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bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V.

bvse

Der bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V.

Lobbying Activity

Response to Sustainable corporate governance

23 May 2022

Sehr geehrte Damen und Herren, anbei die Stellungnahme des bvse e.V. (Bundesverband Sekundärrohstoffe und Entsorgung e.V.), bdsv (DER Stahlschrott-Verband) und vdm (Verband Deutscher Metallhändler e.V.) Mit freundlichen Grüßen Annette Reber Rechtsanwältin bvse e.V. Fränkische Straße 2 53229 Bonn
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Response to Recast of Persistent Organic Pollutants (POPs) Regulation

17 May 2018

Federal Association for Secondary Raw Materials and Waste Management, Germany: Statement on the proposal for a regulation of the European Parliament and the Council on persistent organic pollutants (recast) COM (2018) 144 final 2018/0070 (COD) The Federal Association for Secondary Raw Materials and Waste Management (bvse) has following comments on the proposal for a regulation of the European Parliament and the Council on persistent organic pollutants (recast): Regarding the proposal in general • We consider an adjustment of the regulation of persistent organic pollutants to chemical legislation as necessary and useful. • A recast of the annexes of the EU-POP-regulation is also necessary as there has been five revisions of the annexes during the last years without revising the regulation in general. • We reject the intent to give the Commission the power to adopt delegated acts as laid down in the recast. Comments on the recast in detail The planned transfer of central tasks and their monitoring to ECHA (see recital 21 and Articles 8, 16, 17 and 18 of the draft) align the EU POP Regulation with the chemicals legislation under REACH and CLP. This is in the meaning of uniformity of legal regulation. We welcome the intention, set out in recital 27 of the draft, to list produced POPs in the Protocol or in the Convention of the EU-POP-regulation in Annex I and only in exceptional cases and when duly justified, in Annex II. We consider that in regard of taking penalty measures (see recital 29 and article 14 of the recast) a similar implementation and action within all EU member states is necessary. Otherwise we see the risk that some EU member states will implement stricter rules than others which will lead to discrimination for the industry located in these member states. We want also to point out that penalties are provided within the REACH regulation. This should be considered when sanctioning breaches against the EU-POP regulation. The adjustment of the definitions in article 2 to chemical legislation is reasonable to achieve legal consistency. The retention of the regulations in article 7 regarding waste management is also reasonable. The waste management industry takes responsibility for disposing waste consisting / containing / contaminated by POP substances since many years. The exception stated in article 2 section 2 and even the derogation concept in section 4 are also reasonable. We reject the commissions empowerment to adopt delegated acts stated in article 7 section 5, article 15, article 18 of the recast and even for example in recital 25. According article 290 of the Treaty on the functioning of the European Union a legislative act may delegate to the Commission the power to adopt non-legislative acts of general application to supplement or amend certain non-essential elements of legislative acts. The essential elements of an area shall be reserved for the legislation act and accordingly shall not be the subject of a delegation of power.
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