Persistent organic pollutants: medium-chain chlorinated paraffins.

FEICA welcomes the opportunity to comment on the draft delegated act implementing the EUs commitments under the Stockholm Convention and adding MCCPs to the POPs list. We fully support the objectives of the Convention and the POPs Regulation. However, the proposed immediate ban on MCCPs without any transition period would have severe consequences for the construction sector and EU manufacturers.

We have contributed to the consultation response from ASD but would also like to take the opportunity to submit some more technical details regarding one MCCP usage that is particularly important to us. There is a specific derogation for MCCP in adhesives and sealants used as waterproof coatings and anticorrosion coatings included in the Stockholm Convention but not in the proposed EU POPs entry.

ASD would like to use this opportunity to share some concerns regarding the amendment of Annex I to Regulation (EU) 2019/1021 to include medium-chain chlorinated paraffins (MCCP) as substances subject to certain restrictions.

CLEPA* welcomes the opportunity to provide feedback on the persistent organic pollutants medium-chain chlorinated paraffins under persistent organic pollutants Regulation. Please find our contribution attached for your consideration.

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 MCCPs in their products. These suppliers reported that the substances are intentionally used in some semiconductor equipment, not only present as traces.

FIEEC appreciates the opportunity to provide the following comments on the proposed amendments to Annex 1 of Regulation (EU) 2019/1021, which implements the EUs international commitments under the Stockholm Convention on persistent organic pollutants. The recent addition (Spring 2025) includes restrictions and exemptions on use of medium-chain chlorinated paraffins (MCCPs).

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Position on the proposed restriction on the use of medium-chain chlorinated paraffins (MCCPs) in the one-component foam sector (OCF). On behalf of manufacturers of polyurethane one-component foams (OCF), we would like to draw attention to the critical consequences of the proposed restrictions under the POP Regulation and the Stockholm Convention if they are introduced without adequate transition periods.

The formulations for polyurethane One Component Foams (OCF) may contain Medium Chain Chlorinated Paraffins (MCCP) to leverage their properties as plasticizers and their increased flame retardancy. As these substances are phased out, the treatment of the prepolymer remaining after use of the OCF containers will leave the recycling industry with two treatment options: recycling of these materials or incineration of…

Please find attached the Joint Waste Coalition Paper on MCCPs. The core of the position is that: We strongly advocate that the UTC for MCCPs to be set at a level of 3% The Joint Waste Coalition on MCCP consists of FEAD, EERA, Recycling Europe, Plastics Recyclers Europe, and VinylPlus.

The Test & Measurement Coalition (TMC) was created in 2005 and represents an ad-hoc coalition of leading global companies producing test and measurement industrial type products, particularly those falling under category 9 of the EU RoHS Directive. Together, TMC members represent more than 70% of global production in this sector.

Thank you for the opportunity to provide feedback on the draft proposal to include medium-chain chlorinated paraffins (MCCPs) in Annex I of the POP Regulation. We fully support the overarching goal of reducing persistent organic pollutants and protecting human health and the environment. However, the proposed scope and timeline raise serious concerns.

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 on Medium Chain Chlorinated Paraffins (MCCPs) under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs).

Altair Chemical Srl Official Comment on the Proposed Listing of MCCP under the EU POPs Regulation Altair Chemical Srl acknowledges the ongoing process to align EU legislation with the Stockholm Convention decision on MCCP. To ensure a scientifically sound and enforceable regulatory framework, the following elements are considered essential. 1.

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 MCCPs.

TPF Europa is a mechanical recycling company based in Belgium. We firmly believe that our activities, together with those of fellow manufacturers across Europe, deliver substantial benefits to the environment and support the circular economy.

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 medium chain chlorinated paraffins.

Position of TKK on the Proposed Restriction of MCCP under the EU POPs Regulation On behalf of TKK, a European manufacturer of one component foams (OCF), with production facility located in Slovenia, we would like to present our position on the proposed restriction of medium-chain chlorinated paraffins (MCCPs) under the EU Regulation on Persistent Organic Pollutants and the implementation of the Stockholm Convention.

Europacable, the voice of Europes leading cable system manufacturers, welcomes the opportunity given by the European Commission to provide feedback to the proposal of inclusion of MCCPs in the EU Regulation of Persistent Organic Pollutants (POPs), as a consequence of their inclusion in Annex A of the Stockholm Convention.

Whilst there is further detailed reasoning in the attachment, to ensure harmonised and successful enforcement of the global Stockholm Convention decision on MCCP, as European manufacturers of chlorinated paraffins, we request that: 1) All specific exemptions of MCCP, listed in the Stockholm Convention decision are included in the EU POP Annex I listing with their recommended exemption timings; 2) The 3% threshold…

Please consider attached comments intended to provide constructive input from the standpoint of actual regulatory implementation & compliance, while fully respecting the high-level objectives of EU environmental & chemicals policies and the spirit of the Stockholm Convention.

Position of Soudal on the Proposed Restriction of MCCP under the EU POPs Regulation On behalf of Soudal, a European manufacturer of one component foams (OCF), with production facilities located in Belgium and Poland, we would like to present our position on the proposed restriction of medium-chain chlorinated paraffins (MCCPs) under the EU Regulation on Persistent Organic Pollutants and the implementation of the…

The motorcycle industry faces significant challenges under the proposed EU POPs Regulation concerning medium-chain chlorinated paraffins (MCCPs). While the regulation aims to align with environmental objectives, its current provisions introduce uncertainty, complexity, and potential supply chain disruptions.

The Japan Auto Parts Industries Association (JAPIA) was established in August 1969 as a "public interest incorporated association" for the purpose of promoting the Japanese auto parts industry. Since reorganizing as a "General Incorporated Association" in December 2011, we have been engaged in various activities to further development of the industry.

See feedback attached. EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. See feedback in attached document.

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. See feedback in attached document.

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…

EGMF welcomes the Commission's opportunity to comment on this draft act amending Annex I to the POPs Regulation as regards MCCPs. Our position calls for a clear and exhaustive scope of MCCPs substances, the inclusion of derogations for polymers and rubber used for spare parts and repair of garden machinery, and a general transition period of 18 months from the entry into force of the Delegated Regulation.

In Germany, there is a system for 1K foams that collects used 1K PU foam cans (OCF) and processes them in a recycling plant. OCF cans from Luxembourg, Belgium and the Netherlands are also processed in the same recycling plant. The resulting recyclates also include the non-removable residual content of the foam cans, the prepolymer.

MedTech Europe, the European trade association representing manufacturers of medical technologies, welcomes the opportunity to share its views on the draft delegated act put forward by the European Commission, aiming to implement the Stockholm Convention listing of Medium Chain Chlorinated Paraffins (MCCP), as adopted at COP-12 in Spring 2025.

Statement of Aerosol-service a.s. on the Proposed Restriction of MCCP under the EU Regulation on Persistent Organic Pollutants (POPs) On behalf of Aerosol-service a.s., a manufacturer of one-component polyurethane foams (OCF), we would like to express our position on the proposed restriction of MCCP.

In Germany, there is a system for 1k foams that collects and recycles used 1k PU foam cans (OCF). These recyclates also include the non-removable residual content of the foam cans, the prepolymer. This prepolymer is a valuable raw material and is currently being made available to the adhesive industry for the production of new adhesives, in particular 1K PU foams.

On behalf of the manufacturer of single-component foam (OCF) and polyurethane foams, we would like to comment on the planned regulation of the MCCP under the POP. Our products are widely used in construction on the European market and play an important role in building energy efficiency and fire safety. 1.

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