Comet Group. In contrast to the increase in Penang, electricity consumption in Flamatt fell due to the correction in the semiconductor cycle and the associated lower production volumes.

With the exception of the Flamatt site, Comet leases the premises at all its locations. This complicates emission management to the extent that the availability of renewable electricity at some sites is nil or limited. This also applies to the planned Penang site in Malaysia.

We are actively striving to meet these challenges. We plan to convert our facilities in Aachen to green energy in 2024. We also plan to develop our new building in Penang as a climate-neutral unit.

Although lowering Scope 2 emissions is a complex challenge, especially in regions with limited availability of electricity from renewable sources, we are committed to sustainably reducing our environmental impacts. Through focused planning and coordinated efforts, we aim to significantly cut our Scope 2 emissions.