West Pharmaceutical Services, Inc. (West) provides the following comments on the Proposal; additional detail is contained in the attached document. . West is a leading global manufacturer in the design and production of technologically advanced, high-quality, integrated containment and delivery solutions for injectable medicines.
EU consultation
Persistent organic pollutants: long-chain perfluorocarboxylic acids, their salts and related compounds.
23 submissions from 23 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 28 submissions on this file. Shown here: the 23 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
20 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 10 industry submissions for every one from civil society.
Industry 20Civil society 2Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
- 11 of 23
- in the EU Register
- 50
- full-time lobbying staff
- €7.9M+
- declared costs a year
- 29
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 19 Dec 2025 — it ran from 21 Nov 2025.
- Policy area
- Sustainability (DG ENV)
- Where it stands
- Awaiting adoption
- Adoption expected
- 31 Mar 2026
How it got here
- Reg del draft19 Dec 2025
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg del.
23 positions
EE
European Electronic Component Manufacturers Association (EECA) / European Semiconductor Industry Association (ESIA)
· · filed 19 Dec 2025 · source
Following internal membership surveys conducted by ESIA (European Semiconductor Industry Association) and SEMI Europe, several suppliers of semiconductor manufacturing equipment confirmed that there are components containing LC-PFCAs in their products.
CLEPA* welcomes the opportunity to provide feedback on the persistent organic pollutants long-chain perfluorocarboxylic acids, their salts and related compounds under persistent organic pollutants Regulation. Please find our contribution attached for your consideration.
As a cross-sector association with member companies of Japanese parentage operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive, machinery, semiconductor, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the consultation regarding the…
EURATEX, representing the apparel and textile industry in Europe, welcomes the opportunity to comment on the draft act amending Annex I to Regulation (EU) 2019/1021 on Persistent organic pollutants and would like to highlight that the POP Regulation for C9C21 PFCAs contains two points that clearly deviate from the Stockholm Convention and could be detrimental to our industry.
SEMI Europe, representing the entire semiconductor value chain in Europe and globally, welcomes the opportunity to provide feedback on the European Commissions proposed regulatory measures concerning long-chain perfluorocarboxylic acids (LC-PFCAs) under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs).
AGC welcomes the opportunity to provide feedback to the proposed amendment to Regulation (EU) 2019/1021 concerning long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. Unintentional Trace Contaminant (UTC) Levels & derogation: AGC supports FPGs request for the proposed independent UTC levels for two distinct groups: C9-C14 LC PFCAs and C15C21 LC PFCAs, including derogation for PTFE…
The Fluoropolymers Product Group (FPG), part of Plastics Europe, appreciates the opportunity to provide comments on implementation of regulations for C9-C21 long-chain perfluorocarboxylic acids (C9-C21 PFCAs). LC PFCAs are used in the manufacture of advanced fluoropolymers, which are essential for high-performance applications across sectors such as healthcare, energy, transportation, and electronics.
DAIKYO SEIKO, LTD. welcomes the opportunity to provide comments on the proposal to amend Regulation (EU) 2019/1021 to include long-chain perfluorocarboxylic acids (C9C21 PFCAs), their salts and related compounds in Annex I. Please find our comments in the attached file.
Japan Fluoropolymers Industry Association welcomes the opportunity to provide feedback to the proposed amendment to Regulation (EU) 2019/1021 of the European Parliament and of the Council concerning long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. Please refer to the attached document.
Polis S.p.A. is a compounder specializing in PTFE compounds, as well as PTFE-based micropowders and lubricants for industrial and professional applications. We welcome the opportunity to provide feedback on the proposed amendment to the POP Regulation regarding long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. Our comments specifically address PTFE and PTFE micropowders.
Conference of Fluoro-Chemical Product Japan (FCJ) appreciates the opportunity to provide comments on implementation of regulations for C9-C21 long-chain perfluorocarboxylic acids (C9-C21 PFCAs). We propose that C15, C17, and C19-C21 PFCAs be exempted from the regulation until standard quantitative analytical method will be developed.
The automotive industry is a major downstream user of chemicals and a manufacturer of articles supporting for many years the objectives of the Stockholm Convention. ACEA however would like to express its concern and share its comments regarding the published amending Regulation 2019/1021 of the European Parliament and of the Council as regards to long-chain perfluorocarboxylic acids, their salts and related…
We propose establishing independent UTC levels for two distinct groups: C9C14 LC PFCAs and C15C21 LC PFCAs. These UTC levels shall apply to articles. For the C15-C21 we propose to use the limit 15ppm for the sum of them.
TM
textil+mode (Confederation of the German Textile and Fashion Industry)
· · filed 18 Dec 2025 · source
Textil+Mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to comment on the proposed amendment to Regulation (EU) 2019/1021 on long-chain perfluorocarboxylic acids (C9C21 PFCAs), their salts and related compounds. We identify key issues regarding regulatory coherence, scope alignment with the Stockholm Convention and enforceability.
Chemours welcomes the opportunity to comment on the newly proposed restrictions under Regulation (EU) 2019/1021 for Persistent Organic Pollutants (POPs). With the adoption in the SC COP-12 of inclusion of C9-C21 Long Chain PFCAs in Annex A of the Convention, the current REACH C9-C14 restriction will be transposed into a new entry in the EU POPs Regulation.
Chemservice welcomes the opportunity to provide feedback to the proposed amendment to Regulation (EU) 2019/1021 of the European Parliament and of the Council concerning long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. Please refer to the attached document.
ElringKlinger Kunststofftechnik GmbH is a high-performance plastic processor. We welcome the opportunity to provide feedback on the proposed amendment to the POPs Regulation on long-chain perfluorocarboxylic acids, their salts and related substances. In our submission, we refer in particular to fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups and to PTFE micropowders.
Filed in German · English published by the European Commission
We are manufacturer of specialty lubricants and in this role, we are downstream user of PTFE Micropowders (Fluoropolymer). Our suppliers confirm that all our PTFE Micropowders fulfill existing threshold limits of current available restrictions and EU Regulations (e.g. C9-C14 PFCAs, PFOA, etc.).
We appreciate the opportunity to provide feedback on the proposed amendment to Regulation (EU) 2019/1021 of the European Parliament and of the Council concerning long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. .
The Werkfeuerwehrverband Deutschland (WFVD) (German Industrial Firefighters Association) welcomes and supports the proposed amendment to Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), which seeks to list perfluorocarboxylic acids (C9-21 PFCAs), their salts and related compounds, as decided at the twelfth meeting of the Conference of the Parties to the Stockholm Convention, in Annex A, in…
CC
CECE - Committee for European Construction Equipment
· · filed 15 Dec 2025 · source
The Committee for European Construction Equipment (CECE) welcomes the opportunity to comment on the newly proposed restrictions under Regulation (EU) 2019/1021 for Persistent Organic Pollutants (POPs). Manufacturers of construction equipment require greater clarity regarding the scope and applicability of the proposed exemptions restrictions for substances such as Dechlorane Plus, UV-328, Medium-Chain Chlorinated…
SS
Swedish Society for Nature Conservation
· · filed 24 Nov 2025 · source
The Swedish Society for Nature Conservation, SSNC, fully supports the inclusion of long-chain perfluorocarboxylic acids, their salts, and related compounds in the POPs Regulation. Regulatory action is essential to safeguard European human health and the environment from this highly persistent and toxic group of chemicals.
Take the dataCSV — all 23 submissionsJSONFull text, not the excerpt. Free to cite.Search every submission →
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.