Persistent organic pollutants

The Commission has proposed amendments to Annexes IV and V to Regulation (EU) 2019/1021 of the European Parliament and of the Council on persistent organic pollutants. This initiative intends to update, for certain substances and groups of substances, the concentration limits set in Annexes IV and V of the POPs Regulation, which determine how waste containing POPs is treated, and particularly if it can be recycled…

WEEE did not support the audit of Annex IV since non the three general objectives that is provided to justify the audit is met. On the reverse WEEE submitted to it an incentive in greenhouse gas emissions and reduced recycling. With no change in the quality in recycled materials.

Filed in Swedish · English published by the European Commission

Eurits [the European Union for the Responsible Incineration and Treatment of Special waste] welcomes the publication of the Commission’s proposed regulation on Persistent Organic Pollutants (POPs) which contains, in Annex IV and V, updated concentration limit values of POPs in waste. Please find attached Eurits' detailed comments.

Feedback on the Proposal for a Regulation amending Annex IV and V of the POP-Regulation The BDE fully supports the objectives of the European Commission to protect human health and the environment from harmful effects of persistent organic pollutants (POPs).

Brussels, 22 December 2021 To Whom it May Concern: 3M Corporation (“3M”) appreciates the opportunity to participate in the “Hazardous waste updated concentration limits for chemical pollutants” feedback process. 3M believes regulatory decisions should be grounded in sound science. 3M remains committed to sharing available and relevant information to help inform the authorities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FNADE’s feedback POPs regulation (Annexes IV et V) 2021/12/21 FNADE, the French association for waste management and environmental services, welcomes the European Commission’s proposal, in line with the provisions of the Convention of Stockholm, to update the annexes IV and V of Regulation 2019/1021 on Persistent Organic Pollutants (POPs).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PREAMBLE The HBCD Industry Group (IG) welcomes the European Commission’s efforts to revise the Regulation 2019/1021 on Persistent Organic Pollutants (POPs) to address the sound management of POPs. The definition of appropriate limit values for POPs in waste, including hexabromocyclododecane (HBCDD), aims to guarantee a sound environmental management whilst ensuring the greatest overall benefit for society.

Hazardous Waste Europe would like to acknowledge the huge and serious work carried out by the EU Commission which supports this proposal for amending annexes IV and V to the POP Regulation. HWE fully endorses the rationale behind the proposal. Lowering the annex IV values for a series of POP substances is a powerful and coherent means to align with the ambition for a zero pollution in a non-toxic environment.

CREAToR, PLAST2bCLEANED and NONTOX, as EU-funded research projects focussing on the removal of non-compliant brominated flame-retardants from thermoplastic polymer waste streams, welcome the opportunity to provide comments on the European Commission’s initiative to update the concentration limits of persistent organic pollutants in waste. We have attached our feedback in a separate document.

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the proposed Regulation on persistent organic pollutants (POPs) which contains – in Annex IV & V - the updated concentration limit values of POPs in waste.

The plastics recycling industry has made vast progress to treat complex waste streams. The processes implemented at the recycler facilities successfully manage to produce recyclates below 500 mg/kg of the sum of the PBDEs. The remaining fraction, containing the concentrate of PBDEs, is to be sent, today, to the disposal route for destruction.

EERA position November 2021: The policy objectives of the circular economy and the objectives of a non-toxic world can only be reached by finding an intelligent balance between the two justified interests and EERA hopes to be able to contribute to this debate with this text. .

This relates to waste management of the POP PFOA only as my expertise revolves around firefighting foams and foam systems performance, remediation and environmental impacts. It forms an extract from my detailed submission with references in the PDF file attached.

ESWET – the European Suppliers of Waste-to-Energy Technology – welcomes the publication of an Inception Impact Assessment for the Update of concentration limit values of persistent organic pollutants in waste, as it is one of Waste-to-Energy’s roles to close the toxic loophole of polluted waste.

Arnika protects healthy environment for future generations. Following our mission we welcome the „Hazardous waste - updated concentration limits for chemical pollutants“ initiative. We would like to see limits for POPs set in the way that will protect human health and environment. It is also the aim of the Stockholm Convention (SC).

CCB welcomes the opportunity to provide comments on the EU commission’s initiative to update of concentration limit values of persistent organic pollutants in waste. We believe that the issue of limit values of POPs in waste is very important in light of transition of EU and its member states to circular economy and implementation of the European Green Deal, and in particular stipulated ambition for toxic-free…

It is essential to choose the lower POP content levels proposed if POP levels in recycled products, made from wastes containing these POPs, are to be kept at a tolerable level. In 2015, the German Federal Environment Agency (Umweltbundesamt), published a report (UBA 2015) which warned against the risks of setting POPs waste threshold levels too high as it allows recycling to be contaminated by POPs.

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of an Inception Impact Assessment for the revision of the applicable concentration limit values of persistent organic pollutants (POP) in waste. The necessary phase out of POPs, and the associated review of limit values, is rightfully backed here by an ongoing study taking into account socio-economic parameters.

RIWA, the Dutch Association of River Water Supply Companies, has noticed a considerable number of substances of emerging concern which can exhibit a great risk for the production of drinking water. Therefore, RIWA has welcomed the proposal by the German Federal Environmental Agency (Umweltbundesamt, UBA) titled ‘Protecting the sources of our drinking water - A revised proposal for implementing criteria and an…

The British Coatings Federation (BCF) is the sole UK Trade Association representing the interests of the decorative, industrial and powder coatings, printing inks and wallcovering manufacturers, with our members representing 95% of the UK sales of coatings, inks and wallcoverings. The BCF welcomes the opportunity to comment on the update of concentration limit values of Persistent Organic Pollutants (POPs) in waste.

Pro 3R (For 3R) is a free coalition of civil society organizations, municipal deputies and concerned citizens which was established aim to comment on different waste management policies. Pro 3R represents subjects and individuals which promote waste prevention and recycling as only sustainable ways in waste management.

Czech University of Life Sciences is an important organization in the field of the environment in Czech Republic. Reducing the negative impacts of industry on the environment is one of the important tasks of the university. Scientists of Czech University of Life Sciences are thoroughly addressing this issue.

Please find attached World Coatings Council comments on the updated concentration limits for chemical pollutants David Darling, P.E. VP, Health, Safety and Environmental Affairs American Coatings Association 901 New York Ave., NW Suite 300 West Washington, DC 20001 202-719-3689

We read the Inception Impact Assessment with great interest and agree with most of the considerations included therein; most notably the trade-off reflected upon between the ambition of an absolute toxic-free environment and the circular economy. In this response, we would like to highlight how WEEE/ELV plastics recycling contributes to both of these objectives.

Rethink Plastic feedback Hazardous waste: updated concentration limits for chemical pollutants August 2020 The Rethink Plastic alliance welcomes the opportunity to share our views. The update of the regulatory concentration limits for Persistent Organic Pollutants (POPs) takes place in the context of the European Green Deal and its Circular Economy Action Plan (CEAP).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Center for International Environmental Law (CIEL) is grateful for the opportunity to respond to this consultation. We call on the European Commission to “protect human health and the environment from persistent organic pollutants” (POPs) in the update of POPs content levels in waste, in line with the objective of the EU Regulation on POPs and the Stockholm Convention.

Our association brings together companies that deal with the recycling of ink and toner cartridges for printers and copiers. Our main mission is to contribute to the reduction of waste, to support products and materials with a lower negative impact on health and the environment.

According to the impact assessment, avoiding releases of POPs from waste is a priority. Yet a large part seems to be geared towards facilitating negligent recycling, all the while some of the limit values are already not low enough to ensure public health and environmental safety (both Stockholm Convention objectives).

The European furniture industries embrace the EU Green Deal and circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. The material wood, which is used in furniture to a large extent alongside other materials, offers one of the most promising bases for success due to its CO2-storing properties.

The International Pollutants Elimination Network (IPEN), a global network of 600 Participating Organizations in over 120 countries, has followed the Stockholm Convention (SC) development since its beginning and considers “Hazardous waste - updated concentration limits for chemical pollutants“ an important step.

FEAD, the European Federation for Waste Management and Environmental Services, welcomes amendments to the annexes of Regulation (EU) 2019/1021 on POPs, aiming to achieve a toxic-free environment. FEAD believes that addressing and revising new values for different substances is crucial in order to limit the presence of certain POP substances in waste and in material that could be recovered through it.

I am writing this contribution as the mayor of the village of Vysoká nad Labem, which is 4 km away from the Opatovice Power Plant, which burns 2 million tons of brown coal a year. This power plant is located in the center of a densely populated urban agglomeration. Ash has been deposited near the village for more than 60 years. It is now planned to build a large waste incinerator on the power plant site.

Environmental Policy Department ZVEI comments to Update of concentration limit values of persistent organic pollutants in waste Member of ZVEI - German Electrical and Electronic Manufacturers´ Association - offer electrical and electronic products on a global scale by processing raw materials procured from various locations around the world.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments ToxicoWatch Update of concentration limit values of persistent organic pollutants in waste The Netherlands, August 6, 2020 ToxicoWatch welcomes the opportunity to provide a contribution to a new circular economy action plan to a future EU strategy for a toxic-free environment. The EU POPs Regulation should be at least in harmony with the objectives and requirements of the Stockholm Convention.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Preliminary comments to the European Commission Inception Impact Assessment related to the update of concentration limit values of persistent organic pollutants in waste as per the Annex IV and V of the EU Regulation 2019/1021 on POPs. Over the last few years, ACEA members have significantly reduced the volume and number of substances classified as persistent organic pollutants in new vehicles.

BDI comments to the European Commission Inception Impact Assessment related to the update of concentration limit values of persistent organic pollutants in waste as per the Annex IV and V of the EU Regulation 2019/1021 on POPs The technical feasibility and relevance of enforcing more stringent limit values and the efforts required to analyse waste streams prior to recycling in waste processing plants should be…

EU legislation on persistent organic pollutants (POPs) should respect the objectives and requirements of the Stockholm Convention and therefore limit the recycling of waste containing these pollutants accordingly. To this end, it is necessary to ensure that the specified limit values of POPs in waste are not too high.

Filed in Slovenian · English published by the European Commission

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention. We think that some of the limits for POPs in waste, as set today, are too weak and do not hinder the circulation of POPs in reused materials and recycled products.

MEMO Ref. Ares(2020)4128176 - 05/08/2020 Date 5 August 2020 H20-06830- Update of concentration values for POPs in waste The Swedish Chemicals Agency welcomes the opportunity to provide input on the Commission’s initiative to update concentration limits of persistent organic pollutants (POPs) in waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment.

BSEF position on the European Commission’s Inception Impact Assessment – Update of concentration limit values of persistent organic pollutants in waste Introduction The International Bromine Council (BSEF) acknowledges the Commission’s review of annexes IV and V of the Regulation on Persistent Organic Pollutants (POP Regulation).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FNADE, the french association for waste management and environmental services, welcomes amendments to the annexes of Regulation 2019/1021 on Persistent Organic Pollutants (POPs) in order to achieve a zero-pollution ambition and a non-toxic environment.

The steel industry in Germany is operating and supporting an effective and sustainable circular economy in order to use and recover its materials in the most efficient way. The main focus is on the material steel which can be recycled infinite times as well as the recovery of iron from the residues of iron and steel production.

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment.

ZWE recommends to align the EU POPs Regulation with the objectives and requirements of the Stockholm Convention. The current limitations for POPs in waste are too weak and do not hinder the circulation of POPs in reused materials and recycled products. This occurs fro example by recycling ash from incinerators containing high concentrations of dioxins (Katima, Bell et al.

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment.

Review of certain POPs limits in waste ASD comments on Hazardous waste - updated concentration limits for chemical pollutants Aerospace & Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on the update of concentration limit values of persistent organic pollutants in waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEMBUREAU POSITION PAPER ON INCEPTION IMPACT ASSESSMENT ON POP LIMIT VALUES IN WASTE Brussels,04/08/2020 The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year to replace fuels and raw materials. In the EU, the sector substitutes on average 46% of its fossil fuel consumption with secondary materials such as non-recyclable waste or biomass waste.

Inception Impact Assessment Update of concentration limit values of persistent organic pollutants in waste The Position of the HBCD Industry Group August 2020 Preamble The HBCD Industry Group (IG) recognizes the importance of the Commission’s initiative to review the annexes IV and V of the Regulation on Persistent Organic Pollutants (POP Regulation) to adapt some existing values of POPs in waste to scientific and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Producer responsibility organisations like European Recycling Platform (ERP) are managing the collection and treatment of waste streams like WEEE on producers’ behalf and, therefore, are heavily affected by the above-mentioned provisions.

The goal of reducing the content of certain POPs in new products, especially those made from recycled materials, can only be supported. In our view, the following points should be taken into account when deriving the limit values for POPs: 1) Not only because of the waste hierarchy, waste incineration should be the preference option compared to landfilling for the disposal of POP containing wastes.

European Commission An initiative to update concentration limits for persistent organic pollutants (POPs) in waste To the person in charge of the "Public Consultation Opinion on the Threshold for Control of Concentration of Specific Brominated Flame Retardants Association for Electric Home Appliances expresses the following opinions on behalf of the manufacturers who are responsible for recycling under Japan's…

It is vital to meet the Stockholm Convention objective to protect human health and the environment from persistent organic pollutants (Stockholm Convention 2010). Therefore POPs should not be present in recycled materials and therefore limits should be much lower than currently allowed.

Waste of electrical and electronic appliances (WEEE) and plastics thereof are subject to many regulations dealing with e.g. WEEE, waste, persistent organic pollutants etc., and indirectly affected by other product- related legislation, such as rules on eco-design, restriction and control of hazardous substances, etc.

The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment.

Background Persistent organic pollutants (POPs) are poisonous chemicals that break down slowly and get into the food chain, harming the environment and our health. Waste that contains POPs is of particular concern. The EU therefore sets concentration limits for these chemicals, which it reviews regularly to reflect the latest research.

POPs are detrimental to health and the environment. They are chemicals that could end up in the recycling loops, once products become waste. Delivering the zero pollution ambition for a toxic-free environment wished by the Commission will require POP (and other substances of concern) identification, tracking and appropriate treatment to ensure non toxic material cycles and avoid dispersion into the environment.

EUCOPRO ASBL Rue Vilain XIIII, 53-55 B-1000 Brussels Phone: [phone removed] Fax : [phone removed] EUCOPRO Interest Representative Identification number: 75111426376-95 Brussels, 17th July 2020 Inception Impact Assessment : Update of concentration limit values of persistent organic pollutants in waste Eucopro comments Eucopro – the European Association for Co-processing is composed of waste pre-treatment companies…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please, find attached our comments on the Inception Impact assessment: Update of concentration limit values of persistent organic pollutants in waste (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12411-Update-of-concentration-limit-values-of-persistent-organic-pollutants-in-waste) In relation to the proposal to revise down the limits of Annex IV of the European Regulation on Volatile…

Reaction “Inception Impact Assessment - Update of concentration limit values of persistent organic pollutants in waste” Although EERA is aware of the fact that the last Basel Convention COP decided in Paragraph 8 (containing the following: Encourages Parties and others to, as soon as possible, develop and use methods, including screening methods, that are validated and suitable for industrial-scale use for the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)