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Update of concentration limit values of persistent organic pollutants in waste

Environment

Persistent organic pollutants (POPs) are chemical substances that have a prolonged existence in the environment, gradually accumulate in organisms through the various food chains, and pose a risk to human health and the environment. Waste containing POPs is of special concern. To ensure that such waste is managed in an environmentally sound way and allows safer recycling, this initiative will review of the concentration limit values of POPs in waste.

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Public consultation

ID: 12411

Lobbying Activity

38 responses

Consultation response

Association des Constructeurs Européens d'Automobiles, 6 Aug 2020

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…

Consultation response

Bundesverband der Deutschen Industrie e.V., 6 Aug 2020

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…

Consultation response

DIGITALEUROPE, 29 Jul 2020

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…

Consultation response

CEMBUREAU - The European Cement Association, 4 Aug 2020

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…

Consultation response

Verband der Chemischen Industrie e.V., 31 Jul 2020

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…

Consultation response

Aerospace, Security and Defence Industries Association of Europe, 4 Aug 2020

Dear Madam/Sir, Thank you for this opportunity to comment on the initiative. Please find attached comments on behalf of AeroSpace and Defence Industries Association of Europe (ASD).

Consultation response

Zero Waste Europe, 7 Aug 2020

Please find attach the Rethink Plastic alliance feedback on the Inception Impact Assessment on updated concentration limits for chemical pollutants.

Consultation response

Naturschutzbund Deutschland e.V., 6 Aug 2020

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. This is shown, for example, by…

Consultation response

Wirtschaftsvereinigung Stahl, 5 Aug 2020

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…

Consultation response

European Recycling Industries' Confederation, 17 Dec 2021

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. More precisely, these limit values are of an utmost…

Consultation response

European Recycling Industries' Confederation, 7 Aug 2020

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…

Consultation response

Plastics Recyclers Europe, 17 Dec 2021

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,…

Consultation response

FEAD, 23 Dec 2021

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…

Consultation response

FEAD, 7 Aug 2020

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…

3M warns strict chemical limits threaten fluoropolymer upcycling technology

3M, 22 Dec 2021

3M requests dismissing strict Option 3 limits for PFOA and its salts. They argue for higher limits to support circularity and their proprietary upcycling process.
This allows 3M to maintain its upcycling operations without prohibitive testing costs.
The climate suffers as stricter limits increase carbon emissions from waste incineration.

Consultation response

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 22 Dec 2021

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). In this context, the BDE is committed…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 30 Jul 2020

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…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 21 Dec 2021

Please find FNADE's (the French association for waste management and environmental services) feedback attached.

Consultation response

Center for International Environmental Law, 7 Aug 2020

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…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 5 Aug 2020

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. In order to develop a safe and high-quality…

Consultation response

Coalition Clean Baltic, 7 Aug 2020

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…

Consultation response

BSEF - The International Bromine Council, 5 Aug 2020

Please find attached BSEF’s feedback on the Inception Impact Assessment - Update of concentration limit values of persistent organic pollutants in waste

Consultation response

European Union for Responsible Incineration and Treatment of Special Waste, 22 Dec 2021

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…

Consultation response

Hazardous Waste Europe, 20 Dec 2021

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…

Consultation response

European Recycling Platform SAS, 3 Aug 2020

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. ERP agrees to the preliminary assessment that lowering…

Consultation response

WEEE Forum aisbl, 30 Jul 2020

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…

Consultation response

Hazardous Waste Europe, 27 Jul 2020

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)…

Consultation response

ASOCIACIÓN DE EMPRESAS DE ENERGÍA ELÉCTRICA, 10 Jul 2020

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…

Consultation response

European Suppliers of Waste-to-Energy Technology, 7 Aug 2020

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…

Consultation response

International Pollutants Elimination Network, 7 Aug 2020

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…

Consultation response

Društvo Ekologi brez meja, 7 Aug 2020

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…

Consultation response

European Furniture Industries Confederation, 7 Aug 2020

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…

Consultation response

European Electronics Recyclers Association, 22 Nov 2021

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. . Fact is that those…

Consultation response

Vereniging van Rivierwaterbedrijven, 7 Aug 2020

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…

Consultation response

EKO KROG – društvo za naravovarstvo in okoljevarstvo, 6 Aug 2020

Zakonodaja EU glede obstojnih organskih onesnaževal (POPs) bi morala spoštovati cilje in zahteve Stockholmske konvencije in torej ustrezno omejevati recikliranje odpadkov, ki ta onesnaževala vsebujejo. S tem namenom je potrebno zagotoviti, da opredeljene mejne vrednosti POPs v odpadkih niso…

Consultation response

The Cancer Prevention & Education Society, 30 Jul 2020

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. POPS have…

Consultation response

European Co-Processing Association, 17 Jul 2020

See EUCOPRO comments in the joined file.

Consultation response

European Electronics Recyclers Association, 18 Jun 2020

EERA submits its feed-back in the attached PDF file.