13 submissions from 13 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 24 submissions on this file. Shown here: the 13 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
10 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 5 industry submissions for every one from civil society.
Industry 10Civil 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.
The file, right now
The consultation closed on 18 Mar 2025 — it ran from 18 Feb 2025.
Policy area
Sustainability (DG ENV)
Where it stands
Awaiting adoption
Adoption expected
30 Jun 2025
How it got here
Reg del draft18 Mar 2025
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg del.
We welcome the opportunity to comment on the draft Delegated Regulation amending Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards persistent organic pollutants (polychlorinated biphenyls). More details on our position can be found in the attached document.
Filed in German · English published by the European Commission
FEAD, the European Waste Management Association, welcomes the proposal of the European Commission to propose an unintentional trace contaminant (UTC) limit value for Polychlorinated biphenyls (PCBs) under the Annex I of the POP Regulation.
This feedback (see attached file) is provided on behalf of our client. Our client is an EU-based international player with entities inter alia based in Germany who would like to stay anonymous for the time being. We are however happy to forward any follow up questions the Commission may have to our client.
DIGITALEUROPE welcomes the opportunity to provide feedback to the draft delegated regulations amending Annex I to the Regulation on persistent organic pollutants to amend the limit values for unintentional trace contamination (UTC) for PCBs and PBDEs.
The ZVEI fully supports the objectives of the continuous further development and comprehensive implementation of the Stockholm Convention on POPs, including the introduction of a UTC value for polychlorinated biphenyls (PCBs) as part of the adaptation of Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) in order to ensure legal certainty on the European market.
Filed in German · English published by the European Commission
The subject of the proposal is to reduce the PCB content in substances, mixtures and articles from 5 mg/kg to 0.2 mg/kg - we cannot agree with this in principle and the proposed reduction in the limit should be deleted. We request that the current limit be maintained. Justification: The proposed limit is not realistic.
We, the Japanese electric and electronic (E&E) industrial associations are : JEITA (Japan Electronics and Information Technology Industries Association) https://www.jeita.or.jp/english/ CIAJ (Communications and Information Network Association of Japan) https://www.ciaj.or.jp/en/ JBMIA (Japan Business Machine and Information System Industries Association) https://www.jbmia.or.jp/english/index.php JEMA (Japan…
We welcome the opportunity to comment on the Draft Delegated Regulation amending Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards the persistent organic pollutants polychlorinated biphenyls. Please find more details on our position in the attached document.
We appreciate the Commissions and Member States approach to adapt the Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs) regarding the introduction of a UTC limit for Polychlorinated biphenyls (PCBs). We support the Draft Delegated Regulation with regards to the approach for organic pigments.
Our opinion (attached as PDF) provides information on the following areas related to the UTC for PCBs: Recycling; — Manufacture of cables; Organic pigments; Analytics. We would like to point out some of the necessary adjustments to the UTC, as it is not feasible for selected areas in its current form.
Filed in German · English published by the European Commission
++ The proposed amendment introduces a Unintentional Trace Contaminant (UTC) limit for polychlorinated biphenyls (PCBs), addressing legal uncertainty by setting a 0.2 mg/kg threshold for most substances and a gradual reduction for organic pigments and dyes from 25 mg/kg to 10 mg/kg over three years.
Our company Sprecher Automation is a Europe based manufacturer of high-quality and high-end electrical and electronic equipment (automation systems, control and monitoring systems, protective relays, electrical cabinets, etc.). We welcome the proposed changes in this initiative as it will help to make the requirements more clear and in our opinion this will not have any significant negative effects on the industry.
The proposed delegated act refining the regulatory approach to PCBs is a welcome step toward strengthening the EUs commitment to eliminating persistent organic pollutants (POPs) in line with the Stockholm Convention. However, it is important to ensure that similar attention is given to pesticidal POPs, which continue to pose significant risks to ecosystems, biodiversity, and human health.
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.