COMMISSION STAFF WORKING DOCUMENT European Union Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the review and update of the third European Union Implementation Plan in accordance with Article 9(4) of Regulation (EU) 2019/1021 on persistent organic pollutants
Date: 2021-07-22
Institutions: Directorate-General for Environment, European Commission
Subjects: dangerous substance, environmental protection, environmental standard, international convention, organic chemical, organic pollution, pollution control measures, protocol to an agreement, public health, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.7.2021  SWD(2021) 201 final  COMMISSION STAFF WORKING DOCUMENT European Union Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the review and update of the third European Union Implementation Plan in accordance with Article 9(4) of Regulation (EU) 2019/1021 on persistent organic pollutants  {COM(2021) 408 final}  
 
 
PREFACE 

This  document  presents  the  fourth  revised  and  updated  European  Union  (Union) 
implementation plan required by the Stockholm Convention on Persistent Organic Pollutants 
(“POPs”),  of  which  the  European  Union  is  a  Party.  This  document  also  details  the  work 
undertaken  by  the  Union  towards  the  Protocol  to  the  UNECE  Convention  on  Long-Range 
Transboundary  Air  Pollution  (CLRTAP)  on  POPs1  and  Regulation  (EU)  2019/1021  of  the 
European  Parliament  and  of  the  Council  (“POPs  Regulation”)2,  which  replaces  Regulation 
(EC) No 850/2004 of the European Parliament and of the Council3. The implementation plan 
sets out the Union's regulatory framework for POPs and persistent, bioaccumulative and toxic 
(PBT)  substances,  and  what  have  been  identified  as  the  key  challenges  facing  the  Union 
within Part I (Party Baseline). Part II subsequently sets out the Union’s response to these key 
challenges  and  what  actions  need  to  be  undertaken  to  help  achieve  the  overall  aims  of 
protecting human health and the environment from exposure to POPs.  

The  first  plan,  titled  the  ‘Community  Implementation  Plan’,  was  developed  in  2007 
(SEC(2007)341). The implementation plan was updated with a ‘Union Implementation Plan’ 
published in 2014 (SWD(2014)172 final)4, and further updated with a third implementation 
plan  in  late  2018  (SWD(2018)495)5.  The  further  review  and  update  of  the  third 
implementation  plan  is  needed  to  reflect  developments  both  within  the  policy  environment 
(i.e. further addition of new POPs to the Convention and the Union legislation) and scientific 
environment (i.e. where new research furthers the understanding of POPs). 

The  updated  implementation  plan  will  be  submitted  to  the  Secretariat  of  the  Stockholm 
Convention and published on the website of the European Commission. 

This  document  can  also  be  read  alongside  the  triennial  synthesis  reports  on  the 
implementation  of  the  POPs  Regulation  that  were  developed  on  the  basis  of  information 
submitted by the Member States of the European Union pursuant to Article 12 of Regulation 
(EC) No 850/2004 regarding progress towards the objectives of the Regulation, Convention 
and Protocol. 

1  

2  

3  

4  
5  

Protocol  to  the  1979  UNECE  (United  Nations  Economic  Commission  for  Europe)  Convention  on 
Long- Range Transboundary Air Pollution on Persistent Organic Pollutants 
Regulation  (EU)  2019/1021  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on 
persistent organic pollutants (OJ L 169, 25.6.2019, p. 45) 
Regulation  (EC)  No  850/2004  of  the  European  Parliament  and  of  the  Council  of  29  April  2004  on 
persistent organic pollutants and amending Directive 79/117/EEC (OJ L 158, 30.4.2004, p. 7)  
http://ec.europa.eu/environment/chemicals/international_conventions/index_en.htm 
http://chm.pops.int/Portals/0/download.aspx?d=UNEP-POPS-NIP-EU-COP7.English.pdf 

1 

 
 
 
 
 
                                                           
TABLE OF CONTENTS 

1. 

1.1. 

1.2. 

Introduction ................................................................................................................. 10 

Persistent Organic Pollutants (POPs) ......................................................................... 10 

International agreements addressing POPs ................................................................. 10 

1.2.1.  UNECE Protocol on POPs .......................................................................................... 10 

1.2.2.  Stockholm Convention ............................................................................................... 11 

1.2.3.  Coordination and cooperation among the Basel, Rotterdam and Stockholm 

Conventions ................................................................................................................ 15 

1.3. 

2. 

2.1. 

Purpose of the Union Implementation Plan on POPs ................................................. 16 

PART I – Party Baseline ............................................................................................. 17 

Key Union Legislation and Policies related to the Union’s Obligations under the 
Stockholm Convention and UNECE Protocol on POPs ............................................. 17 

2.2. 

Legislative instruments ............................................................................................... 19 

2.2.1.  Regulation (EC) No 850/2004 (First POPs Regulation) ............................................. 19 

2.2.2.  Recast of the POPs Regulation ((EU) 2019/1021) ..................................................... 20 

2.2.2.1.  Introduction ................................................................................................................. 20 

2.2.2.2.  Institutional changes for the role of ECHA and the Commission .............................. 20 

2.2.2.3.  Changes related to Member States reporting .............................................................. 21 

2.2.2.4.  Changes related to waste and waste management ...................................................... 22 

2.2.2.5.  Changes made to terminology to build greater alignment to REACH ....................... 22 

2.2.2.6.  POP specific changes (notably for PCBs and PBDEs) ............................................... 22 

2.2.3.  European Union chemicals legislation ....................................................................... 23 

2.2.3.1.  REACH ....................................................................................................................... 24 

2.2.3.2.  CLP ............................................................................................................................. 25 

2.2.3.3.  Regulation on Plant Protection Products .................................................................... 25 

2.2.3.4.  Biocidal Products Regulation ..................................................................................... 26 

2.2.3.5.  Regulation on the export and import of hazardous chemicals .................................... 26 

2.2.3.6.  PCB Directive (Directive 96/59/EC) .......................................................................... 26 

2.2.4.  Other environmental legislation with POP relevance ................................................. 28 

2.2.5.  Legislation on food and feed and on the protection of public health ......................... 31 

2.2.6. 

Information exchange between the Commission and the Member States on POPs in 
food and consumer products ....................................................................................... 33 

2.2.7.  Food monitoring within the European Union ............................................................. 34 

2.2.8.  Emission monitoring legislation ................................................................................. 34 

2 

 
 
2.2.9.  Public access to environmental information ............................................................... 35 

2.3. 

Strategies, policies, and programmes ......................................................................... 35 

2.3.1.  Sustainable development ............................................................................................ 35 

2.3.2.  Substitution of substances for intentional use ............................................................ 36 

2.3.3.  Environment Action Programme ................................................................................ 37 

2.3.4.  The Thematic Strategy for Soil Protection ................................................................. 38 

2.3.5.  Strategies for control of pesticides and chemicals ...................................................... 38 

2.3.6.  OpenFoodTox database for pesticide residues in food ............................................... 39 

2.3.7.  Environment and Health Action Plan ......................................................................... 39 

2.3.8.  Multilateral Environmental Agreements (MEAs) ...................................................... 40 

2.3.9.  Monitoring efforts of the Union ................................................................................. 40 

2.4. 

Financial instruments .................................................................................................. 41 

2.4.1.  Funding instruments for the Union ............................................................................. 41 

2.4.2.  Funding for neighbouring and partner countries ........................................................ 43 

2.4.3.  Multilateral programmes funded by the Union .......................................................... 44 

2.5. 

Research and Development and the Framework Programmes ................................... 45 

2.5.1.  European Research Institutions including the JRC .................................................... 46 

2.5.2.  Supporting co-operation, co-ordination and networking ............................................ 47 

2.5.3.  Future research and innovation ................................................................................... 48 

2.6. 

Information Exchange, Public information, awareness and education ....................... 49 

2.6.1.  Overview ..................................................................................................................... 49 

2.6.2.  Stockholm Convention Regional Centres ................................................................... 51 

3. 

3.1. 

Overall Assessment of the POPs issue in the Union .................................................. 53 

POPs regulated before 2009 (“old POPs”) ................................................................. 53 

3.1.1.  Manufacture ................................................................................................................ 53 

3.1.2.  Use and placing on the market .................................................................................... 54 

3.1.3. 

Import, export and intra-Union shipments .................................................................. 54 

3.1.4.  Stockpiles and waste ................................................................................................... 55 

3.2. 

POPs regulated from 2009 (“new POPs”) .................................................................. 57 

3.2.1.  Endosulfan .................................................................................................................. 64 

3.2.2.  POP Polybrominated diphenyl ethers (POP PBDEs) ................................................. 64 

3.2.3.  Tetrabromodiphenyl ether and pentabromodiphenyl ether ......................................... 66 

3.2.4.  Hexabromodiphenyl ether and heptabromodiphenyl ether ......................................... 68 

3.2.5.  Decabromodiphenyl ether ........................................................................................... 70 

3 

 
 
3.2.6.  Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds ................... 73 

3.2.7.  Perfluorooctane sulfonic acid (PFOS), its salts and perfluorooctane sulfonyl fluoride76 

3.2.8.  Pentachlorobenzene (PeCB) ....................................................................................... 80 

3.2.9.  SCCPs – short chain chlorinated paraffins ................................................................. 81 

3.2.10.  HCBD – hexachlorobutadiene .................................................................................... 83 

3.2.11.  PCN – polychlorinated naphthalenes .......................................................................... 83 

3.2.12.  Hexabromocyclododecane (HBCDD) ........................................................................ 84 

3.2.13.  Pentachlorophenol (PCP) ............................................................................................ 87 

3.2.14.  Dicofol ........................................................................................................................ 88 

3.3. 

Unintentionally produced POPs ................................................................................. 89 

3.3.1.  Estimation and monitoring of emissions .................................................................... 89 

3.3.2.  Addressing industrial sources ..................................................................................... 94 

3.3.3.  Addressing domestic sources ...................................................................................... 96 

3.4. 

Information on the state of knowledge on stockpiles and contaminated sites ............ 96 

3.4.1.  PCB contaminated sites and deposits ......................................................................... 99 

3.4.2.  HCH contaminated sites and waste deposits ............................................................ 101 

3.4.3.  Other POPs Pesticides .............................................................................................. 102 

3.4.4.  Contaminated sites from unintentionally formed POPs (PCDD, PCDF, PCB, HCB, 

PeCB, PAHs) ............................................................................................................ 103 

3.4.5.  PBDE contaminated sites ......................................................................................... 104 

3.4.6.  PFOS contaminated sites .......................................................................................... 104 

3.4.7.  Hexachlorobutadiene contaminated sites ................................................................. 108 

3.4.8.  Hexabromocyclododecane in waste stream .............................................................. 109 

3.5. 

Emerging risks from POPs ....................................................................................... 110 

4. 

5. 

PART II – Implementation Plan ............................................................................... 112 

Implementation of the basic obligations of the Stockholm Convention ................... 113 

5.1. 

Elimination of intentional manufacture and use of POPs (Article 3(1)) .................. 113 

5.1.1.  POP pesticides, plus decabromodiphenyl ether, HBB, HBCDD, HCBD, PeCB, 

PCNs, and SCCPs. .................................................................................................... 113 

5.1.2.  PCBs ......................................................................................................................... 114 

5.1.3.  POP-PBDEs (tetra-, penta-, hexa-, hepta- and decabromodiphenyl ether) .............. 117 

5.1.4.  C-DecaBDE uses ...................................................................................................... 123 

5.1.5.  DDT .......................................................................................................................... 124 

5.1.6.  Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride (PFOS)125 

4 

 
 
5.1.7.  Perfluorooctanoic acid, its salts and related-compounds (PFOA) ............................ 128 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

Elimination of import and export of POPs - Article 3(2) of the Stockholm 
Convention ................................................................................................................ 130 

Prevention of the manufacture and use of new chemicals exhibiting characteristics of 
POPs - Article 3(3) of the Stockholm Convention ................................................... 131 

Assessing and controlling chemicals in use - Article 3(4) of the Stockholm 
Convention ................................................................................................................ 132 

General exemptions .................................................................................................. 133 

Reduction of total releases from unintentional production - Article 5 of the 
Stockholm Convention ............................................................................................. 133 

5.6.1.  Obligations and implementation ............................................................................... 133 

5.6.2.  Analysis of implementation ...................................................................................... 135 

5.6.3.  Pentachlorobenzene (PeCB) ..................................................................................... 136 

5.7. 

Identification and environmentally sound management of stockpiles and wastes ... 137 

5.7.1.  Obligations and implementation ............................................................................... 137 

5.7.2.  Analysis of implementation ...................................................................................... 138 

5.7.3.  Disposal and destruction of POP-PBDE containing materials ................................. 139 

5.7.4.  Disposal and destruction of PFOS, PFOA and related PFAS-compounds ............... 142 

5.7.5.  Disposal and destruction of POPs Pesticides ............................................................ 143 

5.7.6.  Destruction of PCB and PCB containing materials .................................................. 144 

5.8. 

6. 

6.1. 

6.2. 

6.3. 

7. 

7.1. 

7.2. 

7.3. 

7.4. 

7.5. 

8. 

9. 

Identification of contaminated sites (Annex A, B and C Chemicals) and if addressed 
then remediation in an environmentally sound manner ............................................ 146 

Implementation of the obligations on supporting activities ..................................... 147 

Information exchange ............................................................................................... 147 

Public information, awareness and education .......................................................... 148 

Research, development and monitoring.................................................................... 150 

Implementation of other commitments ..................................................................... 152 

Technical assistance .................................................................................................. 152 

Financial Assistance ................................................................................................. 153 

Reporting .................................................................................................................. 155 

Effectiveness evaluation ........................................................................................... 156 

Addition of Future Chemicals to the Stockholm Convention .................................. 157 

EU research projects since 2007 with references to POP issues .............................. 159 

Obsolete actions from previous UIP ......................................................................... 185 

5 

 
 
 
LIST OF TABLES 

Table 1 

Overview on POPs regulated at international level; the new POPs under the 
Stockholm Convention (since 2009) are highlighted in grey ................................................... 13 

Table 2 

Union chemicals legislation relevant for POPs ......................................................................... 23 

Table 3 

Further environmental legislative instruments with relevance on the use and 
disposal of POPs (including unintentionally produced POPs).................................................. 29 

Table 4 

Food & Feed related legislation with relevance to POPs .......................................................... 33 

Table 5 

New POPs added to the Stockholm Convention since 2009 .................................................... 57 

Table 6 

Overview on the new POPs (ESWI 2011 + additional references where indicated) ................ 59 

Table 7 

Breakdown of commercial PBDE products on the Union market ............................................ 65 

Table 8 

Table 9 

Results of analysis for POP-PBDE congeners from ELVs and white goods in 
Irish (2015) and UK (2016) studies .......................................................................................... 67 

Amended text of Part I of Annex A to the Stockholm Convention listing PFOA, 
its salts and PFOA-related compounds, and specific exemptions ............................................ 75 

Table 10  New listing of perfluorooctane sulfonic acid (CAS No. 1763-23-1), its salts and 

perfluorooctane sulfonyl fluoride (CAS No. 307-35-7) in part I of Annex B to the 
Stockholm Convention as set out in the decision SC 9/4 of the COP-9 ................................... 78 

Table 11  Releases of unintentionally produced POPs according to the E-PRTR (PCDD + 

PCDF as TEQ) (for the EU27) .................................................................................................. 90 

Table 12  BAT associated emission levels for waste incineration in Commission 

Implementing Decision (EU) 2019/2010 .................................................................................. 95 

Table 13  Research Projects with references to POPs funded under Horizon 2020 ............................... 159 

Table 14  Research Projects with references to POPs funded under FP7 ............................................... 165 

Table 15  Research Projects with references to POPs funded by LIFE+ ................................................ 181 

LIST OF FIGURES 

Figure 1  Overview of the main chemical and environmental legislation related to POPs ..... 18 

Figure 2  DecaBDE emissions to European environment under the realistic scenario ERealistic 

(Earnshaw et al. 2013) ............................................................................................. 71 

6 

 
 
 
 
 
 
 
LIST OF ABBREVIATIONS  

AFFF – Aqueous film forming foam 

ABS – Acrylonitrilebutadiene styrene  

AMAP – Arctic Monitoring and Assessment Programme  

ASR – Automotive Shredder Residue  

BAT – Best Available Technologies 

BREF – BAT Reference Document  

BFR – Brominated flame retardant  

BRS – Basel, Rotterdam, and Stockholm Conventions 

CBC – Cross-Border cooperation  

CLP – Classification, Labelling and Packaging   

CLRTAP – Convention on Long-Range Transboundary Air Pollution 

COPHES – Consortium to Perform Human Biomonitoring on a European Scale  

COP – Conference of the Parties  

BDE – Brominated Diphenyl Ethers 

BEP – Best Environmental Practices 

CLEA – Contaminated Land Exposure Assessment  

DDT – Dichloro-diphenyl-trichloroethane  

EAF – Electric arc furnaces  

EASIS – Endocrine Active Substances Information System 

ECHA – European Chemicals Agency  

EEA – European Environment Agency  

EEE – Electrical and electronic equipment  

EFSA – European Food Safety Authority 

EHBMI – European Human Biomonitoring Initiative  

ELV – Emission Limit Values 

EMEP – European Monitoring and Evaluation Programme  

ENI – European Neighbourhood Instrument  

ENP – European Neighbourhood Policy  

7 

 
 
 
ENRTP – Thematic Programme for Environment and Sustainable Management of Natural 

Resources 

E-PRTR – European Pollutant Release and Transfer Register  

ERA – European Research Area 

ESIS – European Substance Information Systems  

EU – European Union  

FAO – Food and Agriculture Organisation 

FP – Framework Programme  

GEF – Global Environment Facility 

GEOSS – Global Earth Observation System of Systems  

GENASIS – Global Environmental Assessment Information System 

GPGC – Global Public Goods and Challenges 

HBB – Hexabromobiphenyl 

HBCDD – Hexabromocyclododecane 

HBM – Human Biomonitoring  

HCB – Hexachlorobenzene  

HCBD – Hexachlorobutadiene 

HCH – Hexachlorocyclohexane  

HIPS – High Impact Polystyrene 

IED – Industrial Emissions Directive  

IPCheM – Information Platform for Chemical Monitoring 

IPA – Instrument for Pre-Accession Assistance  

IPPC – Integrated Pollution Prevention and Control 

JRC – Joint Research Centre  

KBBE – Knowledge Based Bio-Economy 

LCD – Liquid Crystal Display  

LRTAP – Long- Range Transboundary Air Pollution 

NIPs – National Implementation Plans  

OECD – Organisation for Economic Co-operation and Development 

PAHs – Polycyclic aromatic hydrocarbons 

PBDE – Polybrominated diphenyl ether 

8 

 
 
PCBs – Polychlorinated Biphenyls  

PBT/vPvB – Persistent, Bioaccumulative and Toxic / Very Persistent and Very 

Bioaccumulative 

PCDDs – Polychlorinated dibenzo-p-dioxins  

PCDFs – Polychlorinated dibenzofurans 

PCN – Polychlorinated Napthalenes 

PCP – Pentachlorophenol  

PeCB – Pentachlorobenzene 

PFAA – Perfluoroalkyl Acids 

PFAS – Per- and Polyfluoroalkyl Substances 

PFOA – Perfluorooctanoic Acid 

PFHpA – Perfluoroheptanoic acid 

PFOS – Perfluorooctane sulfonic acid 

PFOSF – Perfluorooactane sulfonyl fluoride  

PM – Particulate Matter  

PMT/vPvM - Persistency, Mobility and Toxicity (PMT) / Very Persistent and Very Mobile 

(vPvM) 

POP – Persistent Organic Pollutant 

PPP – Plant Protection Products 

PXDD/PXDFF – Polyhalogenated dibenzo‐ p‐ dioxins/ Polyhalogenated dibenzofurans 

QSAR – Quantitative Structure–Activity Relationship 

REACH – Registration, Evaluation, Authorisation and Restriction of Chemicals 

RMOA – Regulatory Management Option Analysis  

RoHS – Restriction of Hazardous Substances 

SAICM – Strategic Approach to International Chemicals Management  

SCCPs – Short Chain Chlorinated Paraffins 

SMEs – Small and Medium-sized Enterprises  

SVHC – Substances of Very High Concern  

UN – United Nations  

UNECE – United Nations Economic Commission for Europe 

UPOPs – Unintentionally Produced POPs  

9 

 
 
1. 

1.1. 

INTRODUCTION 

Persistent Organic Pollutants (POPs) 

Persistent  Organic  Pollutants  (POPs)  are  chemicals  that  persist  in  the  environment,  bio-
accumulate  and  pose  a  risk  of  causing  significant  adverse  effects  to  human  health  or  the 
environment. These pollutants are transported across international boundaries far from their 
sources and even accumulate in regions where they have never been used or produced. POPs 
pose  a  threat  to  the  environment  and  to  human  health  all  over  the  globe,  with  the  Arctic, 
Baltic  and  the  Alpine  regions  being  examples  of  Union  sinks  of POPs.  International  action 
has been deemed necessary to reduce and eliminate manufacture6, use and releases of these 
substances. The substances addressed in the international legal instruments on POPs are listed 
in Table 1. 

At  Union  level,  significant  progress  towards  the  elimination  of  POPs  has  been  achieved. 
Manufacture  and  use  of  all  POP  chemicals  is  prohibited  with  some  minor  time  limited 
exemptions that are phased-out over time. A main challenge for the Union is to eliminate POPs 
from the waste cycle and remaining stockpiles as these still present a major emission source. 

International agreements addressing POPs 

1.2. 
1.2.1.  UNECE Protocol on POPs7 

The Executive Body to the UNECE Convention on Long-Range Transboundary Air Pollution 
(CLRTAP) adopted the UNECE Protocol on POPs on 24 June 1998 in Aarhus, Denmark. The 
UNECE  Protocol  on  POPs  focuses  currently  on  a  list  of  16  substances  comprising  11 
pesticides,  2  industrial  chemicals  and  three  unintentional  by-products.    In  2009,  Parties 
adopted  decisions  to  list  seven  new  substances.  However,  those  decisions  did  not  yet  enter 
into force. The ultimate objective is to eliminate any discharges, emissions and losses of these 
POP  substances.  The  POPs  Protocol  has  been  approved  by  the  European  Union  and  23 
Member States8. 

The  UNECE  Protocol  on  POPs  bans  the  manufacture  and  use  of  some  substances  outright 
(aldrin,  chlordane,  chlordecone,  dieldrin,  endrin,  hexabromobiphenyl,  hexachlorobutadiene, 
hexachlorocyclohexane  (technical  HCH),  hexaBDE,  heptaBDE,  tetraBDE,  pentaBDE, 
pentachlorobenzene,  polychlorinated  napthalene  (PCN),  mirex  and  toxaphene).  Others  are 
scheduled  for  elimination  at  a  later  stage  (dichloro-diphenyl-trichloroethane  (DDT), 
heptachlor,  hexachlorobenzene  (HCB),  polychlorinated  biphenyls  (PCBs),  perfluorooctane 
sulfonate  (PFOS),  and  short-chain  chlorinated  paraffins  (SCCPs)).  In  addition,  the  latest 

6   The recast of the EU POPs regulation (EU) 2019/1021 aligns terminology with the EU REACH Regulation 
(EC 1906/2006) for consistency. Under the recast the term ‘production’ used by the Stockholm Convention 
is  replaced  by  ‘manufacture’  used  by  REACH.  For  the  purposes  of  consistency,  all  references  in  the  UIP 
have been amended to ‘manufacture’, but the reader should assume that manufacture and production relate to 
the same activity. 

7   https://www.unece.org/environmental-policy/conventions/envlrtapwelcome/guidance-documents/protocol-

on-pops.html  
8   Greece,  Malta, 

and 
(https://treaties.un.org/Pages/ParticipationStatus.aspx?clang=_en). 

Portugal 

Poland 

did 

not 

yet 

approve 

the 

POPs 

Protocol 

10 

 
 
 
                                                           
version of the UNECE Protocol on POPs, adopted in December 2009, severely restricts the 
use of gamma-hexachlorocyclohexane (lindane)9.  

The  Protocol  includes  provisions  for  dealing  with  the  wastes  of  substances  that  are  banned 
and  it  obliges  Parties  to  reduce  their  emissions  of  dioxins,  furans,  polycyclic  aromatic 
hydrocarbons  (PAHs)  and  HCB  below  their  levels  in  1990  (or  an  alternative  year  between 
1985 and 1995). For the incineration of municipal, hazardous and medical waste, it lays down 
specific emission limit values. 

On 18 December 2009, Parties to the Protocol on POPs adopted decisions 2009/1, 2009/2 and 
2009/3  to  amend  the  Protocol  to  include  nine  new  substances  (taking  the  total  to  26). 
Furthermore, the Parties revised obligations for DDT, heptachlor, HCB and PCBs as well as 
certain  emission  limit  values  (ELVs)  from  waste  incineration,  sinter  plants  and  electric  arc 
furnaces  for  secondary  steel  manufacture.  Parallel  to  this,  with  a  view  to  facilitating  the 
Protocol’s  ratification  by  countries  with  economies  in  transition,  the  Parties  introduced 
flexibility for these countries regarding the time frames for the application of ELVs and best 
available  technologies  (BAT).  Finally,  the  Parties  adopted  decision  2009/4  to  update 
guidance  on  BAT  to  control  emissions  of  POPs  in  Annex  V  and  turn  parts  of  it  into  a 
guidance  document  (ECE/EB.AIR/2009/1410).  The  amendments  for  Annexes  V  and  VII 
entered into force on 13 December 2010, while the 2009/1 and 2009/2 amendments have not 
yet entered into force. 

The Union formally accepted the amendments on 24 June 2016, based on Council Decision 
(EU) 2016/769 of 21 April 2016 on the acceptance of the Amendments to the 1998 Protocol 
to the 1979 Convention on Long-Range Transboundary Air Pollution on Persistent Organic 
Pollutants. 

1.2.2. 

Stockholm Convention11 

The Stockholm Convention on POPs was adopted in 2001 and entered into force in 2004. The 
overall  objective  of  the  Stockholm  Convention  is  to  protect  human  health  and  the 
environment  from  POPs.  It  promotes  global  action  on  POPs  and  requires  Parties  to  take 
measures to eliminate or reduce the release of POPs into the environment. Specific reference 
is made to a precautionary approach as set forth in Principle 15 of the 1992 Rio Declaration 
on  Environment  and  Development.  This  principle  is  implemented  by  Article  8  of  the 
Convention,  which  lays  down  the  rules  for  including  additional  chemicals  under  the 
Convention. 

At  the  time  the  Stockholm  Convention  entered  into  force  in  2004,  a  total  of  12  substances 
were listed within Annexes A, B and/or C comprising nine pesticides, one industrial chemical 
and  two  unintentionally  created  substances  with  no  commercial  value  (dioxins  and  furans). 
Since 2004 additional substances have been added at subsequent  Conferences of the Parties 
(COP).  On  26  August  2010  (following  COP-4)  a  further  nine  substances  were  added, 

9   Note that Annex I to the Protocol states that the use of lindane was limited to control of topical insect pests 
for public health purposes. The use was intended to be re-evaluated in 2012 or one year after entering into 
force, which ever was later. The amendments were adopted in June 2016, meaning the review should have 
taken place in 2017, but no further information on whether this has been completed. 

10   https://digitallibrary.un.org/record/669615?ln=en   
11   http://chm.pops.int/Convention/ConventionText/tabid/2232/language/en-GB/Default.aspx  

11 

 
 
 
                                                           
including  a  new  Annex  C  substance  (pentachlorobenzene).  At  COP-5  (held  in  2011)  the 
pesticide  endosulfan  was  added  to  Annex  A  with  specific  exemptions  (SC5/3).  At  COP-6 
(held  in  2013)  the  flame  retardantant  hexabromocyclododecane  (HBCDD)  was  added  to 
Annex  A  of  the  Convention  with  specific  exemptions  for  manufacture  as  allowed  for  the 
parties listed in the register of specific exemptions and for use in expanded polystyrene and 
extruded polystyrene in buildings. At COP-7 (held in 2015) a further three substances were 
added to  the Annexes (Hexachlorobutadiene and pentachlorophenol  (PCP) and its salts  and 
esters  were  added  to  Annex  A,  while  polychlorinated  napthalenes  (PCN)  were  added  to 
Annexes A and C). At COP-8 (held in 2017) the decision was made to amend Annexes A and 
C of the Convention by listing Decabromodiphenyl ether (commercial mixture, c-decaBDE) 
and short-chain chlorinated paraffins (SCCPs) in Annex A with specific exemptions as well 
as  further  extending  the  listing  of  hexachlorobutadiene  to  both  Annex  A  and  C.  These 
additions  made  in  the  period  2011  (COP-5)  to  2017  (COP-8)  took  the  total  number  of 
substances regulated under the Convention to 28. 

Additionally during the discussions of the fifth Conference of the Parties (COP-5) in 2011, a 
work plan (following decision SC-4/19) was put in place to limit and reduce the emissions to 
the  environment  of  the  four  Stockholm  Convention  homologue  groups  of  polybrominated 
diphenyl  ethers  (POP-PBDEs)  from  wastes  and  also  to  help  close  the  knowledge  gaps  for 
PFOS. COP-5 was also used to promote closer ties between the Stockholm Convention and 
the related policy instruments covered by the Rotterdam Convention and Basel Convention. 

At the COP-9 meeting, held in April/May 2019, further decisions were made to add dicofol 
(no exemptions) and perfluorooctanoic acid (PFOA), its salts and PFOA related compounds 
(with specific exemptions) to Annex A of the Convention (see Sections 3.2.6 and 3.2.14 for 
further details).  

In addition, under Annex B of the Stockholm Convention the manufacture and use of DDT (a 
pesticide  still  used  in  many  developing  countries)  and  PFOS  (a  surfactant)  are  severely 
restricted. The continued use of DDT has been the subject of review and assessment at COP-
5,  COP-6,  COP-7  and  COP-8.  When  PFOS  was  listed  under  Annex  B  of  the  Stockholm 
Convention  in  2009,  the  listing  included  eight  acceptable  purposes  (non-time  limited 
exemption)  and  twelve  specific  exemptions  (time  limited).  At  COP-9,  the  number  of 
exemptions for PFOS was substantuially reduced, and additional requirements for Parties to 
register for remaining specific exemptions were put in place (see Section 3.2.7). 

The  generic  exemptions  allow  laboratory-scale  research,  use  as  a  reference  standard  and 
unintentional  trace  contaminants  in  products  and  articles.  Articles  containing  POPs 
manufactured or already in use before the date of entry into force of the relevant obligation 
are also subject to an exemption provided that Parties submit information on the uses and a 
national  plan  for  waste  management  for  such  artifcles  to  the  Secretariat  of  the  Stockholm 
Convention.  

including 
Releases  of  unintentionally  produced  by-products 
polychlorinated dibenzo-p-dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs), PCBs, 
pentachlorobenzene  (PeCB),  HCB,  PCNs  and  hexachlorobutadiene  (HCBD),  are  subject  to 
continuous  minimisation  with  the  ultimate  objective  of  total  elimination,  where  feasible. 
According  to  Annex  C,  Parties  shall  promote  and,  in  accordance  with  their  action  plans, 
require  the  use  of  best  available  techniques  for  new  sources  within  their  major  source 
categories identified in Part II and Part III of Annex C of the Stockholm Convention. 

in  Annex  C, 

listed 

12 

 
 
The  Stockholm  Convention  also  foresees  identification  and  safe  management  of  stockpiles 
containing or consisting of POPs. Waste containing, consisting of or contaminated with POPs 
shall  be  disposed  of  in  such  a  way  that  the  POP  content  is  destroyed  or  irreversibly 
transformed so that it does not exhibit POPs characteristics. Where this does not represent the 
environmentally preferable option or where the POP content is low, waste shall be otherwise 
disposed  of  in  an  environmentally  sound  manner.  Disposal  operations  that  may  lead  to 
recovery  or  re-use  of  POPs  are  explicitly  forbidden.  With  regard  to  shipment  of  wastes, 
relevant international rules, standards and guidelines, such as the 1989 Basel Convention on 
the Control of Transboundary Movements of Hazardous Wastes and their Disposal, are to be 
taken into account. 

In  addition  to  control  measures,  the  Stockholm  Convention  includes  several  general 
obligations.  All  Parties  are  obliged  to  develop  and  endeavour  to  implement  National 
Implementation  Plans  (NIPs),  facilitate  or  undertake  the  exchange  of  information  and 
promote and facilitate awareness and public access to information on POPs. The Parties shall 
also encourage or undertake appropriate research, development, monitoring and co-operation 
pertaining to POPs, and where relevant, to their alternatives and candidate POPs. They shall 
also  regularly  report  to  the  COP  on  the  measures  taken  to  implement  the  provisions  of  the 
Convention. 

The  Stockholm  Convention  recognises  the  particular  needs  of  developing  countries  and 
countries  with  economies  in  transition  and  therefore  specific  provisions  on  technical 
assistance and on financial resources and mechanisms are included in the general obligations. 

Table 1  Overview on POPs regulated at international level; the new POPs under the 

Stockholm Convention (since 2009) are highlighted in grey 

Substance 

CAS 

Listed in Stock-
holm Convention 

Listed in the UNECE 
Protocol on POPs 

Listed in the POPs 
Regulation 

Intentionally produced POPs 

Annex A 
Annex A 
Annex A 
Annex A 

Yes 
Yes 
Yes 
Yes 

Annex A 

No 

309-00-2 
57-74-9 
143-50-0 
60-57-1 

959-98-8 
33213-65-9 

72-20-8 
76-44-8 

Aldrin 
Chlordane 
Chlordecone  
Dieldrin  

Endosulfan 

Endrin 
Heptachlor 
Hexabromobiphenyl 
(HBB) 

Hexabromocyclododeca
ne (HBCDD) (including 
its isomers) 

Hexabromodiphenyl 
ether and 
heptabromodiphenyl 
ether 

Annex A 
Annex A 

Yes 
Yes 

Yes 

36355-01-8 

Annex A 

25637-99-4 
3194-55-6 
134237-50-6 
134237-51-7 
134237-52-8 

36483-60-0; 

68928-80-3; 

Annex A 

No 

Annex A 

Yes 

13 

Yes 
Yes 
Yes 
Yes 

Yes 

Yes 
Yes 

Yes 

Yes 

Yes 

Yes 

 
 
 
 
 
 
 
Substance 

CAS 

and others 

Listed in Stock-
holm Convention 

Listed in the UNECE 
Protocol on POPs 

Listed in the POPs 
Regulation 

Hexachlorobenzene 
(HCB) 
Alpha hexachlorocyclo-
hexane* 
Beta hexachlorocyclo-
hexane* 
Lindane* 
Mirex 
Pentachlorobenzene 
Pentachlorophenol 
(PCP) 
Polychlorinated 
biphenyls (PCB) 
Tetrabromodiphenyl 
ether and 
pentabromodiphenyl 
ether 
Toxaphene 

DDT 

Perfluorooctane sulfonic 
acid, its salts and 
perfluorooctane sulfonyl 
fluoride (PFOS) 

Perfluorooctanoic acid 
(PFOA), its salts and 
PFOA-related 
compounds 
SCCPs – short chain 
chlorinated paraffins 
HCBD – 
hexachlorobutadiene 
PCN –polychlorinated 
naphthalenes 
Bis(pentabromophenyl)e
ther, also known as 
Decabromodiphenyl 
ether (c-decaBDE) 
Dicofol  

118-74-1 

Annex A 

Yes 

Yes 

Annex A 

Annex A 

Annex A 
Annex A 
Annex A 

Annex A 

Annex A 

Annex A 

Annex A 

Annex B 

Yes: 
Hexachlorocyclohexanes 
(HCH; CAS: 608-73-
1
(CAS: 58-89-9) 

), including lindane 

12

Yes 
Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes (all isomers including 
gamma HCH found in 
lindane) 

Yes 
Yes 
Yes – added with the 2019 
recast 

Yes 

Yes 

Yes 

Yes 

Yes 

Annex B 

Yes 

Yes 

319-84-6;  
608-73-1 

319-85-7 

58-89-9 
2385-85-5 
608-93-5 
87-86-5 and 
others 
1336-36-3 and 
others 

40088-47-9; 
32534-81-9; 
and others 

8001-35-2 

50-29-3 

1763-23-1; 
2795-39-3; 
29457-72-5; 
29081-56-9; 
70225-14-8; 
56773-42-3; 
251099-16-8; 
1691-99-2; 
24448-09-7; 
307-35-7, 
and others 

335-67-1 

Annex A 

No 

Yes – added April 2020 

85535-84-8; 
and others 

Annex A 

87-68-3 

Annex A 

70776-03-3 and 
others 

Annex A 

1163-19-5 

Annex A 

115-32-2 

Annex A 

Yes 

Yes 

Yes 

No 

No 

Yes 

Yes 

Yes 

Yes – added with the 2019 
recast 

Yes – added June 2020 

Yes 

Polychlorinated dibenzo-
p-dioxins (PCDD) 
Polychlorinated 

1746-01-6 

1746-01-6 

Annex C 

Annex C 

Yes 

Yes 

Unintentionally produced POPs 

12   This CAS No. covers the isomer mixture of alpha, beta, gamma, delta and epsilon HCH.  

14 

 
 
                                                           
Substance 

CAS 

Listed in Stock-
holm Convention 

Listed in the UNECE 
Protocol on POPs 

Listed in the POPs 
Regulation 

dibenzofurans (PCDF) 
Hexachlorobenzene 
(HCB) 

118-74-1 

Annex C 

Pentachlorobenzene 

608-93-5 

Annex C 

Polychlorinated 
Biphenyls (PCBs) 
PCN – polychlorinated 
napthalenes 
Polycyclic aromatic 
hydrocarbons (PAHs) 
HCBD – 
hexachlorobutadiene 

1336-36-3 and 
others 

70776-03-3 and 
others 

207-08-9 and 
others  

Annex C 

Annex C 

No 

87-68-3 

Annex C 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes – added with the 2019 
recast 

Yes 

Yes – added with the 2019 
recast 
Yes 

Yes – added with the 2019 
recast 

*  Lindane,  Alpha-  and  Beta  hexachlorocyclohexane,  as  well  as  Chlordecone  and  Hexabromobiphenyl  are  new  POPs 
under the Stockholm Convention but have already been covered under the POP Protocol and the POPs Regulation. 

1.2.3.  Coordination  and  cooperation  among  the  Basel,  Rotterdam  and  Stockholm 

Conventions 

The  Basel,  Rotterdam  and  Stockholm  Conventions  are  multilateral  environmental 
agreements,  which  share  the  common  objective  of  protecting  human  health  and  the 
environment from hazardous chemicals and wastes. These agreements can assist countries to 
manage chemicals at different stages of their life-cycle. 

Recognizing  the  potential  for  synergistic  work  under  the  three  conventions  at  the  national, 
regional  and  global  levels,  the  international  community  has  worked  over  the  past  years  on 
enhancing  cooperation  and  coordination  among  the  Basel,  Rotterdam  and  Stockholm 
Convention.  These  efforts  culminated  in  the  adoption  of  recommendations  on  enhancing 
cooperation  and  coordination  among  the  three  conventions  by  the  three  Conferences  of  the 
Parties held in 2008 and 2009, and the holding of simultaneous extraordinary meetings of the 
Conferences  of  the  Parties  to  the  Basel,  Rotterdam  and  Stockholm  Conventions  in  Bali, 
Indonesia in February 2010, and in Geneva in May 2013. Furthermore, ordinary meetings of 
the Conferences of the Parties were held back-to-back in 2015, 2017 and 2019. 

One  of  the  first  steps  of  the  synergies  process  was  the  restructuring  of  the  secretariats  in  a 
manner that strengthens organizational synergies while respecting the legal autonomy of each 
convention.  Further  steps  taken  at  successive  triple  COP  meetings  resulted  in  aligning  and 
integrating  the  work  of  the  Stockholm,  Basel  and  Rotterdam  Conventions  including  cross-
cutting  measures  for  information  exchange.  Today,  the  enhanced  coordination  and 
cooperation resulting from the synergies process is a fundamental pillar of all the work that is 
done  under  the  conventions  in  order  to  increase  policy  coherence  and  maximise  efficiency 
and resources. The synergies are mainstreamed in all relevant activities, as appropriate, rather 
than  being  a  separate  activity.  The  COP-7  meeting  in  May  2015  introduced  17  new  joint 
activities building on these synergies, and also broadened the remit of the global environment 
facility (GEF) to cover financing for projects on both chemicals and waste (BRS Secretariat, 
201513). At the COP-8 meeting in 2017, reports on reviews of the synergies arrangements for 

13   BRS Secretariat, 2015, ’10 years of synergies decisions – compilation of decisions related to enhancing co-

operation among the Basel, Rotterdam and Stockholm Conventions’ 

15 

 
 
 
                                                           
the  Basel,  Rotterdam  and  Stockholm  Conventions  were  discussed  and  the  BRS  Secretariat 
was  requested  to  continue  to  seek  opportunities  for  enhanced  coordination  and  cooperation 
among the conventions (BRS Secretariat, 2017). 

1.3. 

Purpose of the Union Implementation Plan on POPs 

The Stockholm Convention lays down an obligation to all Parties, to develop and endeavour 
to implement a plan for the implementation of its obligations under the Convention. For the 
Union, this obligation is also transferred to the Article 9 of the POPs Regulation. The Union 
has  in  2007  therefore  developed  an  Implementation  Plan  on  POPs  (SEC(2007)341),  which 
also covers the substances that fall under the UNECE Protocol on POPs14. 

The overall purpose of the implementation plan is not only to fulfill legal obligations, but also 
to  take  stock  of  actions  taken  and  lay  down  a  strategy  and  action  plan  for  further  Union 
measures  related  to  POPs  included  in  the  Stockholm  Convention  and/or  in  the  UNECE 
Protocol on POPs.  

The implementation plan therefore aims to: 

 

review the existing Union level measures related to POPs; 

  assess  their  efficiency  and  sufficiency  in  meeting  the  obligations  of  the 

Stockholm Convention; 

 

identify needs for further Union level measures; 

  establish a plan for implementing the further measures; 

 

identify  and  strengthen  links  and  potential  synergies  between  POPs 
management and other environmental policies and other policy fields; and 

 

increase awareness on POPs and their control measures. 

In  developing  this  implementation  plan  information  and  data  has  been  taken  from  the 
following key sources: 

  Union  policy  and  legislative  documents  used  to  govern  and  manage  the 

policy landscape on chemicals; 

  Member  States’  reports  submitted  to  the  European  Commission  as  per 

Article 12 of Regulation (EC) No 850/2004; 

  Member States National Implementation Plans; 

  Union databases on chemicals including: 

o  Chemical databases held by the European Chemicals Agency as part of 

the REACH15 and CLP16 Regulations; 

o  European Pollutant Release and Transfer Register (E-PRTR); 

14 http://ec.europa.eu/environment/chemicals/international_conventions/index_en.htm 
15 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 on the 
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) (OJ L 396, 30.12.2006, p. 1) 
16 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on the 

classification, labelling and packaging of substances and mixtures (OJ L 353, 31.12.2008, p. 1) 

16 

 
 
 
                                                           
o  UNECE EMEP database for POPs release estimates; 

o  Eurostat; 
o  Pesticides database17; 

o  European Substance Information Systems (ESIS) database; 
o  The EFSA OpenFoodTox database18 

  Scientific journal literature; 

 

Input from key experts in the field. 

Further detailed information can also be found within Member State national implementation 
plans, and triennial synthesis reports developed  by the European Commission,  which detail 
work undertaken within Union, including information on releases and monitoring of POPs. 

2. 

PART I – PARTY BASELINE 

This section presents the Union’s baseline with regard to POP chemicals regulated under the 
Stockholm Convention and the Protocol on POPs. As such it includes at first an overview on 
the  key  Union  legislation  related  to  the  implementation  of  obligations  in  the  mentioned 
international frameworks as well as related Union strategies and programmes, followed by a 
description of existing financial instruments to support the implementation as well as research 
activities. In order to get a full picture of the status quo of the implementation, a description 
will  be  provided  on  what  efforts  are  currently  being  undertaken  by  the  Union  to  raise 
awareness  and  enhance  communication.  Furthermore,  an  overall  assessment  of  POPs 
regarding their manufacture, their use, their placing on the market as well as with regard to 
existing stockpiles and the contamination of the waste stream will be described.  

This Part I ‘Party Baseline’ presents the basic information on the Union situation and will be 
followed by an in-depth analysis in Part II regarding each single obligation of the Stockholm 
Convention.  This  analysis  is  followed  by  the  identification  of  actions  to  improve  the 
implementation. 

2.1. 

Key Union Legislation and Policies related to the Union’s Obligations under the 
Stockholm Convention and UNECE Protocol on POPs 

The  Union  has  implemented  a  number  of  legislative  measures  that  are  related  to  POPs 
addressing  both  the  aims  of  the  Stockholm  Convention  but  also  the  UNECE  Protocol  on 
POPs.  The  following  figure  gives  an  overview  of  the  main  chemical  and  environmental 
legislation  relating  to  POPs  and  to  which  stage  of  the  lifecycle  it  refers  to.  Details  on  the 
legislation related to POPs are described in the following sub-sections.  

17 http://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/public/?event=homepage&language=EN 
18 https://www.efsa.europa.eu/en/data/chemical-hazards-data 

17 

 
 
 
 
 
  
                                                           
Figure 1 

Overview of the main chemical and environmental legislation related to POPs 

18 

 
 
 
 
2.2. 

Legislative instruments 

2.2.1.  Regulation (EC) No 850/2004 (First POPs Regulation) 

As signatory to both the Stockholm Convention and the UNECE Protocol on POPs, in order 
to  implement  the  Union’s  international  obligation,  the  European  Union  legislators  adopted 
the  Regulation  on  persistent  organic  pollutants  (hereafter  called  “Regulation  (EC)  No 
850/2004”)  to  uphold  the  aims  of  the  Convention  and  Protocol  at  Union  level.  This 
Regulation  entered  into  force  on  20  May  2004  and  was  directly  applicable  in  all  Member 
States, including those which are not yet Parties to the Stockholm Convention or the UNECE 
POP Protocol.  

Regulation  (EC)  No  850/2004  contains  provisions  regarding  manufacturing,  placing  on  the 
market and use of chemicals, management of stockpiles and wastes and measures to  reduce 
releases of unintentionally produced POPs. Exports of POPs are regulated under Regulation 
(EU)  No  649/2012  concerning  the  export  and  import  of  hazardous  chemicals.  The 
exemptions  to  the  prohibitions  under  the  POPs  Regulation  are  limited  to  a  minimum. 
Furthermore,  Regulation  (EC)  No  850/2004  contains  provisions  requiring  the  setting  up  of 
emission inventories for unintentionally produced POPs, national and Union implementation 
plans and monitoring and information exchange mechanisms. To a certain extent Regulation 
(EC)  No  850/2004  goes  further  than  the  international  agreements  emphasising  the  aim  to 
eliminate  the  manufacture  and  use  of  the  internationally  recognised  POPs,  notably  this 
includes  the  development  of  legally  binding  thresholds  for  POPs  within  waste,  which  are 
detailed  in  Annex  IV  of  the  Regulation.  Where  the  thresholds  are  exceeded,  only  certain 
disposal or recovery operations can be applied to the waste containing POPs in such a way as 
to  ensure  that  the  POP  content  is  irreveribly  transformed  or  destroyed.  POP  substances 
separated from waste cannot be recycled under any circumstance and have to be destroyed.  

Concerning management of stockpiles, the Regulation provides that all remaining stockpiles 
for which no use is permitted shall be managed as waste. Stockpiles greater than 50 kg meant 
for  permitted  uses  shall  be  notified  to  the  competent  authority  and  managed  in  a  safe, 
efficient  and  environmentally  sound  manner.  Holders  of  a  stockpile  consisting  of  or 
containing any POPs for which no use is permitted shall manage that stockpile according to 
the specified requirements. 

With regard to wastes, producers and holders of waste are obliged to undertake measures to 
avoid contamination of waste with POP substances. Waste with POPs content higher than the 
above  mentioned  lower  POP  limits  (under  Annex  IV)  must  generally  be  disposed  of  or 
recovered  in  such  a  way  that  the  POP  content  is  destroyed  or  irreversibly  transformed.  By 
way of derogation, wastes containing POPs below the limit values indicated in Annex V may 
be otherwise dealt with in accordance with a method listed in Annex V, part 2, subject to the 
conditions outlined in Article 7.4 (b)19. 

19   The  upper  concentration  limits  are  not  valid  for  permanent  underground  landfilling.  Regulation  (EC) 
172/2007  amending  Regulation  (EC)  850/2004:  „These  limits  exclusively  apply  to  a  landfill  site  for 
hazardous  waste  and  do  not  apply  to  permanent  underground  storage  facilities  for  hazardous  wastes, 
including salt mines.” 

19 

 
 
 
                                                           
2.2.2.  Recast of the POPs Regulation ((EU) 2019/1021) 

2.2.2.1.  Introduction 

Regulation (EC) No 850/2004 has been amended several times to take into account changes 
within  the  Convention  and  Protocol  annexes  as  well  as  changes  in  other  related  Union 
legislation such as REACH. On 22 March 2018 the Commission adopted a proposal to recast 
the  POPs  Regulation20.  The  position  of  the  European  Parliament  was  adopted  on  18  April 
2019, and passed to the Council of the European Union in early May 2019. The recast of the 
POPs Regulation was adopted on 20 June 2019 and formally published in the Official Journal 
of the European Union on 25 June 201921. 

While the overall structure of the POPs Regulation is broadly similar to Regulation (EC) No 
850/2004, there are a number of important changes included, which can be broadly grouped 
into five categories: 

 

Institutional changes for the role of the European Chemicals Agency (ECHA) and the 
Commission; 

  Changes related to Member States reporting; 

  Changes related to waste and waste management; 

  Changes made to terminology to build greater alignment to REACH; 

  POP specific changes (notably for PCBs and PBDEs). 

2.2.2.2.  Institutional changes for the role of ECHA and the Commission 

The  POPs  Regulation  provides  a  significant  new  role  for  ECHA  in  its  implementation  and 
development of technical and scientific dossiers. Article 8 of the POPs Regulation defines the 
new duties that  are undertaken by ECHA (further supported by the  Forum  for Exchange of 
Information on Enforcement established under the REACH Regulation, hereafter referred to 
as “the Forum”).  

In particular ECHA has a key role to support the Commission by assisting in identifying new 
substances that meet the criteria to be considered ‘POPs’, and development of the risk profile 
and risk management evaluation dossiers, which are to be developed for the review process 
under  the  Stockholm  Convention.  These  changes  also  allow  greater  transparency  in  the 
process  for  identification  of  new  POPs.  Under  the  POPs  Regulation  ECHA  is  required  to 
publish notice on its website that a proposal for the listing of a substance (screening dossier) 
will be prepared by the Commission  and allow comments  from  all interested parties within 
eight weeks of the publication. 

Furthermore,  during  the  development  of  the  risk  profile  and  risk  management  evaluation 
dossiers,  the  POPs  Regulation  also  allows  input  (and  new  data)  from  all  interested  parties, 
again  with  an  eight-week  window  for  commenting  following  publication  on  the  ECHA 
website. 

20   COM(2018)  144  final.  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  on 

persistent organic pollutants (recast). 

21   https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R1021&from=EN 

20 

 
 
 
                                                           
ECHA also has further duties to provide technical input (upon request from the Commission) 
to ongoing processes under the Convention, collation and publication of information reported 
by the Member States and maintain a section on the ECHA website dedicated to POPs. 

The Forum has the role to establish a network of Member State authorities responsible for the 
enforcement  of  the  POPs  Regulation.  This  network  will  co-ordinate  enforcement  efforts 
carried out at Member State level and will also address waste and waste-related matters that 
fall under the POPs Regulation. 

Article  16  of  the  POPs  Regulation  states  that  ECHA’s  budget  for  this  new  role  will  be 
sourced  through  a  combination  of  a  subsidy  from  the  Commission  and  donations  from  the 
Member States.  

The  POPs  Regulation  also  grants  new  powers  to  the  Commission  for  amendment  of  the 
Annexes. Under Article 15 of the POPs Regulation, the Commission is empowered to adopt 
delegated acts amending Annexes I, II and/or III. The European Parliament and the Council 
still have the right to object, but the use of delegated acts is intended to make the amendment 
of  Annexes  in  light  of  changes  under  the  Convention  or  the  Protocol  more  efficient.  The 
Commission  also  has  a  watching  brief  to  monitor  Annexes  IV  and  V  for  any  necessary 
amendments.  The  Commission  is  also  (under  Article  10)  able  to  consider  the  need  for 
mandatory monitoring of substances listed in Part B of Annex III. Additionally, under Article 
7(5)  of  the  POPs  Regulation,  the  Commission  may  adopt  implementing  acts  concerning 
waste management, in particular with regard to the format of information to be submitted by 
the Member States concerning exemptions from the prescribed waste disposal and recovery 
provisions set out in the Regulation.  

2.2.2.3.  Changes related to Member States reporting 

Reporting is a key component of the POPs Regulation and builds upon the work completed at 
Member State level to tackle the issues posed by POPs. Under Regulation (EC) No 850/2004, 
Article  12  included  obligations  on  Member  States  to  report  annually  (on  management  of 
substances  list  in  Annex  I  or  II)  and  triennially  (on  the  broader  issues,  including  emission 
inventories) to the Commission. Additionally, Article 12 then also placed obligations on the 
Commission to produce a report every three years on the Union’s progress towards the aims 
of the regulation. 

Taking  into  account  the  Commission  Report  on  Actions  to  Streamline  Environmental 
Reporting and its related Fitness Check, the POPs Regulation proposes a different approach 
to  reporting.  Under  Article  13,  Member  States  are  obligated  to  develop  reports  on  their 
progress  to  implement  the  regulation,  including  data  on  annual  monitoring  and  statistics 
which will be published at national level. These reports are to be kept up to date, with annual 
updates for any new data, or if no new data is available, with an update at least once every 
three years as a minimum. 

Under  Article  17  of  the  POPs  Regulation,  the  Agency,  in  cooperation  with  the  Member 
States,  specifies  formats  and  software  for  the  publication  of  data  by  the  Member  States 
pursuant to the Regulation and makes them available free of charge on its website. 

Additionally, for monitoring data the POPs Regulation highlights the importance of the new 
Information Platform for Chemical Monitoring (IPCheM), and that all monitoring data should 

21 

 
 
 
be  provided  to  IPCheM,  again  with  formats  to  be  agreed  between  the  Member  States  and 
ECHA. 

2.2.2.4.  Changes related to waste and waste management 

The POPs Regulation provides a stronger focus on POPs wastes and waste-management. In 
particular, the POPs Regulation comments that for national reports and implementation plans 
Member  States  are  encouraged  to  include  any  information  on  the  identification  of 
contaminated  sites.  Additional  focus  is  also  given  to  management  of  POPs  within  waste 
streams and traceability to avoid regrettable re-entry to the market through recycling. Recital 
17 of the POPs Regulation specifically states: 

“In  order  to  promote  the  traceability  of  waste  containing  POPs  and  ensure  control,  the 
provisions  of  the  record  keeping  system  established  in  accordance  with  Article  17  of 
Directive  2008/98/EC  should  apply  also  to  such  waste  containing  POPs  which  is  not 
defined as hazardous waste according to Commission Decision 2014/955/EU22”. 

This  means  that  for  wastes  containing  POPs,  even  when  not  classified  as  hazardous,  the 
record-keeping  obligations  that  apply  to  producers  or  installations  managing  hazardous 
waste, will also apply, including documenting the quantity, nature and origin of the waste and 
the destination of the waste. As a minimum this requires the holders of such waste to notify 
the competent authority of the POP content of their wastes.  

The recast  further  comments  that  the Commission  is assisted by  the  Committee established 
under the Waste Framework Directive (2008/98/EC) to ensure a consistent approach to how 
wastes are managed within the Union. 

2.2.2.5.  Changes made to terminology to build greater alignment to REACH 

A number of smaller but important changes have been included within the POPs Regulation 
to help build closer alignment with other related Union legislation. In particular under Article 
2 this includes the revision of terminology in a number of places to align more closely with 
REACH. For example, the Stockholm Convention refers to ‘production’, while the REACH 
Regulation refers to ‘manufacture’, covering the same set of activities. 

2.2.2.6.  POP specific changes (notably for PCBs and PBDEs) 

The  majority  of  the  changes  in  the  POPs  Regulation  affect  functional  elements  of  how  the 
legislation works  and roles and obligations for different  bodies. However, there  are a small 
number  of  changes  which  specifically  affect  certain  POPs  substances,  with  the  two  key 
changes  of 
to  polybrominated  diphenyl  ethers  (PBDEs)  and 
importance  relating 
polychlorinated biphenyls (PCBs): 

  PBDEs:  The  POPs  Regulation  made  provisions  under  Annexes  IV  and  V  for 
management of wastes containing PBDEs as a family defined by homologue groups 

22  Commission  Decision  2014/955/EU  of  18  December  2014  amending  Decision  2000/532/EC  on  the  list  of 
waste pursuant to Directive 2008/98/EC of the European Parliament and of the Council (OJ L 370, 30.12.2014, 
p. 44). 

22 

 
 
 
 
 
                                                           
(i.e.  pentaBDE,  hexaBDE,  heptaBDE,  etc.).  By  Commission  Regulation  (EU) 
1342/201423  the  Annex  IV  threshold  (for  low  POP  content)  for  wastes  containing 
PBDEs  as  an  aggregated  sum  was  set  at  1000  mg/kg  (1000ppm).  The  POPs 
Regulation notes the advances made in analytical chemistry and states that within two 
years of entry into force (not later than 16 July 2021) the Commission should review 
that  concentration  limit  and  should,  where  appropriate  and  in  accordance  with  the 
Treaties, adopt a legislative proposal to lower that value to 500 mg/kg.  

Furthermore,  under  Annex  I  of  the  POPs  Regulation  a  new  clause  has  been  added 
regarding  the  presence  of  PBDEs  (tetra,  penta,  hexa,  hepta  and  deca  homologues) 
within  new  articles  placed  on  the  market.  This  sets  a  maximum  threshold  of  500 
mg/kg for unintentional trace contamination of mixtures and articles with PBDEs. 

  PCBs:  Annex  I  part  A  of  the  POPs  Regulation  now  includes  the  additional  text  for 
PCBs:  “Member  States  shall  identify  and  remove  from  use  equipment  (e.g., 
transformers,  capacitors  or  other  receptacles  containing  liquid  stocks)  containing 
more than 0,005 % PCBs and volumes greater than 0,05 dm3, as soon as possible but 
no  later  than  31  December  2025.”  This  incorporates  the  overall  aim  from  the 
Stockholm  Convention  to  eliminate  the  remaining  use  of  PCBs  within  di-electric 
equipment by 2025. 

The  POPs  Regulation  also  includes  the  addition  of  new  terminologies,  in  particular  the 
addition of ‘unintentional trace contamination’, which is defined as: 

“'unintentional trace contaminant' means a level of a substance that is incidentally present in 
a minimal  amount, below which the substance cannot  be meaningfully used, and above the 
detection limit of existing detection methods to enable control and enforcement”. 

2.2.3.  European Union chemicals legislation 

Other  chemicals  legislation  complements  the  POPs  Regulation  in  implementing  the 
obligations of the Stockholm Convention and the POPs Protocol. As Table 2 shows, the other 
chemicals  legislation  particularly  ensures  that  the  export  ban  on  POPs  is  implemented  and 
that  allowed  imports  and  exports  are  in  conformity  with  the  rules  of  the  Stockholm 
Convention, ensures that POPs are collected and irreversibly destroyed and prevents that the 
chemicals exhibiting POP characteristics are produced or marketed.  

Table 2  Union chemicals legislation relevant for POPs 

Acronym 

Legal reference 

POPs regulated / POP reference 

REACH 

CLP 

Regulation (EC) No 
1907/2006 

Testing on PBT (persistent, bioaccumulative and 
toxic) criteria according to Annex XIII  

Regulation (EC) No 
1272/2008 

Inventory of classification and labelling of 
hazardous substances. 

Areas of 
regulation 

Manufacture, 
placing on the 
market & use 

Classification, 
Labelling, 

23 http://data.europa.eu/eli/reg/2014/1342/oj 

23 

 
 
 
  
 
                                                           
Acronym 

Legal reference 

POPs regulated / POP reference 

Plant Protection 
Product Regulation 

Regulation (EC) No 
1107/2009 

Biocidal Products 
Regulation  

Regulation (EU) 
528/2012 

An active substance, safener or synergist shall only 
be approved where it is not considered to be a 
persistent organic pollutant (POP) resp. PBT 
substance.  
Active substances meeting two of the PBT criteria 
shall be candidates for substitution 

Active substances meeting the PBT criteria shall 
not be approved. 
Active substances meeting two of the PBT criteria 
shall be candidates for substitution 

Areas of 
regulation 
Packaging 

Placing on the 
market & use  

Placing on the 
market & use 

PIC Regulation 
concerning the 
export and import of 
hazardous chemicals 

Regulation (EU) No 
649/2012 

POPs as listed in Annexes A and B of the 
Stockholm Convention are subject to export ban  

Export and import 
of dangerous 
chemicals 

PCB Directive 

Directive 96/59/EC 

Disposal of polychlorinated biphenyls and 
polychlorinated terphenyls (PCB/PCT) 

Disposal 

2.2.3.1.  REACH 

Regulation  (EC)  No  1907/2006  (REACH)  inter  alia  includes  provisions  to  ensure  that 
industrial  chemicals  having  POP  characteristics  are  identified  and  prevented  from  being 
produced  or  imported  in  the  Union.  Furthermore  under  the  authorisation  and  restriction 
processes, the promotion of innovation, use of safer alternatives and contribution to the goal 
of achieving sustainable development of chemical use are covered.  

REACH  requires  Union  companies  which  manufacture  or  import  chemical  substances  in 
quantities of one tonne or more per year to register these substances and ensure that they can 
be  used  safely.  This  information  is  submitted  in  the  form  of  registration  dossiers  to  the 
European Chemicals Agency (ECHA)24. The submission contains a technical dossier and, for 
substances  manufactured  or  imported  in  quantities  of  10  tonnes  per  annum  (tonnes  p.a.)  or 
above, a Chemical Safety Report (CSR). The chemical safety assessment detailed by the CSR 
has to cover: 

(a)  human health hazards; 
(b) physicochemical hazards; 
(c)  environmental hazards; 
(d) persistent,  bioaccumulative  and  toxic  (PBT)  and  very  persistent  and  very 

bioaccumulative (vPvB) properties.  

For  hazardous  substances  (such  as  those  assessed  to  be  a  PBT  or  vPvB),  an  exposure 
assessment  and  risk  characterisation  must  be  included  in  the  Chemical  Safety  Report.  For 
some of the substances identified as PBT or vPvB, an authorisation from the Commission is 
required  for particular uses. This  is  the case when a substance meeting the  requirements of 

24   https://echa.europa.eu/substances-of-very-high-concern-identification-explained  

24 

 
 
 
                                                           
the  ‘substance  of  very  high  concern’  (SVHC)  criteria25  is  included  in  Annex  XIV  of  the 
Regulation  and  will  then  become  banned  once  the  set  sunset  date  has  passed  unless  an 
authorization  is  granted.  Only  specific  uses  for  which  a  request  for  authorization  has  been 
made following specific requirements with regard to the assessment of the substance can be 
allowed. Prior to inclusion into Annex XIV the selected substances are part of the so-called 
Candidate  List,  which  in  itself  already  implies  a  number  of  obligations  such  as  e.g.  the 
obligation to deliver information on the content of a substance in an article. 

REACH  further  includes  the  possibility  to  restrict  the  use,  placing  on  the  market  or 
manufacture of substances by listing them in Annex XVII of REACH. This is another legal 
instrument  that  can  be  used  to  prevent  manufacture  and  use  of  substances  having  POP 
characteristics.  

With  the  above  described  measures  REACH  gives  greater  responsibility  to  industry  to 
manage the risks from  chemicals  and to  provide  safety information  on the substances. This 
information  has to  be passed down the chain  of  manufacture. The REACH Regulation  also 
aims to increase the knowledge of the chemicals properties and of the exposure through the 
required  provision  of  specific  documentation  and  to  improve  the  risk  management  of 
chemicals. 

2.2.3.2.  CLP 

The CLP Regulation (EC) No 1272/2008 is the Union Regulation on Classification, Labelling 
and Packaging of substances and mixtures26. The legislation introduces throughout the Union 
a  system  for  classifying  and  labelling  chemicals,  based  on  the  United  Nations’  Globally 
Harmonised  System  (UN  GHS).  CLP  is  about  the  hazards  of  substances  and  mixtures  and 
how to inform others about them. CLP does not contain a specific hazard class for PBT and 
vPvB  substances,  however  Article  53(2)  calls  for  the  promotion  at  the  UN  level  for  the 
harmonisation  of  the  criteria  for  classification  and  labelling  of  PBT  and  vPvB  substances. 
However,  the  classification  and  labelling  inventory27  set  up  by  the  CLP  Regulation  makes 
available relevant information that can be used to identify new potential POP candidates and 
also provides classification and labelling of several POPs. 

2.2.3.3.  Regulation on Plant Protection Products 

Regulation  (EC)  No  1107/2009  concerning  the  placing  of  plant  protection  products  on  the 
market28  (PPP  Regulation)  prevents  chemicals  exhibiting  POP  characteristics  from  being 
used in plant protection products. This is achieved by the provisions according to which an 
active  substance,  safener  or  synergist  shall  only  be  approved  for  use  in  plant  protection 
products where it is not considered to be a POP or if it is not considered to be a persistent, 
bioaccumulative  and  toxic  substance  (PBT)  or  a  very  persistent  and  very  bioaccumalative 
substance  (vPvB).  In  addition,  a  substance  may  only  be  approved  as  a  candidate  for 
substitution if it meets two of the PBT criteria. 

25   http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/substances-of-very-high-concern-

identification 

26  OJ L 353, 31.12.2008, p. 1. 
27  http://echa.europa.eu/en/information-on-chemicals/cl-inventory 
28  OJ L 309, 24.11.2009, p.1. 

25 

 
 
 
 
                                                           
Regulation  (EC)  No  396/2005  on  maximum  residue  levels  of  pesticides  in  or  on  food  and 
feed  of  plant  and  animal  origin  sets  the  highest  level  of  a  pesticide  residue  that  is  legally 
tolerated  in  or  on  food  or  feed  when  pesticides  are  applied  correctly.  This  includes  MRL 
values for several POPs (see Section 2.1.5).  

2.2.3.4.  Biocidal Products Regulation 

to  promote  substitution  of  substances 

Regulation  (EU)  No  528/2012  concerning  the  making  available  on  the  market  and  use  of 
biocidal  products29  aims 
that  exhibit  PBT 
characteristics  in  biocidal  products  for  less  hazardous  ones.  The  use  of  PBT  substances  in 
biocidal products is only allowed if there are no alternatives available. This is achieved by the 
provision that an active substance that meets two of the PBT criteria as set out in Annex XIII 
of  the  REACH  Regulation  shall  be  considered  as  a  candidate  for  substitution  and  shall  be 
identified  as  such  in  a  regulation  approving  an  active  substance  under  the  Biocides 
Regulation. A similar process also exists under the PPP Regulation. The approval of an active 
substance that is considered as a candidate for substitution shall be renewed for a period not 
exceeding seven years. As part of the evaluation of an application for an authorisation (or a 
renewal  of  an  authorisation)  of  a  biocidal  product  containing  an  active  substance  that  is  a 
candidate for substitution, the Competent Authority shall perform a comparative assessment 
to evaluate whether there are other authorised biocidal products (or non-chemical control or 
prevention methods) which present significantly lower risk for human or animal health or the 
environment. 

2.2.3.5.  Regulation on the export and import of hazardous chemicals 

The  export  of POP  substances  or  articles  containing  POPs  is  regulated  by  Regulation  (EU) 
No  649/2012  concerning  the  export  and  import  of  hazardous  chemicals30.  This  Regulation 
implements  the  Rotterdam  Convention  on  the  Prior  Informed  Consent  (PIC)  Procedure  for 
certain hazardous  chemicals and pesticides in  international trade and provides for an export 
ban of POP substances listed in Annexes A and B of the Stockholm Convention and in  the 
POPs Regulation. The decisions made at the COP-4 to the Stockholm Convention held on 4–
8  May  2009  listing  new  substances31  were  implemented  by  Regulation  (EU)  No  214/2011. 
The  fifth  Conference  of  the  Parties  to  the  Stockholm  Convention  (COP-5)  (April  2011) 
decided  to  list  endosulfan  in  Annex  A.  That  decision  was  implemented  in  the  Union  by 
Commission  Regulation  (EU)  No  73/2013,  which  adds  endosulfan  to  the  list  of  chemicals 
that are banned for export. Under Regulation (EU) No 649/2012 substances listed in Annex I 
are as a minimum subject to the export notification requirements. For POP-PBDEs and PFOS 
listed in Annex I, this includes  in  addition explicit consent requirements  (with the potential 
for exceptional waivers) from receiving non-EU countries. 

29  OJ L 167, 27.6.2012, p. 1. 
30  OJ L 201, 27.7.2012, p. 60. 
31   Including 

chlordecone,  hexabromobiphenyl, 

alpha 

and  beta  hexachlorocyclohexanes, 

lindane 

pentachlorobenzene and pentabromodiphenyl ether 

26 

 
 
 
 
 
                                                           
2.2.3.6.  PCB Directive (Directive 96/59/EC) 

Articles  containing  PCBs  already  in  use  are  covered  by  specific  provisions  laid  down  in 
Council Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated 
terphenyls (PCB/PCT)32. The directive aims for the approximation of the laws of the Member 
States  on  the  controlled  disposal  of  PCBs,  the  decontamination  or  disposal  of  equipment 
containing  PCBs  and/or  the  disposal  of  used  PCBs  in  order  to  eliminate  them  completely. 
According to the Directive, Member States had to take the necessary measures to ensure that 
used  PCBs  are  disposed  of  and  that  PCBs  and  equipment  containing  PCBs  are 
decontaminated or disposed of in an appropriate manner. 

Member States were obliged to compile inventories of equipment with PCB volumes of more 
than 5 dm³. These inventories were to be sent to the Commission by September 1999 at the 
latest.  The  equipment  and  PCBs  contained  in  the  inventories  had  to  be  decontaminated  or 
disposed  of  by  2010  at  the  latest  (deadlines  are  different  for  the  new  Member  States).  The 
inventories must supply the following data: 

 
 
 
 
 

the names and addresses of the holders; 
the location and description of the equipment; 
the quantity of PCBs contained in the equipment; 
the date and type of treatment planned; 
the date of the declaration. 

Moreover, the Directive stipulates that any equipment which is subject to inventory must be 
labelled. Member States must prohibit the separation of PCBs from other substances for the 
purpose of reusing the PCBs and the topping-up of transformers with PCBs. 

Concerning  the  appropriate  waste  management,  Member  States  had  to  take  the  necessary 
measures to ensure that: 

  PCBs, used PCBs and equipment containing PCBs which is subject to inventory are 
transferred  to  licensed  undertakings,  at  the  same  time  ensuring  that  all  necessary 
precautions are taken to avoid the risk of fire; 

  any incineration of PCBs or used PCBs on ships is prohibited; 
  all  undertakings  engaged  in  the  decontamination  and/or  the  disposal  of  PCBs,  used 

 

PCBs and/or equipment containing PCBs obtain permits; 
transformers  containing  more  than  0.05%  by  weight  of  PCBs  are  decontaminated 
under the conditions specified by the Directive. 

In  accordance  with  the  committee  procedure  referred  to  in  Directive  75/442/EEC33,  the 
Commission: 

  had  to  fix  the  reference  methods  of  measurement  to  determine  the  PCB  content  of 

contaminated materials34; 

  could fix technical standards for the other methods of disposing of PCBs; 

32  OJ L 243, 24.9.1996, p. 31. 
33   OJ L 194, 25.7.1975, p. 39. 
34   This task  has been addressed by  Commission Decision 2001/68/EC establishing two reference  methods of 

measurement for PCBs pursuant to Article 10(a) of Council Directive 96/59/EC. 

27 

 
 
 
 
                                                           
  had  to  make  available  a  list  of  the  manufacture  names  of  capacitors,  resistors  and 

induction coils containing PCBs35; 

  had to determine, if necessary, other less hazardous substitutes for PCBs. 

The Commission completed the tasks mentioned above, as appropriate. 

Within three years following the adoption of Directive 96/59/EC, Member States had to draw 
up  plans  for  the  decontamination  and/or  disposal  of  inventoried  equipment  and  the  PCBs 
contained  therein  and  plans  for  the  collection  and  subsequent  disposal  of  equipment  not 
subject to inventory. Furthermore, under the recast of the POPs Regulation (EU) 2019/1021 
all remaining PCBs within di-electric equipment (above 0.005% PCB in volumes greater than 
0.05 dm3) are to be irreveribly destroyed by 2025. 

2.2.4.  Other environmental legislation with POP relevance 

In addition  to  the chemicals legislation, environmental  legislation especially those targeting 
water, waste and products also cover POP-related issues. 

Table  3  summarizes  the  most  relevant  legislation  with  POP  relevance  and  indicates  which 
POPs  are  regulated.  The  table  also  includes  environmental  legislation  covering  releases  of 
unintentionally produced POPs. The legislation is presented in more detail in Part II if further 
measures for the implementation may be necessary.  

In  comparison  with  the  first  Implementation  Plan,  four  new  legislative  acts  have  been 
adopted: Directive 2008/98/EC on Waste (Waste Framework Directive), Regulation (EC) No 
1013/2006 on shipments of waste, Directive 2010/75/EU on Industrial Emissions (including 
waste  incineration),  Regulation  (EC)  No  66/2010  on  the  EU  Ecolabel  and  Directive 
2006/11/EC on pollution caused by certain dangerous substances discharged into the aquatic 
environment.  

The  most  important  legislation  covering  the  release  of  unintentionally  produced  POPs  is 
Directive 2010/75/EU, the Industrial Emissions Directive (IED)36 which since 7 January 2014 
has  repealed  and  replaced  Directive  2008/1/EC  concerning  integrated  pollution  prevention 
and  control  (IPPC  Directive)  and  Directive  2000/76/EC  on  Waste  Incineration  (amongst 
others).  

The purpose of the IED is to ensure a high level of protection of the environment taken as a 
whole. Industrial installations operating activities covered by Annex I of the IED are required 
to obtain an environmental permit from the authorities in the Member States. Emissions of all 
relevant polluting substances (including POPs), which are likely to be emitted in significant 
quantities, have to be regulated in the permit.  The whole environmental performance of the 
installation is taken into account, covering e.g. emissions to air, water and land, generation of 
waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration 
of  the  site  upon  closure.  The  conditions  set  out  in  this  permit,  in  particular  the  emission 
limits, have to be based on the application of BAT.  

35   In 2001 the Commission has drawn up a list and made it available to the Member States. 
36   OJ L 334, 17.12.2010, p. 17. 

28 

 
 
 
 
                                                           
The  definition  of  BAT  in  the  IED  generally  corresponds  with  the  one  of  the  Stockholm 
Convention.  In order to  identify  BAT, the Commission  organises  an information  exchange, 
where  BAT  is  described  and  defined  for  the  different  industrial  sectors  in  so-called  Best 
Available Techniques REFerence Documents (BREFs). Where relevant, also for POPs, BAT 
Associated  Emission  Levels  (BAT-AELs)  are  developed.  Under  the  IED,  the  BAT 
conclusions  is  the  part  of  the  BREF  that  is  formally  adopted  as  Commision  Implementing 
Decision.  The  BAT  and  BAT-AELs  set  out  therein  are  to  be  used  by  the  permitting 
authorities in setting permit conditions and emission limit values for permits. Emission levels 
set in the permits for certain pollutants should be within the BAT-AELs unless a derogation 
from BAT-AELs applies to the installation37.  

Table 3 

Further environmental legislative instruments with relevance on the use and 
disposal of POPs (including unintentionally produced POPs)  

Acronym 

Legal reference 

POPs regulated / POP reference  

Areas of regulation 

EU Ecolabel 

Regulation (EC) No 
66/2010 

Criteria of product categories laid down in 
Commission decisions may cover POPs e.g. 
in textile floor covering for trace 
contamination with POP pesticides38 

A product cannot obtain an ecolabel if it 
contains a PBT/vPvB substance. 

Different product categories, 
see: 39 

RoHS Directive 

Directive 
2011/65/EU  

Ban of PBDE and other hazardous 
substances in electrical and electronic 
equipment. 

Manufacture and import of 
electrical and electronic 
products  

Waste Directive 

Directive 
2008/98/EC 

Waste Shipments 
Regulation 

Regulation (EC) No 
1013/2006 

Industrial 
Emissions 
Directive 

Directive 
2010/75/EU  

The classification of waste as hazardous 
waste should be based, inter alia, on the 
Union legislation on chemicals, in particular 
concerning the classification of preparations 
as hazardous, including concentration limit 
values used for that purpose.40 

This regulation establishes procedures and 
control regimes for the shipment of waste. 
Reference is made in Annex VIII of this 
Regulation to technical guidelines under the 
framework of the Basel Convention, on the 
environmentally sound management of 
waste containing or contaminated with 
POPs. 

Waste incineration: Emission limit values 
for air, discharges of waste water for 
dioxins and furans. 
Industrial activities: Polychlorinated 
dibenzodioxins and polychlorinated 

Waste  

Waste 

Industrial emissions 

37   A derogation may apply only where an assessment shows that the achievement of emission levels associated 
with the best available techniques as described in BAT conclusions would lead to disproportionately higher 
costs compared to the environmental benefits due to the geographical location or the local environmental 
conditions of the installation concerned; or the technical characteristics of the installation concerned. 

38  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:332:0001:0016:EN:PDF  
39  http://ec.europa.eu/ecat/   
40   https://ec.europa.eu/environment/waste/framework/framework_directive.htm  See also EU 1357/2014 which 
replaces  Annex  III  of  the  Waste  Framework  Directive.  In  particular  recital  2  details  the  measures  for 
hazardous wastes. 

29 

 
 
 
                                                           
Acronym 

Legal reference 

Directive 
76/464/EEC 
has been 
codified as 
2006/11/EC  

Directive 
2006/11/EC 

POPs regulated / POP reference  
dibenzofurans are among the main air 
pollutants to be considered in permitting 
and persistent hydrocarbons and persistent 
and bioaccumulable organic toxic 
substances among the main water 
pollutants.  
First series of Commission Implementing 
Decisions establishing BAT conclusions for 
the different industrial sectors have been 
adopted under the IED (with more to follow 
over the coming years). 

Pollution through the discharge of the 
various dangerous substances within List I 
into the aquatic environment must be 
eliminated.  
List I contains certain individual substances 
selected mainly on the basis of their 
toxicity, persistence and bioaccumulation.  

Areas of regulation 

Pollution caused by certain 
dangerous substances 
discharged into the aquatic 
environment 

Landfill Directive 

Directive 
1999/31/EC 

Hazardous waste for landfills needs a prior 
treatment.  

Waste 

WEEE Directive 

Directive 
2012/19/EU 
(recast) 

Environmental 
Liability Directive 

Directive 
2004/35/EC 

ELV Directive 

Directive 
2000/53/EC 

Groundwater 
Directive 

Directive 
2006/118/EC 

Drinking Water 
Directive 

Council Directive 
98/83/EC 

Provisions on waste containing hazardous 
substances, e.g. removal of PCB containing 
capacitors and plastic containing 
brominated flame retardants from all 
separately collected WEEE, mandatory 
segregation of PCB-containing 
components,. 

Note the original WEEE Directive 
(2002/96/EC) was recast in 2012. 

Intended to reduce incidents and also ensure 
remediation on the basis of the polluter pays 
principle of significant emissions both to 
land (and as a consequence soil) and water.  
The Directive raises expectations in terms 
of preventive action, reducing the incidence 
of emissions as well as promoting 
remediation. 

Due to the segregation of hazardous 
components from the vehicle, the releases 
of unintentionally produced POPs from 
shredder plants are decreased.  

Groundwater quality standards and 
threshold values for most important 
pollutants, among them pesticides. 

Standards for the most common substances 
(so-called parameters), among them PAHs, 
and pesticides (aldrin, dieldrin, heptachlor 
and heptachlor epoxide). 

30 

Treatment of waste electrical 
and electronic equipment 
(WEEE) 

The directive is focused on 
instances of environmental 
damage, such as emissions of 
pollutants that change the 
status of land, water, and 
biodiversity. The Directive 
only applies to environmental 
damage caused by an 
emission, event or incident 
which took place after 30 
April 2007 where such 
damage derives either from 
activities carried out after that 
date or activities which were 
carried out but had not 
finished before that date 

Collection, treatment, 
recycling and disposal of end-
of-life vehicles. 

Protection of groundwater 
from detrimental 
concentrations of harmful 
pollutants. 

Quality of water intended for 
human consumption 

 
 
 
 
Acronym 

Legal reference 

POPs regulated / POP reference  

Areas of regulation 

Marine Strategy 
Framework 
Directive 

Directive 
2008/56/EC 

Water Framework 
Directive 

Directive 
2000/60/EC 

SEVESO III 
Directive 

Ambient air quality 

Directive 
2012/18/EU  

Directive 
2004/107/EC 

Synthetic compounds identified as priority 
substances under directive 2000/60/EC 
which are relevant for the marine 
environment. 

The Water framework directive acts as the 
parent piece of legislation for all water and 
water quality related issues within the EU. 
For POPs the water framework directive 
along with the daughter directive on 
Environmental Quality Standards put in 
place the requirements to quantify and 
manage the release of POPs into the water 
environment. This includes the development 
of River Basin Management Plans to 
actively identify and manage the 
anthropogenic burdens upon waters within 
the EU. 

Pollution from industrial accidents. 

Protection of marine waters 
under the sovereignty and 
jurisdiction of Member States 

Protection of inland surface 
waters, transitional waters, 
coastal waters and 
groundwater. 

Prevention, Preparedness and 
Response to chemical 
accidents  

Limit values for benzo[a]pyrene as a marker 
for PAH in ambient air.  

Protection of ambient air 
quality for identified polutants 

The EQS directive repeals the ‘Annex X’ 
list of priority and priority hazardous 
substances quoted under the water 
framework directive (2000/60/EC). Annex I 
of the EQS Directive expands upon the 
Annex X list with additional named 
pollutants, deemed as priority or priority 
hazardous substances (including POPs) for 
which maximum environmental 
concentrations (EQS) must not be exceeded. 
In the case of priority hazardous substances, 
discharges, emissions and losses must be 
phased out to natural background levels. 
The directive also creates a ‘watch-list’ for 
monitoring additional substances of concern 
in the natural environment. 
The directive also places a requirement for 
inventories of discharges, emissions and 
losses for priority substances which should 
inform planning and reporting under the 
river basin management plans (RBMPs) 
communicated under the water framework 
directive. 

The new legistlation includes a compost 
safety limit for total PAHs (EPA 16) of 6 
mg/kg dm, which also applies to any 
material recirculated through the 
composting process  

Protection of inland surface 
waters, transitional waters, 
coastal waters and 
groundwater. 
Dioxins and Furans, PCBs 
PAHs, hexachlorobenzene, 
hexachlorobutadiene, 
pentachlorobenzene are  
included in Annex I as PHS, 
i.e.there is an objective to 
phase out discharges, 
emissions and losses. 

Fertilising products applied to 
land  

Environmental 
Quality Standards 
(EQS) 

Directive 
2013/39/EC 

Fertilising Products 
Regulation 

Regulation (EC) No 
2003/2003 will be 
replaced from 16 
July 2022 by 
Regulation  
(EU) 2019/1009 

2.2.5.  Legislation on food and feed and on the protection of public health  

Regulations  (EC)  No  1881/2006  and  396/2005  and  Directive  2002/32/EC  set  maximum 
residues  levels  for  POP  substances  in  food  and  feed.  Regulation  (EC)  No  1883/2006  sets 
minimum requirements on methods of sampling and analysis for the official control of levels 

31 

 
 
 
of  dioxins  and  dioxin-like  PCBs  in  certain  foodstuffs  and  Regulation  (EC)  152/2009  sets 
minimum requirements on methods of sampling and analysis for the official control of levels 
of dioxins and dioxin-like PCBs in feed (see Table 4).  

EFSA  conducts  an  annual  monitoring  programme  for  residues  of  pesticides  in  food.  POPs 
formerly  used  as  pesticides  are  covered  by  MRLs  and  are  therefore  included  in  the 
monitoring  programme.  EFSA  is  responsible  for  preparing  an  annual  report41  on  pesticide 
residues based on an analysis of information submitted by Member States in accordance with 
Regulation (EC) No 396/2005.  

In  comparison  with  the  situation  when  the  first  Implementation  Plan  was  drafted,  there  are 
substantial  changes  in  the  Union  food  and  feed  legislation.  These  changes  relate  to  the 
conversion  of  the  maximum  levels  in  feed  and  food  for  dioxins  and  dioxin-like  PCBs, 
previously  expressed  in  Toxic  Equivalent  Factors  (TEF)  1998,  into  maximum  levels 
expressed in TEF 2005. Furthermore maximum levels for non dioxin like PCBs (the so called 
indicator  PCBs)  have  been  established  in  feed  and  food.  The  POP  Regulation  requires  the 
setting  up  of  emission  inventories  for  unintentionally  produced  POPs,  some  of  which  may 
enter  the  food  chain  via  atmospheric  deposition  and  bioaccumulation.  More  detail  can  be 
found in section 2.1.1.  
The  European  Food  Safety  Authority  (EFSA)  produced  a  report  in  May  201542  to  evaluate 
the  methodologies  used  internationally  in  deriving  health  based  safety  values  for  dioxins, 
furans  and  dioxin-like  PCBs  within  food.  This  study  aimed  to  better  understand  the 
methodologies used by the Joint FAO/WHO Expert Committee on Food Additives (JECFA), 
US EPA, and Scientific Committee on Food (SCF). The study notes that, while the JECFA 
and  SCF  base  assessments  on  animal  data,  the  USEPA  make  use  of  human  data.  Further 
differences in the modelling approach for toxicology and accepted no observed adverse effect 
level  (NOAEL)  between  SCF/JECFA  and  US-EPA  resulted  in  US-EPA  values  being  three 
orders  of  magnitude  lower  than  the  SCF/JECFA  values.  EFSA  have  stated  that  these 
differences  warrant  a  comprehensive  risk  assessment  to  further  understand  the  relationship 
between animal and human toxicology data.  

In June 2018 EFSA published a paper on the risk for animal and human health related to the 
presence  of  dioxins  and  dioxin‐like  PCBs  in  feed  and  food43.  The  data  from  experimental 
animal and epidemiological studies were reviewed and it was decided to base the human risk 
assessment on effects observed in humans and to use animal data as supportive evidence. The 
study  essentially  led  to  a  new  health-based  guidance  value  for  dioxins  and  dioxin-like 
polychlorinated biphenyls (dl-PCB)44. 

41   EFSA 

(2019) 

The 

European  Union 

report 

on 

pesticide 

residues 

in 

food, 

https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2019.5743 

42   EFSA, 2015, ‘Scientific  statement on the health-based  guidance values  for dioxins and  dioxin-like PCBs’, 

doi:10.2903/j.efsa.2015.4124. http://www.efsa.europa.eu/en/efsajournal/doc/4124.pdf 

43   http://www.efsa.europa.eu/en/efsajournal/pub/5333  
44   https://www.efsa.europa.eu/en/press/news/181120 

32 

 
 
 
 
                                                           
 
Table 4  Food & Feed related legislation with relevance to POPs 

Acronym 

Legal reference 

POPs regulated / POP reference  

Maximum levels 
for certain 
contaminants in 
foodstuffs 

Regulation (EC) No 
1881/2006 

- Dioxins (sum of polychlorinated dibenzo-para-dioxins (PCDDs) and 
polychlorinated dibenzofurans (PCDFs) and dioxin-like PCBs and non-
dioxin-like PCBs (indicator PCBs) 
- Benzo(a)pyrene and the sum of of benzo(a)pyrene, benz(a)anthracene, 
benzo(b)fluoranthene and chrysene as a marker of carcinogenic PAH in 
certain foodstuffs 

Regulation (EU) No 
252/201245 

Methods of sampling and analysis for the control of levels of dioxins and 
dioxin-like PCBs in food for regulatory purposes 

Pesticide Residues 
in Food 

Regulation (EC) No 
396/2005 

Setting Maximum Residue Levels for POP Pesticides in food products  

Undesirable 
substances in 
animal feed 

Directive 2002/32/EC 

Aldrin, Dieldrin, Camphechlor (toxaphene), Chlordane, DDT, Endosulfan, 
Endrin, Heptachlor, Hexachlorobenzene (HCB), Hexachlorocyclohexane 
(HCH, incl. Lindane), Dioxins (sum of polychlorinated dibenzo-para-dioxins 
(PCDDs) and polychlorinated dibenzofurans (PCDFs) and polychlorinated 
biphenyls (PCBs). 

Regulation (EC) No 
152/200946 

Methods of sampling and analysis for checking the levels of dioxins and 
dioxin-like PCBs in feed for regulatory purposes 

2.2.6. 

Information exchange between the Commission and the Member States on POPs in 
food and consumer products  

The information exchange among the Member States authorities and the Commission on the 
presence of POPs in food and consumer products is ensured by the rapid alert systems. There 
are currently two Union rapid alert systems and both are publicly available. The legal basis 
for their establishment are provided in Regulation (EC) No 178/2002, Directive 2001/95/EC 
and Regulation (EC) No 765/2008.  
The Rapid Alert System for Food and Feed (RASFF)47 was put in place to provide food and 
feed control authorities with an effective tool to exchange information about measures taken 
responding to serious risks detected in relation to food or feed. This exchange of information 
helps Member States to act more rapidly and in a coordinated manner in response to a health 
threat  caused  by  food  or  feed.  Notifications  cover  e.g.  the  contamination  of  food  and  feed 
with dioxins and dioxin-like PCBs or with PAHs.  
The  Rapid  Alert  System  for  non-food  dangerous  Products  (RAPEX)48  facilitates  the  rapid 
exchange of information between Member States and the Commission on measures taken to 
prevent or restrict the marketing or use of products (non-feed/non-food) posing a serious risk 
to the health and safety of consumers. Measures ordered by national authorities and measures 
taken voluntarily by producers and distributors are reported by RAPEX. 

45   OJ L 84, 23.3.2012, p. 1. 
46   OJ L 314, 1.12.2009, p. 66. 
47   http://ec.europa.eu/food/food/rapidalert/index_en.htm 
48   http://ec.europa.eu/consumers/safety/rapex/index_en.htm 

33 

 
 
 
 
                                                           
2.2.7.  Food monitoring within the European Union 

Routine  monitoring  of  food  and  feed  is  an  important  aspect  of  early  detection  of 
contamination  of  food  and  feed  by  POPs.  Under  Regulation  (EU)  2017/62549,  a  EU 
Reference  Laboratory  (EURL)  was  established  in  Freiburg,  Germany50  tasked  with 
developing analytical standards for dioxins and furans and PCBs within food and feed. EURL 
is  further  complemented  by  national  laboratories  within  the  Member  States,  who  have  the 
role of carrying out analysis for routine monitoring. In order to ensure comparability between 
EURL  and  national  reference  laboratories,  proficiency  tests  are  conducted  twice  annually. 
These tests involve the  use of the same sample, which is issued for analysis by all national 
laboratories. The results are then collated and assessed with any marked deviation from the 
average  result  requiring  process  amendment  and  further  testing  for  any  specific  national 
reference  laboratory.  Representatives  from  the  national  reference  laboratories  and  EURL 
meet twice annually to review and discuss any specific topics of interest for analysis. 

Under Regulation (EC) 396/2005, Member States are required to share results of their official 
controls  and  other  relevant  information  to  the  Commission.  EFSA  then  prepares  an  annual 
report  on  pesticide  residues  in  the  Union,  based  on  an  analysis  of  this  information  (see 
Section 2.1.5). 

2.2.8.  Emission monitoring legislation 
The  European  Pollutant  Release  and  Transfer  Register  (E-PRTR)  Regulation51  aims  to 
enhance  public  access  to  environmental  information.  The  E-PRTR  replaced  the  European 
Pollutant Emission Register (EPER) in 2007 and includes additional pollutants and economic 
activities.  E-PRTR  covers  91  pollutants,  and  65  economic  activities  which  have  to  be 
reported by regulated facilities above set reporting thresholds. The E-PRTR also implements 
stricter threshold levels for a number of pollutants (including POPs) (see also sections  3.3.1 
on emission monitoring and 2.3.9 on monitoring efforts of the Union) compared to previous 
EPER inventories.  

The E-PRTR also collects and collates information on the transfer and management of waste, 
which  includes  total  quantities  of  hazardous  waste  disaggregated  to  facility  level.  Further 
information  on specific  pollutants or concentrations of pollutants within hazardous waste is 
not a reporting requirement of the E-PRTR. 

The  European  Commission  launched  an  initative  early  in  2016  to  aid  access  to  monitoring 
data,  which  includes  information  on  POPs,  called  the  Information  Platform  for  Chemical 
Monitoring  data  (IPCheM)52.  The  platform  is  managed  by  the  Joint  Research  Centre  in 
collaboration  with  a  number  of  international  and  national  bodies.  It  draws  together 
monitoring data-sets in the form of ‘modules’, which are available publicly. IPCheM aims to 
support  a  more  coordinated  approach  for  collecting,  storing,  accessing  and  assessing  data 
related to the occurrence of chemicals and chemical mixtures, in relation to humans and the 

49   Regulation  (EU)  2017/625  of  the  European  Parliament  and  of  the  Council  of  15  March  2017  on  official 
controls  and  other  official  activities  performed  to  ensure  the  application  of  food  and  feed  law,  rules  on 
animal health and welfare, plant health and plant protection products (OJ L 95, 7.4.2017, p. 1) 

50   EURL laboratory: http://www.crl-dioxin-freiburg.eu/ 
51   OJ L 33, 4.2.2006, p. 1. 
52   http://ipchem.jrc.ec.europa.eu/#home-page 

34 

 
 
 
                                                           
environment. In the current version of the platform (IPCheM Version 5.0, March 2018), the 
portal was revisited and integrated with sections dedicated to end users and data providers.  

The  POPs  Regulation  furthermore  identifies  the  key  role  of  the  IPCheM  platform  for 
monitoring data. The POPs Regulation states that IPCheM will act as the main repository for 
POPs monitoring data developed and reported by Member States. It also states that the format 
of  data  and  software  to  be  used  when  developing  and  submitting  data  to  IPCheM  will  be 
agreed  between  the  Member  States  and  ECHA  to  help  maximise  efficiency  and 
comparability. 

2.2.9.  Public access to environmental information  
The  Directive  2003/4/EC  on  public  access  to  environmental  information53  guarantees  the 
right of access to environmental information held by or for public authorities. This right is for 
any  applicant  (private  individuals,  organisations,  etc.)  and  has  to  be  granted  without  any 
justification. With regards to  emissions, no request  can be  refused. Thus, this directive is  a 
powerful instrument to gather emission data, also on POPs, and can be used supplementary to 
the above mentioned on E-PRTR. 

2.3. 

Strategies, policies, and programmes 

2.3.1. 

Sustainable development  

In  2001,  the  European  Union  adopted  the  Sustainable  Development  Strategy  (EU  SDS)  to 
provide  a  long-term  vision  combining  economic  dynamism,  social  cohesion  and  high 
environmental standards54. In 2009, the European Commission Communication COM(2009) 
400 final55 reviewed the EU SDS to respond to the most recent economic and financial crisis 
from  the  perspective  of  a  long-term  sustainable  development  with  the  goal  to  further 
mainstream  the  EU  SDS  into  the  European  policy  fields.  From  the  seven  key  challenges 
proposed,  two  contain  POPs  related  issues  though  they  are  not  explicitly  mentioned,  i.e. 
sustainable consumption and manufacture as well as public health. 

The review reaffirms the position of the European Council about sustainable development as 
a  fundamental  Union  objective  under  the  Treaty  of  Lisbon.  This  follow-up  of  the  Lisbon 
Strategy was adopted in June 2010 by the heads and governments of the  Member States. In 
the Union, a key issue is to mainstream sustainable development thinking into various parts 
of the Europe 2020 Strategy. The EU SDS contributed to moving Europe out of the crisis and 
laying the foundations for a more sustainable future built on smart, sustainable and inclusive 
growth.  In  monitoring  progress  under  the  EU  SDS,  the  Commission  (EUROSTAT)  has 
produced  bi-annual  monitoring  reports  on  sustainable  development,  most  recently  in 
September 2015. 

Concerning  sustainable  development,  the  European  Union  had  a  key  role  during  the  UN 
negotiations  on  the  2030  Agenda  for  Sustainable  Development,  including  the  sustainable 

53   Directive  2003/4/EC  of  the  European  Parliament  and  the  Council  of  28  January  2003  on  public  access  to 

environmental information and repealing Council Directive 90/313/EEC, OJ L 41, 28.1.2003, p. 26 

54   See  communication  of  the  Commission  COM(2001)  264  final  and  the  conclusions  from  the  Gothenburg 

European Council.  

55   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0400:FIN:EN:PDF 

35 

 
 
 
 
                                                           
development  goals  (SDGs), which was  adopted by the General  Assembly on 25 September 
2015. There are 17 goals, which are to be achieved by 203056 and which include responsible 
consumption  and  manufacture;  good  health  and  well  being;  industry,  innovation  and 
infrastructure;  life  below  water  and  life  on  land.  The  new  European  Consensus  for 
Development  frames  the  implementation  of  the  2030  Agenda  in  partnership  with  all 
developing countries, taking due account of the framework provided by the Lisbon Treaty. In 
particular,  the  European  Union  and  its  Member  States  undertake  to  promote  resource 
efficiency  and  sustainable  consumption  and  manufacture,  including  the  sustainable 
management  of  chemicals  and  waste,  with  a  view  to  decouple  economic  growth  from 
environmental degradation and enable the transition to a circular economy. To help support 
these aims the POPs Regulation places a key focus on waste and sustainability. This includes 
increased traceability for all wastes that contain POPs and obligations on Member States to 
put  in  place  measures  to  support  the  implementation  of  the  Regulation  to  identify  POPs 
within waste and their final destination. The Regulation already includes low-POP thresholds 
in  its  Annex  IV  at  concentrations  equal  or  above  which  wastes  must  not  be  recycled 
(although pre-treatment operation to separate POP substances or to sort out POP-containing 
waste  are  permitted),  however,  the  new  requirements  for  traceability  will  also  cover  below 
threshold concentrations for POPs in waste. 

The  Stockholm  Convention  and  the  POPs  Regulation  are  intended  to  protect  human  health 
and  the  environment  from  those  substances  identified  as  POPs.  Part  of  this  work  includes 
aspects around innovation and sustainability to ensure that one POP substance is not replaced 
by another POP. In the Union this is further controlled by the REACH Regulation under the 
authorisation and restriction processes. 

2.3.2. 

Substitution of substances for intentional use 

A fundamental component of sustainable development and elimination of POPs from goods 
intentionally placed on the market is the substitution of POPs substances by alternatives that 
do  not  have  the  characteristsics  detailed  under  Annex  D  of  the  Stockholm  Convention. 
Within  European  Union  the  REACH  Regulation  aims  to  identify  substances  which  are 
persistent, bioaccumulating and/or toxic (in addition to those that are carcinogenic, mutagenic 
or  toxic  to  reproduction  or  substances  which  give  rise  to  an  equivalent  level  of  concern), 
termed  ‘substances  of  very  high  concern’  (SVHCs)57.  A  key  aim  of  the  REACH 
Authorisation  process  is  to  ensure  that  SVHCs  are  progresively  replaced  with  suitable 
alternatives.  Action  to  restrict  the  use  of  certain  PBT  substances  and  require  the  use  of 
alternatives, has also been taken through the REACH restriction process. Note that under the 
POPs Regulation, ECHA will take a central role in the development of scientific dossiers for 
new  candidate  POPs,  allowing  greater  synergies  between  REACH  and  POPs  on  the 
international stage. 
As  part  of  the  7th  EAP,  the  European  Commission  funded  a  pilot  project  to  look  at 
substitution with regard to brominated flame-retardants. The Enfiro project58 was intended to 
help  develop  alternatives to  brominated flame-retardants  (including substances identified as 

56   UN Sustainability goals, http://www.un.org/sustainabledevelopment/sustainable-development-goals/ 
57   ECHA,  substances  of  very  high  concern:  https://echa.europa.eu/substances-of-very-high-concern-

identification-explained 

58   Enfiro project: http://www.enfiro.eu/ and https://cordis.europa.eu/project/rcn/92068/factsheet/en 

36 

 
 
 
                                                           
POPs), as well documenting lessons learnt in order to help others successfully transition away 
from POPs based substances to safer alternatives.  

Alongside the Enfiro project the European Commission has aimed to promote collaboration 
in the field of substitution. The Executive Agency for Small and Medium Sized Enterprises 
(EASME)  (part of the programme to  assist  small and medium  sized enterprises (SMEs) for 
innovation (COSME)) has developed the Partnership Opportunities Database (POD) to help 
SMEs  within  the  Union  make  contact  with  partner  organisations  to  look  at  the  issue  of 
substitution,  which  includes  the  issue  of  substitution  for  SVHCs  substances  within 
commercial manufacture and goods. A number of other valuable resources are also open to 
industry  including  the  information  provided  by  the  ECHA  website59,  Subsport60,  and 
Medswitch61 amongst others. 

2.3.3.  Environment Action Programme 

The  Union’s  principal  strategy  for  environmental  policy  is  the  Environment  Action 
Programme (EAP), which is also relevant for this implementation plan.  

In  June  2013,  political  agreement  was  reached  on  the  seventh  Environment  Action 
Programme  (EAP),  the  7th  EAP.  The  7th  EAP  sets  out  the  priority  objectives  for  European 
Union  environment  policy  to  2020,  set  out  in  an  ambitious  longer-term  vision  for  an 
inclusive,  green  and  competitive  European  economy  that  safeguards  the  environment.  The 
programme identifies three key objectives: 

 

 

 

to protect, conserve and enhance the Union’s natural capital; 

to turn the Union into a resource-efficient, green, and competitive low-carbon economy; 

to safeguard the Union's citizens from environment-related pressures and risks to health 
and wellbeing.  

The priority areas can be found at: https://ec.europa.eu/environment/action-programme/. 
The  7th  EAP  sets  out  a  framework  to  support  the  achievement  of  nine  priority  objectives 
through  development  and  better  implementation  of  Union  environment  law,  state  of  the  art 
science,  securing  the  necessary  investments  in  support  of  environment  and  climate  change 
policy, and improving the way that environmental concerns and requirements are reflected in 
other  policies.  The  Programme  aims  to  boost  efforts  to  help  EU  cities  become  more 
sustainable, and improve the Union's capacity to  meet regional and global environment and 
climate challenges. 
Priority  objective  3  of  the  7th  EAP  "To  safeguard  the  Union’s  citizens  from  environment-
related  pressures  and  risks  to  health  and  well-being"  specifically  aims  to  tackle  hazardous 
chemicals, including nanomaterials, and chemicals that interfere with the endocrine system. 
This will in particular focus on the assessment of the combination effects of substances and 
the effective management through relevant Union legislation. 

59   ECHA website: https://echa.europa.eu/substitution-to-safer-chemicals 
60   Subsport website: http://www.subsport.eu/ 
61   MedSwitch website: http://www.switchmed.eu/en 

37 

 
 
 
                                                           
In  July  2018,  a  report  was  published  on  the  study  ‘Towards  an  8th  Environmental  Action 
Programme – Local  and regional dimension’62. The purpose of the study was to inform the 
Committee of the Regions (CoR) in the preparation of its own-initiative opinion on the EAP, 
focused specifically on a possible 8th EAP. The study aimed to support the opinion through 
an analysis of the local and regional dimensions of a potential 8th EAP. 

More recently in December 2019, the European Commission presented the  European Green 
Deal63, setting out a roadmap for making the Union’s economy fully sustainable. As part of 
the roadmap the Green Deal also sets ambitions for eliminating pollution, including an action 
plan for zero-pollution and a new chemicals strategy for a toxic-free environment. 

2.3.4.  The Thematic Strategy for Soil Protection 

The  Thematic  Strategy  for  Soil  Protection  was  adopted  by  the  European  Commission  in 
2006. The purpose of the Strategy is to “protect the soil while using it sustainably, through 
the prevention of further degradation, the preservation of soil function and the restoration of 
degraded soils”. The four pillars of the Strategy are awareness raising, research, integration, 
and legislation.   

The Strategy has resulted in an increased focus on soil issues, with this becoming the focus of 
many research projects. To date these have been primarily on issues such as soil degradation, 
impacts  of  agriculture,  etc.,  rather  than  on  POPs64.  However,  with  soil  protection  and 
remediation of soil contamination falling under the Strategy, there is the potential for this to 
be  the  subject  of  future  research,  in  particular  on  the  consolidated  harmonisation  of  soil 
monitoring for POPs and other contaminants. Indeed, the POPs Regulation now gives much 
greater  onus  on  contaminated  sites,  encouraging  Member  States  to  include  details  of 
identified  sites  and  work  to  identify  contaminated  sites  within  both  national  reports  and 
national implementation plans. 

Strategies for control of pesticides and chemicals 

2.3.5. 
The Chemicals Strategy for Sustainability65, which was adopted in October 2020, strives for a 
toxic-free environment, where chemicals are produced and used in a way that maximises their 
contribution  to  society  including  achieving  the  green  and  digital  transition,  while  avoiding 
harm  to  the  planet  and  to  current  and  future  generations.  It  envisages  the  EU  industry  as  a 
globally competitive player in the production and use of safe and sustainable chemicals. The 
strategy  proposes  a  clear  roadmap  and  timeline  for  the  transformation  of  industry  with  the 
aim of attracting investment into safe and sustainable products and production methods. 

This strategy sets a pathway towards implementation of this vision through actions to support 
innovation for safe and sustainable chemicals, strengthen the protection of human health and 

62   https://publications.europa.eu/en/publication-detail/-/publication/f106cce3-9535-11e8-8bc1-

01aa75ed71a1/language-en/format-PDF 

63   https://ec.europa.eu/info/files/communication-european-green-deal_en 
64   European  Commission  2012  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European Economic and Social Committee and the Committee of the Regions  – the implementation of the 
Soil Thematic Strategy and ongoing activities. COM (2012) 46 final. Dated 13.2.2012 

65   COM(2020) 667 final 

38 

 
 
 
 
                                                           
the  environment,  simplify  and  strengthen  the  legal  framework  on  chemicals,  build  a 
comprehensive  knowledge  base  to  support  evidence-based  policy  making,  and  set  the 
example of sound management of chemicals globally. 

The  Union  Strategy  for  Dioxins,  Furans  and  Polychlorinated  Biphenyls  adopted  in  2001 
(COM(2001)  593)66  has  the  goal  to  assess  the  current  state  of  the  environment  and  the 
ecosystem and to reduce exposure from dioxins and PCBs to humans and the environment. In 
July  2007,  the  Communication  of  the  Commission  COM(2007)  396  final67  provided  the 
second  progress  report  on  the  main  achievements  with  regard  to  the  implementation  of  the 
strategy  during  the  period  between  2004  and  2006,  elucidating  the  several  environmental 
measures  on  POPs  which  have  been  adopted  in  2004  and  the  new  maximum  levels  for 
contaminants in food and feed, which have been updated in 2006.  

In October 2010, the Commission adopted the third progress report on the dioxin strategy for 
the  period  2007  to  2009  (COM(2010)  562  final)68.  The  report  concluded  that  the  overall 
objective  of  the  strategy,  i.e.  to  develop  an  integrated  approach  in  order  to  reduce  the 
presence  of  dioxins,  furans  and  PCBs  in  the  environment  as  well  as  in  feed  and  food,  has 
been achieved to a large extent, bearing in mind the reduction of industrial emissions of these 
pollutants  by  about  80%  over  the  past  two  decades.  The  report  further  concluded  that 
additional sources should be targeted by national or local measures.  

In December 2013, the Commission put forward Recommendation 2013/711/EU69 for further 
reduction  of  dioxins  and  furans,  and  dioxin-like  PCBs  within  food  groups,  as  amended  by 
Commission  Recommendation  2014/663/EU  of  11  September  2014.  This  Recommendation 
called  for  increased  monitoring  of  these  substances  within  free  range  eggs,  organic  eggs, 
lamb and sheep livers and sea food (particularly crabs). The recommendation also  indicates 
acceptable levels for the presence of dioxins and furans, and dioxin-like PCBs, within food. 

Further  progress  is  expected  within  the  framework  of  the  Union  Implementation  Plan  on 
Persistent Organic Pollutants and the relevant NIPs elaborated by Member States.  

2.3.6.  OpenFoodTox database for pesticide residues in food 

Since the creation of EFSA in 2002, the authority has completed food-based risk assessments 
for more than 4,000 substances. For individual substances, a summary of human health (and 
depending on relevant legislation animal health and ecological hazard assessments) data and 
conclusions  have  been  collated  and  summarised  within  a  publicly  available  database  called 
‘OpenFoodTox’.  This  database  provides  high  level  summarised  data  on  a  substance-by-
substance basis including details of outcomes for specific toxicological endpoints, and hazard 
reference values that have been developed and then adopted by different expert committees. 
This includes data on the safe limits for pesticide residues in food covering a number of the 
POPs covered by the POPs Regulation. 

66   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52010DC0593:EN:NOT  
67   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0396:FIN:EN:PDF 
68   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0562:FIN:EN:PDF 
69   http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013H0711 

39 

 
 
 
 
                                                           
2.3.7.  Environment and Health Action Plan 

The Environment and Health Action Plan (EHAP) was launched in June 2004 to coordinate 
health, environment and research areas and to develop a system for integrated information on 
environment  and  health  and  to  assess  the  environmental  impact  on  human  health  more 
efficiently.  In  June  2007,  a  mid-term  report  was  published  in  a  Communication  of  the 
Commission (COM(2007) 314 final70). It highlighted the growing links between environment 
policy and health policy. It showed, for example, that an important development in relation to 
the Strategy on Dioxins  and PCBs was the adoption  of  Regulation (EC)  No 850/2004. The 
progress  report  on  the  implementation  of  the  EHAP  of  March  2010  (SEC(2010)  387)71 
presented the progress  of activities  after the mid-term  review, assessed the results achieved 
since 2004 and suggested the follow-up for the Action Plan post 2010.  

2.3.8.  Multilateral Environmental Agreements (MEAs) 

Many  environmental  problems  transcend  national  boundaries  and  can  only  be  efficiently 
handled through international co-operation. The European Union is a party in more than 40 
international environmental agreements72, among them the Stockholm Convention, the Basel 
Convention, the Rotterdam Convention and the Minamata Convention. 

Within the Strategic Approach to International Chemicals Management (SAICM), a number 
of  useful  documents  that  address  the  question  of  how  to  improve  communication  on 
chemicals  in  products  and  articles  including  POPs  have  been  developed.  The  Chemicals  in 
Products Programme (CiP Programme) was initiated by the Union in 2009 and welcomed by 
the SAICM Governing body at ICCM4, in September 2015. The finalised Programme and the 
accompanying guidance can be found on UNEP's web page73. 

2.3.9.  Monitoring efforts of the Union 

Monitoring efforts in the Union cover monitoring of emission loads into the environment and 
monitoring of environmental concentrations. 

The European Monitoring  and Evaluation  Programme (EMEP) is  a scientifically  based and 
policy driven programme for international cooperation under the Convention on Long-range 
Transboundary  Air  Pollution  (CLRTAP).  The  EMEP  provides  scientific  information  about 
emission inventories and emission projections, atmospheric monitoring and modelling as well 
as  an  integrated  assessment  to  help  solve  transboundary  air  pollution  problems.  This  set  of 
information  is  an  important  basis  for  developing  further  emission  control  strategies  and 
implementing the Convention and its Protocols. 

Several  measures  relating  to  the  monitoring  of  POPs’  emissions  have  been  taken  by  the 
Member States in order to identify and characterize sources and releases of these substances. 
Many  of  these  measures  are  included  in  the  NIPs  and  have  benefited  from  the  numerous 
national  policy  frameworks.  Besides  the  national  emission  inventories  for  the  release  of 

70   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0314:FIN:EN:PDF  
71   http://register.consilium.europa.eu/pdf/en/10/st08/st08201.en10.pdf 
72   http://ec.europa.eu/environment/international_issues/pdf/agreements_en.pdf 
73   https://www.unenvironment.org/explore-topics/chemicals-waste/what-we-do/emerging-issues/chemicals-

products 

40 

 
 
 
 
                                                           
unintentionally produced POPs into the air, water and soil, the EMEP emission inventory and 
the  E-PRTR  database  are  further  available  inventories  of  releases.  Article  4  of  the  Water 
Framework Directive (Directive 2000/60/EC) also requires the development of inventories of 
discharges  and  losses  for  priority  and  priority  hazardous  substances  (which  includes  some 
POPs).  This  information  is  intended  to  inform  planning  and  reporting  for  river  basin 
management plans (RBMPs), with the first cycle covering the 2009-2015 period. The fourth 
implementation  report  (2015)74  included  a  review  of  progress  in  the  implementation  of  the 
Programmes of Measures planned by Member States in their RBMPs. A Commission report 
on the assment of Member States’ second RBMPs is ongoing and is expected later in 2019. 
The EEA report on ‘European waters – Assessment of status and pressures 2018’75, indicated 
that  inputs  from  urban  wastewater  treatment  plants  lead  to  contamination  of  over  13,000 
water  bodies  with  polyaromatic  hydrocarbons  (PAHs),  mercury,  cadmium,  lead,  and  nickel 
being  the  dominated  substances  causing  failure  to  achieve  good  chemical  status.  PAHs  in 
particularly have been linked to atmospheric deposition from combustion of fuels, rather than 
direct release to water. 

As  regards  the  monitoring  of  environmental  concentrations,  there  are  several  regional 
monitoring programmes established as part of regional conventions or initiatives that covers 
part  of  the  Union  and  includes  some  of  the  POPs.  The  Arctic  Monitoring  and  Assessment 
Programme  (AMAP)  analyses  fluxes,  pathways  and  environmental  levels  of  POPs  and 
presents  an  assessment  of  the  Arctic  environment  contamination76.  Other  examples  are  the 
Trilateral  Monitoring  and  Assessment  Programme  of  the  Waddensea  (TMAP),  the 
Monitoring  Network  in  the  Alpine  Region  for  Persistent  and  other  Organic  Pollutants 
(MONARPOP) as well as sea conventions (such as e.g. HELCOM, OSPAR and MED POL). 

The  mission  of  the  European  Environment  Agency  (EEA)  is  to  provide  sound  and 
independent  information  on  the  environment,  with  the  goal  to  ensure  that  decision-makers 
and the general public are kept informed about European environmental data, knowledge and 
assessments. The Agency collects data on POP emissions and where available data on POP 
concentrations in the environment and analyses their trends77,78. Some of the Agency’s data 
on POPs originate from the monitoring of Priority Substances in water bodies conducted by 
Member States under the Water Framework Directive.  

As  mentioned  in  Section  2.1.5,  for  POPs  present  in  pesticide  residues,  EFSA  provides  an 
annual monitoring report, based on an analysis of information provided by Member States.  

2.4. 

Financial instruments 

Using different  funding  instruments,  the  Union  provides a significant  amount  of funding to 
environmental  projects  and  programmes,  both  within  the  EU  as  well  as  in  neighbouring 
countries  and  in  developing  countries.  There  are  several  financial  instruments  and 
programmes that can be relevant also for POP related projects.  

74   http://ec.europa.eu/environment/water/water-framework/impl_reports.htm 
75   EEA Report No 7/2018: https://www.eea.europa.eu/ds_resolveuid/2c13c637dfe84d37b8a9d39e2b1fb30f  
76   http://www.eea.europa.eu/publications/92-9167-058-8/page004.html  
77   https://www.eea.europa.eu/data-and-maps/indicators/eea32-persistent-organic-pollutant-pop-emissions-

1/assessment-10 

78   http://www.eea.europa.eu/publications/NYM2/page005.html 

41 

 
 
 
                                                           
2.4.1.  Funding instruments for the Union 

The  LIFE  programme  supports  environmental  and  nature  conservation  projects  within  the 
Union to protect the environment and limit negative anthropogenic effects. The programme 
was  established  in  1992  and  operated  through  individual  phases,  each  one  running  for  4 
years.  

The phase between 2007 and 2013 was called LIFE+ and had a budget of €2.1 billion, while 
funding  was  provided  via  three  key  areas:  LIFE+  Nature  &  Biodiversity,  LIFE+ 
Environmental  Policy  &  Governance,  and  LIFE+  Information  &  Communication,  where  at 
least 78 percent of the budgetary resources was used for action grants to projects.  
LIFE+  projects  promoted  synergies  between  different  priorities  under  the  6th  Environment 
Action  Programme.  Two  projects  in  relation  with  POPs  were  funded  by  the  LIFE+ 
programme:  one  to  evaluate  the  extent  of  exposure  of  the  general  population,  especially 
women of reproductive age79, and the second to evaluate emission exposure of PAHs in the 
population80. The LIFE+ programme was designed to complement other funding programmes 
for the environment which are described as follows.   

LIFE programme has also supported investigations into the implementation of bioremediation 
techniques  for  the  mitigating  of  soil  contamination,  with  contaminants  including  PCBs, 
pesticides and PAHs (LIFE97 ENV/IT/000024 and LIFE03 ENV/IT/000321).81 

There  are  numerous  other  funds  of  the  Union  with  different  target  groups  that  do  not 
specifically  refer  to  POPs,  but  which  support  the  implementation  of  the  environmental 
legislation  or  the  supply  of  technical  solutions  (the  Competitiveness  and  Innovation 
Framework Programme82, for example, supports small and medium-sized enterprises (SMEs) 
innovation activities (including eco-innovation), while the NGO operating grants83 inter alia 
promote  the  active  participation  of  NGOs  in  the  development  and  implementation  of 
environmental policy).  
On  the  20th  of  December  2013  the  LIFE  2014-2020  Regulation  (EU)  No  1293/2013  was 
published in the Official Journal (L 347, p. 185). The Regulation establishes the Environment 
and  Climate  Action  sub-programmes  of  the  LIFE  Programme  for  the  next  funding  period, 
2014–2020. The budget for the period is set at €3.4 billion. On the 19th of March 2014, the 
LIFE  multiannual  work  programme  for  2014-2017  was  adopted  by  Commission 
Implementing Decision (2014/203/EU). 

The  LIFE  multiannual  work  programme  for  2014-2017  set  the  framework  for  the  first  four 
years  for  the  management  of  the  LIFE  Programme  2014-2020.  It  contains  an  indicative 
budget,  explains  the  selection  methodology  for  projects  and  for  operating  grants  and 
establishes outcome indicators for the two LIFE sub-programmes – for Environment and for 
Climate Action. The total budget for funding projects during the period covered amounts to 

79   http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=3433 
80   http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=3756 
81   European Commission 2014 LIFE and Soil Protection 
82   https://www.welcomeurope.com/european-funds/cip-competitiveness-innovation-framework-programme-

572+472.html#tab=onglet_details  

83   http://ec.europa.eu/environment/ngos/index_en.htm 

42 

 
 
 
                                                           
€1.1  billion  under  the  sub-programme  for  Environment  and  €0.4  billion  under  the  sub-
programme for Climate Action. 

The  European  Commission  proposes  to  raise  the  budget  of  the  LIFE  programme  to  €5.45 
billion  between  2021  and  2027.  The  new  LIFE  programme  would  have  four  sub-
programmes:  nature  and  biodiversity;  circular  economy  and  quality  of  life;  climate  change 
mitigation and adaptation; and clean energy transition. 

With  regards  to  soil  contamination,  the  Cohesion  Funds  have  provided  support  to  the 
regeneration  of  brownfield  sites  across  the  Union.  In  the  period  2007-2013,  around  €3.1 
billion  of  funding  was  allocated  under  the  Cohesion  Policy,  with  Hungary,  Czechia  and 
Germany allocated the most funding. Note that it is not known how much of this related to 
soil  contamination  by  POPs.84  More  recently  a  range  of  additional  projects  have  been 
launched to tackle the issue of soil contamination from POPs, including: 

  LindaNET85  which  is  a  collaborative  effort  amongst  regions  to  work  towards  the 

improvement of sites contaminated by HCH and Lindane.  

  DISCOVERED86 which is project launched in the Aragon region of Spain to tackle 
lindane  pollution.  The  project  aims  to  develop  a  prototype  pollution  mitigation 
system based on in-situ chemical oxidation with alkaline activation to restore water 
quality. 

  The  JRC  also  reported  in  2018  on  progress  with  indicators  for  management  of 

contaminated sites in the Union87. 

2.4.2.  Funding for neighbouring and partner countries 

The  European  Neighbourhood  Policy  (ENP)  was  initially  launched  in  2003  and  fully 
developed  in  2004,  as  a  foreign  relations  instrument  to  build  ties  with  countries  to  the  east 
and south of the Union. The main objective of the ENP is ‘avoiding the emergence of new 
dividing lines between the enlarged Union and our neighbours and instead strengthening the 
prosperity,  stability  and  security  of  all  concerned’.88  The  ENP  applies  to  the  Union’s 
immediate  neighbours  by  land  or  sea,  including,  the  16  ENP  countries  being  Algeria, 
Armenia,  Azerbaijan,  Belarus,  Egypt,  Georgia,  Israel,  Jordan,  Lebanon,  Libya,  Moldova, 
Morocco, Palestine, Syria, Tunisia and Ukraine. The ENP was reviewed in November 2015, 
in parallel with the the work conducted on the Union's Global Strategy.  

The  central  element  of  the  inititive  are  the  bilateral  ENP  Action  Plans  agreed  between  the 
Union  and  each  partner  country.  Aspects  relating  to  environment,  climate  change,  energy, 
transport  and  sustainable  development  are  amongst  the  topics  covered  by  the  ENP  Action 
Plans.  Through 
that  many 
environmental  problems  go  beyond  the  borders  of  individual  countries  and  the  Union, 

the  ENP,  Union  environmental  policy  acknowledges 

84   European  Commission  2012  Report  from  the  Commission  to  the  European  Parliament,  The  Council,  The 
European Economic and Social Committee and the Committee of the Regions  – the implementation of the 
Soil Thematic Strategy and ongoing activities. COM (2012) 46 final. Dated 13.2.2012 

85   https://www.interregeurope.eu/lindanet/ 
86 https://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=4633 
87   https://esdac.jrc.ec.europa.eu/public_path/shared_folder/doc_pub/EUR29124.pdf 
88   http://ec.europa.eu/environment/archives/enlarg/med/pdf/enp_flyer_en.pdf 

43 

 
 
 
                                                           
specifically  noting  the  importance  of  acid  rain,  biodiversity,  desertification,  hazardous 
wastes, oil spills, persistent organic pollutants, the protection of the great rivers and seas as 
well as tropical forests.  

The  ENP’s  financial  arm  is  the  European  Neighbourhood  Instrument  (ENI)  and  is  worth 
€15.4  billion  from  2014  –  2020.  The  ENI  functions  through  10  priority  areas  including 
Climate Change Adaption and Management of Natural Resources. The ENI provides the bulk 
of Union funding to the 16 ENP partner countries mentiond above, the vast majority of the 
ENI funding being used for bilateral cooperation.  

The  ENP  follows  on  from  the  previous  programme,  the  European  Neighbourhood  and 
Partnership Instrument (ENPI), which targeted sustainable development and approximation to 
EU  policies  and  standards  –including  the  implementation  of  the  POP  Regulation–  in 
neighbouring  third  Countries  as  well  as  through  a  strategic  partnership  with  the  Russian 
Federation.  The ENPI operated for the period 2007-2013, with nearly €12 billion in Union 
funding  available  to  support  these  partners’  reforms.  The  ENPI  had  15  cross-border 
cooperation (CBC) programmes which receive a funding of €1.2 billion for the same period. 
The Instrument for Pre-Accession Assistance (IPA) which replaces several programmes (e.g. 
the PHARE programme) and financial instruments for candidate countries (Iceland, Turkey, 
Serbia, Montenegro and the former Yugoslav Republic of Macedonia) or potential candidates 
(Albania, Bosnia and Herzegovina, Kosovo) also provides nearly €12 billion.  

2.4.3.  Multilateral programmes funded by the Union  

The promotion of measures to address worldwide environmental problems is a key objective 
of the Union policy. The Commission thus provides funding to international and multilateral 
programmes. 

The current  instrument  is  the  thematic programme on Global  Public Goods and Challenges 
(GPGC),  which  covers  the  period  2014-2020  and  replaces  previous  sectoral  programmes 
funded  by  the  Union,  including  the  Environment  and  Sustainable  Management  of  Natural 
Resources including Energy Thematic Programme (ENRTP). Some examples funded within 
the ENRTP:  

  Support  to  the  Secretariat  of  Stockholm  Convention  of  about  €1,000,000  in  the 
period 2007 to  2011 to  support Parties to  implement  their obligations  under the 
Stockholm Convention, to further elaborate the dioxin and furan toolkit to better 
adapt the toolkit guidance to the needs of developing countries and to support the 
gathering of monitoring data on POPs. 

  Support  to  the  Secretariat  of  Stockholm  Convention  of  €1,450,000  to  support 
their  2012-2013  programme  of  work,  including  the  technical  assistance 
programme,  the  global  monitoring  plan  for  effectiveness  evaluation,  the 
programme on unintentionally produced POPs, the programme on endosulfan, the 
programme  on  new  POPS  and  candidate  POPs  and  support  for  participation  of 
developing countries at COP-6. 

  Further  ENRTP  support  includes  €4.5  million  to  FAO  for  the  cleaning  up  of 

obsolete pesticides in the Africa Stockpiles Programme. 

  Through  ENRTP  –  phase  III  (2012-2017)  of  the  global  capability  development 
under the Life Cycle Initiative was supported with €4 million, which focussed on 

44 

 
 
 
promotion and training of life-cycle analysis approaches to improve sustainability 
and avoid regrettable substitution for POPs. 

The GPGC Environment and Climate envelope provided financial support to the Secretariat 
of the Basel, Rotterdam and Stockholm Conventions to implement the programme of work as 
agreed  by  the  Conferences  of  the  Parties,  which  also  included  the  provision  of  technical 
assistance to developing countries and countries with economies in transition: 

  Support  to  the  Secretariat  of  Stockholm  Convention  of  €2,000,000  to  support  their 
2014-2015,  2016-2017  and  2018-2019  programmes  of  work,  including  the  global 
monitoring  plan,  the  programme  on  unintentionally  produced  POPs,  the  support  of 
developing countries to  establish their POPs inventories and to  draw-up and review 
national  implementation  plans,  and  the  development  and  revision  of  guidance, 
including on the BAT/BEP toolkit and on reporting. 

Further support was provided to the following initiatives: 

 

 

the  Quick  Start  Programme  Trust  Fund  of  the  Strategic  Approach  to  International 
Chemicals  Management  (SAICM)89,  which  aims  at  supporting 
the  sound 
management of chemical and waste in order to minimise significant adverse impacts 
on the environmnet and human health; 

the Special Programme to support the institutional strengthening at the national level 
for  the  implementation  of  the  Basel,  Rotterdam  and  Stockholm  Conventions,  the 
Minamata  Convention  and  the  Strategic  Approach  to  International  Chemicals 
Management (€17 million). 

 

the promotion and further development of the IOMC toolbox (phase III - €2 million), 
including training of users in developing countries. 

  The  programme  for  the  period  2018-2020  of  the  GPGC  Environment  and  Climate 
envelope will continue support to combat pollution and promote sound management 
of chemicals ands waste through the Switch to Green Flagship Initiative.  

2.5. 

Research and Development and the Framework Programmes 

Research and development is essential for the support of policies such as, inter alia, consumer 
protection or the protection of the environment. The Research Framework Programme (FP) is 
the main instrument for funding research and development in the Union.  

The Seventh Framework Programme (FP7), ran for the period 2007-2013 with a total budget 
of over €50.5 billion from which €1.9 billion was attributed to the relevant thematic areas of 
‘Environment (including Climate Change)’, €1.9 billion to ‘Food, Agriculture and Fisheries, 
and Biotechnology’ and €6.1 billion to ‘Health’. These thematic areas particularly supported 
research  on  projects  related  to  POPs  (see  Table  13).  The  programmes  ‘Ideas’  (€7.5  billion 
over 7 years) and ‘People’ (€4.7 billion over 7 years) of the FP7 also funded some projects 

89   http://www.saicm.org/Implementation/QuickStartProgramme/tabid/5523/language/en-US/Default.aspx 

45 

 
 
 
 
 
                                                           
with  reference  to  POPs.  The  thematic  areas  and  programmes  are  indicated  in  Table  13  in 
section 8 of this document. The primary aim of funding the 'Food, Agriculture and Fisheries, 
and Biotechnology' research theme under the FP7 was to build a European Knowledge Based 
Bio-Economy, KBBE being the abbreviation for this thematic area. 

Thirtyseven projects with POP relevance have been funded under the FP7 receiving around 
€143  million  from  the  Union.  Projects  with  POPs  reference  have  especially  been  funded 
within  the  framework  of  the  thematic  area  ‘Environment’  –  22  projects–  as  it  included  the 
environment  and  health  sub-activity.  This  sub-activity  funded  research  to  support  Union 
policy initiatives such as the European Environment and Health Action Plan 2004-2010, the 
Community Strategy for Endocrine Disrupters, and the Stockholm Convention on persistent 
organic  pollutants  (POPs).  The  projects  funded  deal  with,  inter  alia,  harmonising  human 
(bio)monitoring  and  improving  the  understanding  of  environmental  and  human  exposure  to 
chemicals such as PCBs and perfluorinated compounds90 and their potential health effects.  

Within  the  thematic  strategy  ‘Food,  Agriculture  and  Fisheries,  and  Biotechnology’  / 
‘Knowledge Based Bio-Economy’, nine large POP-projects were funded, focussing on food 
safety  aspects  such  as  sampling  strategies  and  detection  methods  for  specific  foods  and  on 
quality  and  safety  assurance  of  feed.  Furthermore  under  this  thematic  area,  projects  are 
funded seeking alternative solutions to chemical pesticides.  

In  2007,  the  Commission  also  saw  the  need  to  examine  development  of  affordable 
alternatives to DDT to control malaria, e.g. by exploiting available biological knowledge on 
the mosquito vector. On the topic of “affordable alternatives for DDT”, no research  project 
was granted within FP7. As for identification of substances that can be used as alternatives to 
POP,  there  is  one  research  project  on  substitution  options  for  specific  brominated  flame 
retardant.  

Horizon 2020 has taken over from FP7 with a new body of research for the period between 
2014 – 2020. The programme has an overall budget of about €80 billion euros. Key overall 
themes for Horizon 2020 include: 

 

the programme to  assist small and medium sized enterprises (SMEs) for innovation 
(COSME); 

  a programme relating to consumer protection and products; 

 

the third health programme; 

  a research programme for coal and steel; 

 

the justice programme relating to civil and commercial matters; and 

  a programme for the promotion of agriculture products. 

Research  relating  to  POPs  will  feature  in  a  number  of  these  thematic  areas  with  key  work 
looking  at  monitoring  of  POPs  in  the  natural  environment91,  work  to  assist  with  the  de-

90   https://ec.europa.eu/environment/integration/research/pdf/fp7_catalogue.pdf   
91   http://ec.europa.eu/environment/enlarg/med/horizon_2020_en.htm 

46 

 
 
                                                           
pollution of the mediterranean92, and the management of ‘POPs’ substances within consumer 
supply chains. 

2.5.1.  European Research Institutions including the JRC 

The Joint Research Centre (JRC) has been established as part of the European Commission in 
1958. As the Commission's in-house science service, the Joint Research Centre's mission is to 
provide  Union  policies  with  independent,  evidence-based  scientific  and  technical  support 
throughout  the  whole  policy  cycle.  Working  in  close  cooperation  with  policy  Directorates-
General,  the  JRC  addresses  key  societal  challenges  while  stimulating  innovation  through 
developing  new  methods,  tools  and  standards,  and  sharing  its  know-how  with  the  Member 
States,  the  scientific  community  and  international  partners.  The  Horizon  2020  budget 
dedicated to the JRC is around €1.9 billion (about 53% of the JRC budget), of which around 
€210  million  is  dedicated  to  operational  research  activities  conducted  through  through  its 
seven  research  institutes,  specialised  in  different  areas  of  research93.  Some  of  these  have 
relevant projects with POPs.  

The JRC, for example, develops and provides testing methods and reference material also for 
POP  substances.  The  JRC  performs  monitoring  of  POPs,  supports  the  development  and 
standardization  of  analytical  protocols  in  the  frame  of  the  European  Committee  for 
Standardization and within the Water Framework Directive and supports the implementation 
of  the  Stockholm  Convention  at  the  Union  level.  The  JRC  provides  access  to  several  web-
based  information  tools,  for  example,  EASIS  (Endocrine  Active  Substances  Information 
System)  which  includes  results  from  different  scientific  studies  on  chemicals  related  to 
endocrine  activity  (https://easis.jrc.ec.europa.eu/)  as  well  as  IPCheM  (Information  Platform 
for  Chemical  Monitoring),  which  provides  access  to  chemical  occurrence  data  in  various 
indoor  air  and  consumer  products) 
media  (e.g.  environment,  humans,  food/feed, 
(https://ipchem.jrc.ec.europa.eu/),  and  will  act  as  the  main  repository  for  POPs  monitoring 
data under the recast of the POPs regulation (EU 2019/1021). 

The  JRC  also  elaborates  the  Best  Available  Techniques  Reference  Documents  (BREFs) 
based on the IPPC Directive initially, and now based on the IED. BREFs have been created 
covering a wide range of industry sectors94,95; with regular work to provide updates over time 
where  needed96. Under  the  IED,  the  BAT  conclusions  of  the  BREF  are  adopted  as 
Commission  Implementing  Decisions97.  Several  of  the  BREFs  also  contain  information  on 

92   http://ec.europa.eu/environment/enlarg/med/pdf/horizon2020/mid-term%20review%20EN.pdf 
93 

http://www.europarl.europa.eu/RegData/etudes/IDAN/2015/571312/EPRS_IDA%282015%29571312_EN.p
df 

from 

the  website  of 

the  European 

IPPC  Bureau, 

94   The  BREFs 

can  be  downloaded 
https://eippcb.jrc.ec.europa.eu/reference  

95   An additional document, the Management of Tailings and Waste-Rock in Mining Activities BREF, was 
developed under the framework of the Commission's Communication COM(2000) 664 on the 'Safe 
Operation of Mining Activities'. 

96  Further  detail  on 

the  current  BREFs  and  ongoing  update  work  can  be 

found  here: 

https://eippcb.jrc.ec.europa.eu/reference. 

97   Commission  Implementing  Decision  2012/119/EU  of  10  February  2012  laying  down  rules  concerning 
guidance on the collection of data and on the drawing up of BAT reference documents and on their quality 

47 

 
 
 
                                                           
 
POPs  and  related  BAT  as  well  as  the  corresponding  emission  levels  associated  with  the 
application of BAT (BAT-AELs). 

Furthermore,  the  JRC  is  involved  in  several  research  activities  that  include  monitoring 
programmes  and  case  studies  for  inland  and  marine  waters,  ambient  air,  soil  including 
contaminated  sites,  sediments,  sewage  sludge,  compost,  food  and  biota,  as  well  as  multi-
media modelling of POPs.  

2.5.2. 

Supporting co-operation, co-ordination and networking  

Modern  research  in  a  global  environment  necessitates  co-operation  at  different  levels.  The 
fragmentation of the Union's efforts cannot be overcome without determined actions. Taking 
up this  challenge, the  European Commission,  Member States and the European Parliament, 
the scientific community and industry have created the "European Research Area" (ERA98), 
this provides a framework for researchers and technologists to move freely within the Union, 
including  promoting  open  access  to  results  and  gender  equality.  As  of  2017,  the  ERA 
included a database of research positions covering 40,000 opportunities per annum and 250 
service  centres  to  help  facilitate  researchers  resettling  to  new  locations  within  the  Union. 
Funding  under  horizon  2020  (€6  billion)  and  the  European  Research  Council  (€13  billion) 
have been provided to bring together the combined scientific knowledge across the Union as 
part of the European Research Area. 

This effort was launched by a European Commission Green Paper in 2007 followed in 2008, 
by  a  new  political  partnership  between  the  Member  States  and  the  Commission  called  the 
"Ljubljana Process", which aimed to overcome fragmentation and to build a strong ERA. 

Additionally as part of the Horizon 2020 planning, the Union created The European Network 
for  Observing  our  Changing  Planet  (ERA-PLANET)  in  January  2016,  which  includes  a 
network of 38 partner organisations from 14 Member States, one European Economic Area 
country and one associated country aiming at strengthening the European Research Area in 
the domain of Earth Observation in coherence with the European participation to Group on 
Earth Observation (GEO) and the Copernicus. The partners will reinforce the interface with 
user communities, whose needs the Global Earth Observation System of Systems (GEOSS) 
intends  to  address.  It  will  provide  more  accurate,  comprehensive  and  authoritative 
information to policy and decision-makers in four distinct topics of the ERA-PLANET that 
reflect the key societal benefit areas reflected in both GEO and Copernicus: Smart cities and 
Resilient societies; Resource efficiency and Environmental management; Global changes and 
Environmental treaties; Polar areas and Natural resources99. 

The  domains  will  address,  among  others:  chemical  pollution  by  persistent  contaminants, 
assessment  of  global  change  patterns,  impact  of  long-range  transport  of  air  pollutants  and 
their atmospheric deposition, challenging issues for cities and society such as urban growth, 
air  quality,  health  and  contaminated  sites  as  well  as  resource  efficiency  and  depletion.  The 
current  ERA-Planet  project  strives to strengthen  the European leadership  within the current 
GEO 2015-2025 Work Plan. 

assurance referred to in Directive 2010/75/EU of the European Parliament and of the Council on industrial 
emissions, OJ L 63/1, 2.3.2012 

98   https://ec.europa.eu/info/research-and-innovation/strategy/era_en  
99   ERA-Planet: http://eraplanet.meteo.noa.gr 

48 

 
 
 
                                                                                                                                                                                     
2.5.3.  Future research and innovation 

The ongoing discussion on the fate of newly listed POPs present in articles of everyday use 
and  on  the  associated  challenges  with  recycling  and  disposal  of  such  articles  will  certainly 
result in identification of additional research needs. Such research could also make use of the 
documents that address  how industry can improve information  on chemicals  in  articles that 
have been developed under the Chemicals in Products Project (CiP) (see section 2.3.8). 

Horizon  2020  and  in  particular  Societal  Challenge  1  “Health,  Demographic  Change  and 
Wellbeing”,  Societal  Challenge  2  “Food  Security,  Sustainable  Agriculture  and  Forestry, 
Marine, Maritime and Inland Water Research and the Bioeconomy” and Societal Challenge 5 
“Climate  Action,  Environment,  Resource  Efficiency  and  Raw  Materials”  provide  new 
opportunities  for  Research  and  Innovation  to  develop  new  solutions  to  prevent  and  detect 
POPs  contamination  and  toxicity  to  the  environment  and  human  health,  including  marine 
wastes, pesticides in agriculture and food products. 

As part of Horizon 2020, the European Human Biomonitoring Initiative (EHBMI) has been 
created.  This  is  a  new  medium  term  European  initiative  whose  full  implementation  under 
Horizon  2020  takes  place  between  2016-2021.  The  objective  is  to  create  a  European  joint 
programme  for  monitoring  and  scientific  assessment  of  human  exposures  to  chemicals  and 
potential  health  impacts,  building  on  previous  activities  undertaken  at  Union  and  national 
levels with a special focus on linking research to evidence based policy decision making.  

The  aim  of  this  interdisciplinary  initiative  is  to  assess  the  exposure  of  European  Union 
citizens  to  chemicals  of  concern  through  human  biomonitoring  (HBM),  to  link  this 
information to data on exposure sources and epidemiological surveys and to promote research 
on the exposure response relationships in humans.  

In  addition,  it  should  coordinate  HBM  activities  at  national  and  Union  level,  promote 
capacity  building  and  the  spread  of  best  practice,  provide  a  platform  through  which 
harmonised  and  validated  information  and  data  collected  at  national  level  can  be  accessed 
and  compared  and  support  research  and  innovation  (improving  underlying  methods  and 
procedures, biomarkers etc). Data generated will be included in the Information Platform for 
Chemical Monitoring Data (IPCheM platform) developed by the Joint Research Centre100.  

The  preliminary  work  in  2015  identified  nine  priority  groups  of  chemical  substances  that 
were  examined  to  develop  factsheets  covering  substance  classification,  policy-related 
questions and research objectives to span the science-policy interface. In 2017 a further nine 
priority groups of substances were identified to undergo the same process. Upon completion 
of  developing  factsheets,  the  HBM4EU  project  has  continued  the  research  on  the  first  nine 
priority substances, with results reported in 2019101,102. The HBM4EU groups of substances 
include PAHs, PFAS, and flame retardants (including POP flame-retardants) in the original 
(2015) list. The 2017 list further includes pesticides as a general grouping. 

100  IPCheM aims to support a coordinated approach to collecting, storing and accessing monitoring data on 

chemicals and chemical mixtures in humans and in the environment: http://ipchem.jrc.ec.europa.eu/#home-
page 

101  https://www.hbm4eu.eu/the-substances/ 
102  https://www.hbm4eu.eu/wp-

content/uploads/cmdm/6740/1571732940_HBM4EU_AD5.2_Reporting_first_set_of_substances_v1.1_final.pdf 

49 

 
 
 
                                                           
Further  actions  on  research  and  innovation  around  POPs  are  being  carried  out  by  the 
Stockholm Convention Regional Cenres (see section 2.5.1).  

2.6. 

Information Exchange, Public information, awareness and education 

2.6.1.  Overview 

The  Union  institutions  are  committed  to  ensuring  transparency  and  the  involvement  of 
stakeholders and the general public. This is stipulated in the Regulation 1049/2001 on public 
access  to  Union  documents  and  transparency  in  the  decision-making  processes  and  in  the 
communication from the Commission 2002/704 towards a reinforced culture of consultation 
and  dialogue.  The  public  access  to  environmental  information  is  specifically  laid  down  in 
Directive 2003/4/EC.  

The main instruments for transparency and information access are the Europa website and a 
specific  website  dedicated  to  POPs  hosted  by  ECHA103,104.  In  addition  the  European 
Commission hosts databases such as Eur-Lex, statistic databases of Eurostat, the E-PRTR105, 
the  Union  pesticide  database106,  and  OpenFoodTox  for  pesticide  residues  in  food,  and 
databases of Union institutions on specific topics such as the The Chemical Lists Information 
System (CheLIST)107. The Directorate General for Environment maintains the POP-specific 
website  containing  information  on  Union  legislation  and  POP-related  research  projects.  As 
part of the POPs Regulation, ECHA now also has a key role to play on hosting information 
on POPs, including new elements on candidate POPs and the stakeholder consultation (which 
takes  place  over  eight-weeks)  during  the  preparation  of  a  nomination  and  the  review  of  a 
nominated substances108. Additionally, the European Environment Agency (EEA) publishes a 
substantial  amount  of  information  relevant  to  POPs109,  and  the  European  Food  Safety 
Authority (EFSA) has a role in communication of the risks regarding POPs in food. 

Under  the  POPs  Regulation,  there  is  also  a  requirement  for  Member  States  to  develop  and 
publish  reports  on  their  progress  against  the  Articles  of  the  regulation.  This  includes 
statistical and monitoring data, and is required to be kept up to date, with revisions annually 
(or at least once every three years where no new data is available).  

In  addition  the  general  public  or  any  interested  stakeholder  can  have  access  to  certain 
information on the presence of SVHC substances110 in articles in the context of the REACH 
Regulation.  A  request  can  be  sent  to  the  supplier  of  an  article  who  has  to  provide  a  reply 
within 45 days111. 

Within  SAICM,  the  Union  has  actively  promoted  the  development  of  the  Chemicals  in 
Products  Programme,  which  is  a  voluntary  initiative  designed  to  assist  all  stakeholders 
throughout the product life cycle who are seeking procedures for the exchange of information 

103  http://ec.europa.eu/environment/chemicals/international_conventions/index_en.htm 
104  https://echa.europa.eu/understanding-pops 
105  http://prtr.ec.europa.eu/  
106  https://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/public/?event=homepage&language=EN 
107  http://chelist.jrc.ec.europa.eu/  
108  https://echa.europa.eu/proposals-for-new-pops 
109  https://www.eea.europa.eu/data-and-maps/indicators/eea32-persistent-organic-pollutant-pop-emissions-1 
110  According to Article 57 of the REACH Regulation; see also section 0. 
111  According to Article 33 of the REACH Regulation. 

50 

 
 
 
                                                           
on chemicals  in  products. Stakeholders include  businesses, governments, intergovernmental 
agencies,  recyclers,  waste  management  actors,  non-governmental  organisations,  and 
consumer  groups.  The  programme  document112  explains  the  objectives  of  the  Programme’s 
information  exchange  system  and  describes  the  roles  and  suggested  responsibilities  of 
stakeholders in respect of the exchange of chemicals in products information throughout the 
product life cycle. The Guidance for stakeholders on exchanging information on chemicals in 
products has been created to support the Chemicals in Products Programme. It is intended to 
guide those who are designing a chemicals-in-products information system or those seeking 
to  participate  in  an  existing  system.  It  is  also  aimed  at  guiding  stakeholders  who  require 
assistance in exchanging information  on their chemicals in products by describing the steps 
that are commonly taken in scoping,  designing,  and building information exchange systems 
on chemicals in products. 

Furthermore,  as  part  of  the  revised  waste  framework  that  entered  into  force  in  July  2018, 
ECHA is  required  to  establish a new database of information  for Substances of Concern  In 
articles  as  such  or  in  complex  objects  (Products)  (the  SCIP  Database)113.  Those  companies 
supplying  articles  and/or  products  containing  SVHCs  have  to  provide  data  to  the  SCIP 
Database, to help ensure that information on such articles is available throughout the whole 
lifecycle  of  products  and  materials,  including  at  the  waste  stage.  The  information  in  the 
database is made available to waste operators and consumers. 

Consultations  with  stakeholders  are  an  integral  part  of  the  Union’s  environment  policy  and 
provide the opportunity for authorities, civil society and individual citizens to provide input. 
Accordingly, the draft Implementation Plans are also subject to an open consultation process.  

In keeping with the Union’s principle of subsidiarity, public information, awareness raising 
and  education  on  POPs  fall  within  the  remit  of  the  Member  States,  while  the  POPs 
Regulation  urges  the  Member  States  to  provide  awareness  programmes  and  public 
information. A summary of the activities at Member State level can be found in the second 
synthesis report,114 with the third synthesis report expected later in 2020.  

The Commission and Member States exchange information  at  regular Competent  Authority 
meetings  where  national  representatives  for  POP 
topics  are: 
implementation  of  the  Convention  and  the  POPs  Regulation,  nomination  of  chemicals  that 
exhibit  POP  caracteristics  to  the  Stockholm  Convention,  exchange  of  information  on 
occurrence  and  elimination  of  POPs  and  data  gathering  via  reporting  obligations  under  the 
POPs Regulation. 

issues  meet.  Core 

112  SAICM, 2015, ‘The Chemicals in Products Programme’, 

http://www.saicm.org/Portals/12/Documents/EPI/Guidance%20for%20Stakeholder%20in%20Exchanging%
20CiP%20Information_October2015.pdf 

113  https://echa.europa.eu/scip-database 
114  BIO IS (2011): Technical Support on Reporting Obligations and Update of the Community Implementation 

Plan under POP Regulation. ENV.D.3/SER/2010/0068r. Synthesis report. June 2011. 

51 

 
 
 
                                                           
Stockholm Convention Regional Centres 

2.6.2. 
The Stockholm Convention has established a network of 16 regional centres globally115 with 
a mandate for knowledge transfer and awareness raising for the issues surrounding POPs. The 
network has an obligation to support information exchange on a global basis with individual 
centres  working  both  at  a  level  within  their  own  regional  geography  but  also  to  provide 
support to other areas of the planet where needed. Within the Union two such centres exist, 
one based in Czechia (RECETOX) and one based in Spain (The Regional Activity Centre for 
Sustainable  Consumption  and  Production  (SCP-RAC)).  Additionally  under  the  Basel 
Convention a regional centre with similar obligations is also based within Czechia. 

The  two  Stockholm  Convention  regional  centres  located  in  the  Union  have  obligations  to 
support knowledge exchange and raise awareness; they also work to ensure that duplication 
of effort is avoided116. This means that those two regional centres have different core interests 
and  focus  as  well  as  promoting  knowledge  exchange  and  awareness  raising.  Details  of  the 
future  work  plans  2016  –  2019  for  both  centres  are  detailed  on  the  Stockholm  Convention 
website under the details for the individual centres117. 

The  Stockholm  Convention  Regional  Centre  for  Capacity  Building  and  the  Transfer  of 
Technology (SCRC) in Czechia has been established to promote chemicals management and 
management of wastes containing toxic chemicals in the Central and Eastern European region 
and  worldwide  by  providing  training,  capacity  building,  expertise  support  in  a  number  of 
fields.  The  Regional  Centre  is  hosted  by  the  Research  Centre  for  Toxic  Compounds  in  the 
Environment (RECETOX).  

This  is  achieved  primarily  through  the  GENASIS  (Global  ENvironmental  ASsessment 
Information  System),  a  platform  that  disseminates  information  on  POP  levels  in  the 
environment  and  gives  access  to  formation  on  individual  POPs.  GENASIS  was  created  in 
cooperation  of  RECETOX  with  IBA  MU,  institutes  of  the  Masaryk  University,  Brno, 
Czechia. GENASIS combines expertise, validated data from partner institutions, input from 
regular  environmental  monitoring  programmes  and  provides  a  data  repository,  analytical 
tools  and  data  management,  providing  the  user  with  available  up-to-date  information  on 
spatial  and  temporal  trends  in  POPs  concentrations  in  various  environmental  matrices  (air, 
water, soil, biota and human tissues).  

Experts  from  RECETOX  between  2010-2014  in  collaboration  with  UNDP,  UNIDO  and 
NATO  built  capacities  in  Armenia,  Kazakhstan  and  Kyrgyzstan;  in  2013-2015  intensively 
and  in  long  term  cooperated  with  Turkey,  Bosnia  and  Herzegovina  and  Serbia;  and  in  the 
years  2012-2016  for  example,  performed  short-term  training  in  Armenia,  Brazil,  China, 
Ghana, South Korea, Malaysia, Mali, Maldives, Seychelles, Ukraine and other countries.  

The  SCRC  RECETOX  2016-2019  work  plan  has  the  following  key  goals:  strengthening 
global capacities in  chemical  analyses of toxic chemicals,  support in  implementation  of the 
Global Monitoring Plan to the Stockholm Convention by operating monitoring networks and 
training experts in sampling, and monitoring and data mining and management. 

115  Stockholm Convention Regional Centres: 

http://chm.pops.int/Partners/RegionalCentres/Overview/tabid/425/Default.aspx  

116  Personal Communication, Recetox, 2016. 
117  http://chm.pops.int/Partners/RegionalCentres/Overview/tabid/425/Default.aspx 

52 

 
 
                                                           
RECETOX  has  also  supported  knowledge  exchange  through  a  series  of  ‘international 
summer  schools’  open  to  experts  and  general  interest  groups.  The  14th  Summer  School  on 
Toxic Compounds in the Environment (2018) focussed on contaminants in the environment, 
including modeling long-range transport, sampling and analysis, and use of GIS data.118 The 
latest summer school (15th international summer school) held in June 2019 was organised in 
association with the HBM4EU programme and had a focus on human biomonitoring data. 

The  Regional  Activity  Centre  for  Sustainable  Consumption  and  Production  (SCP/RAC)  in 
Barcelona,  Spain,  is  a  centre  for  international  cooperation  with  Mediterranean  countries  on 
development  and  innovation  in  the  manufacture  sector  and  civil  society,  based  on  more 
sustainable  consumption  and  manufacture  models.  This  centre  undertakes  activities  in  the 
Mediterranean  region  related  to  technical  assistance  and  promotion  of  capability  and 
information  exchange  in  relation  to  resource  efficiency,  clean  manufacture  and  pollution 
prevention.  It  also  works  on  providing  support  related  to  the  reduction  of  hazardous 
chemicals through BAT and BEP (Best Environmental Practices). 

For  example,  the  GRECO  project  is  a  Mediterranean  initiative  designed  to  promote  green 
competitiveness  in  the  region  by  showing  the  economic  benefits  that  businesses  can  gain 
from an environmental approach. The SCP/RAC also support the identification of the assets 
and  challenges  for  Green  Entrepreneurship  in  the  Mediterranean  region  and  collection  and 
dissemination  of  successful  case  studies  of  Green  Entrepreneurs.  Furthermore,  the  SWIM-
H2020  SM  Project  (Sustainable  Water  Integrated  Management  and  Horizon  2020  Support 
Mechanism 2016-2019) funded by the Union aims to contribute to reduced marine pollution 
and  a  sustainable  use  of  scarce  water  resources  in  the  countries  of  North  Africa  and  the 
Middle East. 

SCP-RAC acts as the Stockholm Convention regional centre for the Mediterranean covering 
all of the southern Member States, but also countries in northern Africa and countries at the 
far east of the Mediterranean area bordering with the Middle East. The core focus of the SCP-
RAC  centre  is  sustainability  and  the  elimination  of  POPs  from  the  supply  chain.  This 
includes review of both manufacture activities as well as the wider supply chain. SCP-RAC 
have  supported  this  process  with  provision  of  information  for  substituition  detailed  on  the 
subsport website119 and input to the ‘SwitchMed’120 programme.  

3. 

OVERALL ASSESSMENT OF THE POPS ISSUE IN THE UNION 

At  Union  level,  significant  progress  towards  the  elimination  of  POPs  has  been  achieved. 
Manufacture and use of all POPs is prohibited with some exemptions that are decreasing. A 
main  challenge  for  the  Union  is  to  eliminate  POPs  from  the  waste  cycle  and  remaining 
stockpiles  as  these  still  present  a  major  emission  source.  The  following  sections  briefly 
introduce the situation in the Union for the different POPs. 

118  http://www.sense.nl/courses/past/10892612/14th-Summer-School-on-Toxic-Compounds-in-the-

Environment-2018 

119  Subsport website http://www.subsport.eu/ 
120  SwitchMed website http://www.switchmed.eu/en 

53 

 
 
 
 
                                                           
3.1. 

POPs regulated before 2009 (“old POPs”) 

The term “old POPs” covers the substances listed in the Stockholm Convention or the POP 
Protocol  and  regulated  by  Regulation  (EC)  No  850/2004  before  2008,  i.e.  before  the  new 
POP substances were listed in the Stockholm Convention or the POP Protocol in 2009, 2011, 
2013, 2015, 2017 and 2019 (cf. section 3.2). The data on old POPs presented in the following 
sections are based on the third synthesis report and draft version of the fourth synthesis report 
covering  2010  – 2013  and 2013  – 2015 respectively;  which includes all  annual  reports and 
the 2010 – 2013 and 2013 – 2015 triennial reports of the Members States. 

3.1.1.  Manufacture 

The old POPs are no longer manufactured in the Union.  

a 

as 

for 

the 

under 

consideration 

The specific exemption of the use of DDT in dicofol manufacture has been withdrawn from 
the  POPs  Regulation.  This  notes  that  dicofol  itself  has  been  found  to  meet  the  Annex  D 
criteria 
Stockholm  Convention 
POP 
(UNEP/POPs/POPRC.10/3).    The  Commission  decided  on  the  non-inclusion  of  dicofol  in 
Annex I to Council Directive 91/414/EEC and on the withdrawal of authorisations for plant 
protection  products  containing  that  substance  (2008/764/EC)121  in  2008.  According  to  the 
Commission Decision, all existing authorizations for dicofol in plant protection products had 
to  be  withdrawn  before  30  March  2009.  National  registration  of  dicofol  was  no  longer 
possible after March 2009. Any transition period granted by the Member States expired by 30 
March 2010. Up to the year 2006, dicofol has been produced by Montecinca SA. at Monzón, 
Spain. The yearly manufacture amounted to approx. 1500 t. Manufacture was discontinued in 
2006,  when  the  registration  for  Spain  expired.  Until  2009,  dicofol122  was  furthermore 
formulated and used in Italy123.  

3.1.2.  Use and placing on the market 

The use of the old POPs listed in Annexes A and B has been progressively phased-out in the 
Union. Remaining uses of old POPs are only in articles that were produced and placed on the 
market  before  the  entry  into  force  of  the  POPs  Regulation  and  as  standards  for  research 
purposes. Some illegal placing on the market of imported fireworks containing HCB has been 
reported  by  some  Member  States  in  the  period  2010-2013  and  again  in  2013-2015.  Other 
Member States also indicated the presence of SCCPs and/or HCB in items such as childrens 
toys,  christmas  lights,  plastics  bags,  electric  products  and  other  articles  in  2014  and  2015 
which resulted in products being withdrawn from the market. The enforcing authorities of the 
relevant Member States have intervened to stop these illegal practices and ensured a proper 
disposal of the products, although no penalites were reported as a result.  

121  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:262:0040:0041:EN:PDF  
122  Dicofol meets the Stockholm Convention Annex D criteria  
123   http://www.unece.org/env/lrtap/TaskForce/popsxg/2010/Exploration%20of%20management%20options%2

0for%20Dicofol%20final.pdf 

54 

 
 
 
 
 
                                                           
3.1.3. 

Import, export and intra-Union shipments 

Waste  containing  POPs  (e.g.  obsolete  pesticides  or  contaminated  equipments)  has  been 
shipped    into  some  Member  States  for  the  purpose  of  its  disposal  and  elimination.  These 
shipments originate from EU and non-EU countries that lack adequate technology for proper 
disposal  of  such  waste.  These  shipments,  including  imports  are  being  undertaken  in 
accordance  with  the  provisions  of  the  Stockholm  Convention  and  they  contribute  to  the 
overall  reduction  of  POPs.    Slovenia,  for  example,  indicated  that  there  are  no  technical 
facilities  for  disposing  of  PCB  and  PCB  equipment  (with  final  disposal  or  destruction  of 
PCB)  in  an  environmentally  sound  manner  in  the  country.  Therefore  the  waste  PCB  and 
waste PCB equipment is shipped to other Member States, i.e. France, Germany and Austria, 
for disposal in an environmentally sound manner. 

Some  illegal  imports  of  POPs  embedded  in  products  occurred  in  the  period  2013-2015. 
Hexachlorobenzene was imported as part of fireworks, which also occurred during the 2010-
2013 period, along with SCCPs found in plastic items including toys, electrical products and 
bathroom  items.  As  mentioned  in  the  sub-section  3.1.2,  the  enforcing  authorities  took 
appropriate measures to remove them from the market as soon as possible. 

There is very little Union export of POPs.  In the period 2013-2015, a few kilograms of the 
following  substances  have  been  exported  under  the  exemption  for  standards  for  research 
purposes: 

  Aldrin, Lindane, Dieldrin, Endrin, DDT, HCB, PCBs,  heptachlor, HCH, endosulfan, 

and hexachlorobutadine 

Conversely  a  review  of  the  ECHA  website  for  notifications  on  exports  from  non-EU 
countries  to  the  Union  showed  that  in  2019  the  USA  notified  the  export  of  the  following 
substances: 

  Endrin to Germany, 

  PCBs to France, Germany and the UK, 

  Pentachlorobenzene to Germany, 

  PFOA to France and the UK, 

  SCCPs to France, Germany and the UK. 

3.1.4. 

Stockpiles and waste 

Only one Member State (Spain) reported information on stockpiles of obsolete pesticides in 
their triannual reports covering the period 2013-2015. For comparison, in the third synthesis 
report (covering the period 2010-2012), four Member States were reported to have provided 
information  on  stockpiles  of  obsolete  pesticides,  i.e.,  Bulgaria,  Hungary,  Lithuania  and  the 
United  Kingdom.  The  reported  quantities  varied  between  88  kg  in  the  United  Kingdom  to 
200 tonnes in Hungary.  

In the Member States NIPs no information on stockpiles of obsolete pesticides was reported 
for the period 2013-2015 and beyond or Member States indicated that all identified stockpiles 
have been disposed. 

55 

 
 
 
Issues have been identified with contaminated land at former sites of manufacture which in 
turn can generate waste which requires management during remediation works; this may be 
an issue in particular for sites where manufacture of lindane previously took place.   

It  is  noted  that,  ‘in  almost  all  Member  States  where  lindane  production  took  place,  the 
elimination and de-pollution of soils, surface water and groundwater is needed’ and that ‘hot-
spots’, with  thousands,  and often hundred thousands, of tonnes of  lindane and HCH  waste, 
are  pending  remediation  activities  in  Czechia,  France,  Germany,  Hungary,  Italy,  Poland, 
Romania, Slovakia and Spain124. 

In  their  triannual  report  (2013-2015),  Spain  provided  information  on  sites  contaminated  by 
HCH in four regions, i.e. Aragón, Castilla y León, País Vasco and Galicia. In the region of 
Aragón,  lindane  was  manufactured  between  1975  and  1989,  with  the  generated  solid  and 
liquid  waste  disposed  in  the  landfills  of  Sardas  and  Bailín.  Many  decontamination  actions 
have  been  undertaken  and  actions  are  still  planned,  such  as  hydrogeological  monitoring  or 
further testing activities.  

PCB disposal by end of 2010 (PCBs in larger equipment) and 2025 (all remaining PCBs)   

The Stockholm Convention has set an objective to eliminate the use of PCBs in equipment by 
2025 and to make determined efforts to achieve environmentally sound waste management of 
liquids and equipment contaminated with PCBs by 2028. 

At Union level the aims of the Convention are  incorporated into Directive 96/59/EC on the 
disposal of PCBs and PCTs (cf. section 2.2.3) and further in the POPs Regulation  (cf. section 
2.2.2). The PCB directive places a requirement on all Member States to develop registers of 
equipment  containing  more  than  5  dm3  of  PCBs  and  communicate  the  registers  to  the 
European Commission.  Furthermore the PCB Directive  required the Member States  to  take 
action  to  ensure  that  the  equipment  containing  PCBs  (of  more  than  5  dm3)  in  the  registers 
were decontaminated or disposed of by 31 December 2010 at the latest. 
Under the PCB Directive equipment smaller than 5 dm3, with concentrations between 0.05% 
and  0.005%  PCB  could  still  be  included  within  the  register,  but  could  be  marked  as  ‘PCB 
contaminated <0.05%’ and would therefore not be subject to the 31 December 2010 deadline. 
The  POPs  Regulation  includes  a  provision  under  Part  A,  Annex  I  of  the  regulation  that  all 
remaining PCBs in-use for di-electric equipment (with greater than 0.005% concentration and 
0.05 dm3 size) must be identified and removed from use by no later than 31 December 2025. 

In compliance with the PCB Directive, inventories of PCB-containing equipment, as well as 
action plans for their disposal and collection were compiled by all Member States. 

In  December  2011,  the  Commission  launched  a  survey  to  assess  what  progress  had  been 
made against this target, and requested the Member States to provide information about PCB 
wastes.  Additionally  in  2014  an  ex-post  evaluation  of  the  PCB  Directive125  also  assessed 
what  progress  had  been  made  towards  the  2010  target.  Both  the  2011  survey  and  2014 
evaluation  identified  that  good  progress  had  been  made  towards  the  identification  of  PCB-
containing  equipment  and  disposal  of  PCB  wastes  within  the  Union,  with  some  Member 
States close to meeting the 2010 target. However, most Member States had not met the target 

124  European  Union  (2016)  “Lindane  (persistent  organic  pollutant)  in  the  EU”,  Report  for  the  European 

Parliament, Policy Department C: Citizen’s Rights and Constitutional Affairs 
125 European Commission, 2014: Ex-post evaluation of certain waste stream directives. 

56 

 
 
                                                           
of decontamtion or disposal of liquids and equipment contaminated with PCB on registers by 
31 December 2010.  

In  order  to  better  understand  and  complement  the  data  on  PCB-containing  equipment,  a 
request  for  information  was  sent  out  by  the  contractor  to  the  Member  State  Competent 
Authorities in April 2017. Acknowledging the levels of uncertainty inherent to the estimates 
of PCBs in such equipment, the request asked for input on the quantities of PCB actively in 
use in di-electric equipment, both in 1990 and in 2015, as well as the quantities of PCBs that 
have  been  destroyed  between  1990  and  2015.  In  total,  14  Member  States  responded  to  the 
request. The majority of the Member States reported that in 2015 <10% of the PCBs  in-use 
from  the  1990  reference  year  were  still  in  use.  Five  of  these  Member  States  estimated  a 
fraction  of  PCB  in  use  below  1%.  Croatia  and  Romania  reported  significantly  higher  PCB 
fractions still in use, 30% and 49%, respectively. It should be noted that their estimates were 
based on different reference years, i.e. 2008 for Croatia and 2005 for Romania. 

A number of reasons have been cited for difficulties in achieving this target in both the 2011 
survey  and  2014  ex-post  evaluation.  In  particular  the  survey  highlighted  issues  with 
identification of PCB-containing equipment with a lack of reliable and comparable data in the 
Union. Reporting has been in some cases incomplete and in some cases, the number of pieces 
of  equipment  instead  of  the  PCB  content  (expressed  in  kg  or  tonnes)  were  reported.  Some 
Member States did  not  distinguish  between equipment containing  more than 500 ppm  (500 
mg/kg) PCB and equipment containing more than 50 ppm (50 mg/kg) PCB, as is listed in the 
Directive. Therefore analysis is required which can be costly. This is a position which can be 
further  complicated  where  di-electric  equipment  containing  heat  transfer  fluids  that  may 
contain PCBs are ‘topped up’ to replace lost fluids with non-PCB-based oils. This does not 
remove the contamination but only dilutes it. 

The  ex-post  evaluation  also  noted  that,  for  newer  Member  States  e.g.  Bulgaria  and  Croatia 
not benefiting from transition provisions in accession treaties, meeting the 2010 deadline was 
extremely challenging. However the ex-post evaluation also goes on to state that work is still 
ongoing  towards  the  overall  aims  of  of  the  PCB  Directive,  and  the  target  of  disposal  and 
decontamination  of  PCB-containing  equipment  can  be  expected  to  be  achieved  by  at  least 
90% of Member States in the coming years. 

The POPs  triennial synthesis report for the period 2010-2012, which is  based on data from 
submissions  by  Member  States  under  Article  12  of  Regulation  (EC)  No  850/2004, 
highlighted that work to identify, remove and dispose of PCB-contaminated liquids was still 
ongoing  after  2010.  However,  since  different  approaches  to  quantify  materials  have  been 
used, it is  difficult  to  comment  on total  quantities that are still existing  in  use or stockpiles 
requiring disposal.  

POPs regulated from 2009 (“new POPs”) 

3.2. 
The new POPs are the substances that were listed in the Stockholm Convention at the 4th, 5th, 
6th, 7th, 8th and 9th COP meetings held in May 2009126, in April 2011, in May 2013, in May 
2015,  in  May  2017,  and  in  May  2019  respectively,  and  in  the  POP  Protocol  at  the  27th 

126  α-, β-, γ-HCH, chlordecone, HBB, tetra-, penta-, hexa-, and hepta- BDE, PeCB, PFOS (including salts) and 

PFOSF 

57 

 
 
 
                                                           
meeting  of  the  Executive  Body  of  LRTAP  Convention  held  in  December  2009127  and  that 
were not listed in any of these instruments before. An summary of ‘new’ POPs added to the 
Convention since 2009 is provided in Table 5 below.  

Table 5  New POPs added to the Stockholm Convention since 2009 

COP   Date  

POPs added  

4 

4 to 8 May 2009 

5 

6 

7 

25 to 29 May 2011 

28 April to 10 May 2013 

4 to 15 May 2015 

  Alpha hexachlorocyclohexane in Annex A without specific exemptions (decision 

SC-4/10)  

  Beta hexachlorocyclohexane in Annex A without specific exemptions (decision SC-

4/11)  

  Chlordecone in Annex A without specific exemptions (decision SC-4/12)  
  Hexabromobiphenyl in Annex A without specific exemptions (decision SC-4/13)  
  Hexabromodiphenyl ether and heptabromodiphenyl ether in Annex A with specific 

 
 

 

 
 

exemptions (decision SC-4/14)  
Lindane in Annex A with specific exemptions (decision SC-4/15)  
Pentachlorobenzene in Annex without specific exemptions and in Annex C 
(decision SC-4/16)  
Perfluorooctane sulfonic acid, its salts and perluorooctane sulfonyl fluoride in 
Annex B with acceptable purposes and specific exemptions (decision SC-4/17)  
Tetrabromodiphenyl ether and pentabromodiphenyl ether in Annex A 
Technical endosulfan and its related isomers in Annex A with a specific exemption 
(decision SC-5/3) 

  Hexabromocyclododecane in Annex A with specific exemptions (decision SC-6/13) 
  Hexachlorobutadiene in Annex A without specific exemptions (decision SC-7/12) 
 
Pentachlorophenol and its salts and esters in Annex A with specific exemptions 
(decision SC-7/13)  
Polychlorinated naphthalenes in Annex A with specific exemptions and in Annex C 
(decision SC-7/14) 

 

  Decabromodiphenyl ether (commercial mixture, c-decaBDE) in Annex A with 

8 

24 April to 5 May 2017 

 

specific exemptions (decision SC-8/10) 
Short-chain chlorinated paraffins in Annex A with specific exemptions (decision 
SC-8/11) 

9 

29 April to 10 May 2019 

  Hexachlorobutadiene in Annex C (decision SC-8/12) 
 

Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds in Annex A 
with specific exemptions  

  Dicofol in Annex A, with no exemptions  

Prior  to  their  listing  the  new  POPs  were  subject  to  prohibition  or  severe  restrictions  in  the 
Union. With the new amendments of the POP Regulation, certain restrictions go further than 
previously was the case in order to comply with the new international commitments. In this 
context  it  needs  to  be  highlighted  that  HBCDD,  POP-PBDEs  and  PFOS  in  contrast  to  the 
other new POPs will continue to challenge the management of certain waste streams due to 
the  long  life-span  of  the  major  product  groups  containing  them  (e.g.  vehicles,  electronics), 
and due to the fact that they are contained in products that are still in use (ESWI 2011 ). 

127  SCCPs  (short  chain  chlorinated  paraffins),  HCBD  (hexachlorobutadien)  and  PCN  (polychlorinated 

naphthalenes); http://www.unece.org/env/lrtap/pops_h1.htm  

58 

 
 
 
 
                                                           
The following table gives a first overview on the situation concerning the new POPs. Please, 
note  that  the  figures  from  ESWI  are  estimates.  Further  information  on  the  individual 
substances is given in the sections below. 

59 

 
 
 
Table 6  Overview on the new POPs (ESWI 2011 + additional references where indicated)  

Substance 

Purpose 

Manufacture 

Use/Stockpiles in Products 

Import 

Export 

Waste 

Emissions 

Chlordecone* 

Pesticide 

Hexacyclohex
ane – 
including 
lindane** 

Pesticide 

Endosulfan 

Pesticide 

Hexabromobip
henyl* 

Industrial 
Chemical 

Historical manufacture began 
in the USA in the early 1950s. 
No Union manufacture but 
was marketed in the Union 
until 1993128. No current 
manufacture expected  

Technical HCH (containing 
alpha and beta isomers) began 
manufacture in the mid-1940s. 
Vijgen et al. estimate that 
300,000 tonnes of HCH 
including lindane was made 
and used in Europe between 
1950-2000129. 

Historic manufacture in 
Europe amounted to 10.000 to 
50.000 tonnes per year. 
Manufacture stopped latest in 
2007. 
Historical manufacture within 
the USA from early to late 
1970s. No manufacture in the 
Union, but was marketed. No 
current manufacture 
expected.130 

No current use is reported. 

Banned 

Banned 

No information 
available. 

No information 
available. 

No current use is reported. 

Banned 

Banned 

Potential 
significant 
contaminated 
land issue. For 
every 1 tonne 
of lindane 
produced up to 
10 tonnes of 
toxic waste 
containing 
HCH isomers 
was produced.  

No information 
available. 

No current use is reported. 

Banned 

Banned  

No information 
available. 

No information 
available. 

No current use is reported. 

Banned 

Banned 

No information 
available. 

No information 
available. 

128  Stockholm Convention Risk Management Evaluation (UNEP/POPS/POPRC.3/20/Add.2) 
129  Vijgen et al. (2011). HCH as new Stockholm Convention POPs – a global perspective on the management of Lindane and its waste isomers. Env Sci Pollut Res. 18, 152-

162. 

130  Stockholm Convention Risk Management Evaluation (UNEP/POPS/POPRC.3/20/Add.3) 

60 

 
 
                                                           
Substance 

Purpose 

Manufacture 

Use/Stockpiles in Products 

Import 

Export 

Waste 

Emissions 

Tetrabromo-
diphenyl ether 
and penta-
bromodiphenyl 
ether 

Hexabromo-
diphenyl ether 
and hepta-
bromodiphenyl 
ether 

Perfluorooctan
e sulfonic acid 
(PFOS), its 
salts and per-
fluorooctane 
sulfonyl 
fluoride  

Industrial 
Chemical 

Manufacture in the Union 
ceased in 1997 

Industrial 
Chemical 

Manufacture within the Union 
stopped in 1996/98 

Industrial 
Chemical 

Within the Union exemptions 
for specific uses 

Historical use in applications with a high 
lifetime, such as automotive and 
upholstery application that are still in use.  
Estimated amount of C-PentaBDE in 
automotive applications in 2010: 258,3 t 
Accumulated amount of C-PentaBDE in 
upholstery applications: 321 t. 
Estimated amount of C-PentaBDE in 
upholstery applications in 2010: 96.95 t 

No amount of 
C-PentaBDE in 
imported 
finished articles 

Estimated C-
PentaBDE 
exported in 
ELVs in 2010: 
4,1 t 

Historical use in Acrylonitrilebutadiene-
styrene (ABS) polymers (95%) 
Estimated amount of C-OcteBDE in EEE 
applications in 2010: 258,3 t 

No amount of 
hexaBDE in 
imported 
finished articles 

Estimated current uses: the metal plating 
industry (6,500 kg/y), hydraulic fluids 
(730 kg/y), photographic industry (562 
kg/y used +~1,280 kg from historical 
storage), semiconductor industry (9.3 
kg/y), fire fighting foams (90t in stocks) 
Total sources 163 t/y and 1,730 t in 
product131 (mainly from carpets) 

No information 
available, 
except for the 
photo industry: 
finished articles 
containing 
PFOS account 
for 150 kg/y 

(Illegal) E-
waste possibly 
contaminated 
with C-Octa-
BDE; amount 
of C-OctaBDE 
not quantifiable 
No information 
available, 
except for the 
photo industry: 
finished articles 
containing 
PFOS account 
for 250 kg/y   

C-PentaBDE in 
automotive 
waste:  
~243.3 t in 
2010 
C-PentaBDE in 
upholstery 
applications: 
91.3 t in 2010 

C-PentaBDE in 
automotive 
emissions:  
~15 t in 2010 
C-PentaBDE in 
upholstery 
emissions: ~6 t 
in 2010 

128 t of C-
OctaBDE in 
2010 

c-OctaBDE 
emissions : ~3 t 
in 2010 

163t PFOS in 
2010 

PFOS 
emissions: >1 t 
in 2010 

Hexabromocyc
lododecane 

Industrial 
Chemical 

Manufacture and use within 
the Union was subject to 
REACH Authorisation. 13 
companies were granted 
Authorisation in 2016 for two 
specific applications.132 

As of January 2016 only two applications 
were granted continued use: as a flame-
retardant for expanded polystyrene 
boards and as a flame-retardant in 
expanded polysyrene beads. The 
Authorisation expired in August 2017. 
Data on usage rates post-January 2016 

No current data 
post-REACH 
Authorisation 

No current data 
post-REACH 
Authorisation 

No information 
available. 

41 kg 
per/annum to 
air and 35 kg to 
water during 
manufacture 
and 530 kg to 
air/560 kg to 
water from use 

131  Represents the existing stock of the substance in product in use.  
132  ECHA news update: http://echa.europa.eu/view-article/-/journal_content/title/authorisations-granted-for-two-uses-of-hbcdd 

61 

 
 
                                                           
Substance 

Purpose 

Manufacture 

Use/Stockpiles in Products 
unknown. 
Data from 2014133 suggested 
manufacture rates of 5,000 – 7,500 
tonnes per annum. 

Import 

Export 

Waste 

Emissions 
phase116. 

Industrial 
Chemical; 
Intermediate 
in pesticide 
manufacture; 
By-product 

Industrial 
Chemical 

Pentachlorobe
nzene (PeCB) 

SCCPs – short 
chain 
chlorinated 
paraffins 

No intentional manufacture or 
use 

Sources in Europe accounts for about 
2,632 kg/y (dominated by the power 
manufacture from coal) 

No information available134.  
In the POPRC risk profile for 
PeCB135 no trade or stockpiles 
have been reported. 

307,8 kg PeCB 
in 2010 

PeCB 
emissions: 
~2.324t in 2010 

Use and placing on the market 
for some applications 
restricted since 2002 

Total sources ~ 2.151 t and in used 
products 22.132 t in 2010 

No information 
available. 

No information 
available. 

2.082 t SCCPs 
in 2010 

HCBD – 
hexachloro-
butadiene 

Industrial 
Chemical 
By-product 

No use and manufacture in the 
Union; unintentional 
manufacture as by-product 

Total sources 506 kg in 2010  
Estimated amount of HCBD from the 
chlorine industry in 2010: ~500 kg 
Accumulated amount of HCBD from 
sewage sludge: ~6 kg 

No information 
available. 

No information 
available. 

500 kg HCBD 
in 2010 

PCN – 
polychlorinate
d naphthalenes 

Industrial 
Chemical 
By-product 

No use and manufacture in the 
Union; unintentional 
manufacture as by-product 

Historical use mainly in the electrical 
industry 

No information 
available. 

No information 
available. 

3.240,74 kg 
PCN in 2010 

133  VECAP annual report: http://www.vecap.info/publications-2/ 
134  http://ihcp.jrc.ec.europa.eu/our_databases/edexim  
135  UNEP/FAO/RC/CRC.7/9/Add.2, document No. 4, November 2007 

62 

SCCPs 
emissions: ~69t 
in 2010 

HCBD 
emission from 
the plastic 
industry to 
waste water in 
2008: 24 kg;  
no further 
information 
available 
PCN 
emissions: 
~12kg in 2010 

 
 
                                                           
Substance 

Purpose 

Manufacture 

Use/Stockpiles in Products 

Import 

Export 

Waste 

Emissions 

Decabromodip
henyl ether*** 

Industrial 
chemical 

No manufacture in the Union 
after 1999. Use declined from 
mid-2000s, some remaining 
use permitted for legacy 
automotive and aircraft parts 

Between 1970 – 2010 around 185,000 – 
250,000 tonnes of c-decaBDE was used 
in the EU. Earnshaw et al (2013) assumes 
stockpiles of 75,000 tonnes in 2000. 

Consumption rates declined from 11,000 
tonnes per annum in 1999 to 4,000 
tonnes in 2012.  

No information 
available 

No information 
available 

Assuming 10 
year lifespan of 
goods and 
stockpile of 
75,000 tonnes 
would equate to 
7.5 tonnes of 
waste per 
annum (in 
plastics, textiles 
and soft 
furnishings). 

Predicted 
decaBDE 
emissions in 
the EU: Air 4 
tonnes p/a; 
water 2.75 
tonnes p/a and 
soil 0.25 tonnes 
per annum 
(Earnshaw et 
al, 2013) 

Banned 

Banned 

No information 
available. 

No information 
available. 

Pentachloroph
enol and its 
salts and 
esters**** 

Pesticide 
(timber 
treatment) 

No manufacture or use in the 
Union.  
Under the POPs Regulation, 
from 2019 pentachlorophenol 
and its salts and ester are not 
permitted for manufacture, 
and shall not be used in the 
production of another 
substance, mixture, or article. 
Before, REACH restriction 
limited concentrations to 0.1% 
w/w when placed on the 
market since 2008. 

REACH restriction on decaBDE 2 March 
2019 limits placing on the market above 
0.1% w/w. 

Use of PCP was heavily restricted in the 
EU from 1991 (Council Directive 
91/173/EEC), however treated timbers 
can have a long life span up to 50 years. 
Total quantity of remaining stocks of 
timber contaminated with PCP is 
unknown. 

Usage of PCP in the EU had dropped to 
100 tonnes per annum (import) by 1996, 
with only five Member States still using 
PCP at that time (Eurochlor, 1999).  

63 

 
 
 
 
 
Substance 

Purpose 

Manufacture 

Use/Stockpiles in Products 

Import 

Export 

Waste 

Emissions 

Estimated volumes of use in the EU in 
2014 were (ECHA, 2015): 

Perfluorooctan
oic acid 
(PFOA), its 
salts and 
PFOA-related 
compounds 

Surfactant 
and 
processing 
aid for 
production 
of 
fluoropolym
ers 

Dicofol  

Pesticide 

Production of PFOA related 
substances in the Union in 
2014 estimated at 100 to 
>1000 t/y (ECHA, 2015) 

Under the POPs Regulation, 
from 2020 PFOA, its salts and 
related compounds are not 
permitted for manufacture, 
and shall not be used in the 
production of another 
substance, mixture, or article. 
However, a number of 
exemptions apply. 

Around 1,500 t were produced 
in the Union in 2000 
(primarily in Spain and Italy). 
Use was around 90 – 150 t/y, 
primarily in Spain, where use 
ceased in 2009. 

Under the POPs Regulation, 
from 2020 dicofol is 
prohibited for manufacture 
and use in another substance, 
mixture, or article. 

 

Textile and leather treatment 
(~1,000 t) 
Paper treatment (>150 – 200 t) 
Firefighting agents (>50 – 100 t) 
Paints and inks (>50 – 100 t) 

 
 
 
  Others uses (>0.1 – 0.5 t) 
  Manufacture of fluoropolymers 

(<20 t) 
Photo industry (1.0 t) 
Semiconductor industry (<0.05 t) 

 
 
  Other uses (0.5-1.5 t) 

From 2020, under the POPs Regulation 
the use of PFOA was restricted with a 
number of specifically exempted uses. 

Banned (from 
2020), but with 
derogations 

Not yet listed 
in PIC 
Regulation. 

No information 
available. 

No information 
available. 

From 2020, the POPs Regulation 
prohibited all uses. 

Banned 

Banned 

No information 
available. 

No information 
available. 

* The limited use of chlordecone and hexabromobiphenyl within Europe means the potential risk for release to environment is equally low. Further discussion is not provided within this section. 

**  The manufacture and use of hexachlorohexane including Lindane was significant in Europe. However the greatist issue now posed by this substance relates to contaminated land. Further discussion of HCH and 
lindane is provided in section 3.4.2 

***Details on manufacture and stockpiles based on EU risk assessments from 2001 and 2003 and REACH striction dossier (2014), information on waste and emissions based on Earnshaw et al, (2013). 

****Details based on EU regulation, and Eurochlor dossier (1999).  

64 

 
 
 
 
 
3.2.1.  Endosulfan 

Endosulfan is an insecticide that has been used since the 1950s to control crop pests, tsetse 
flies  and  ecto  parasites  of  cattle  and  as  a  wood  preservative.  Its  manufacture  in  the  Union 
stopped  in  2006/2007.  Export  was  allowed  to  continue  until  banned  by  Regulation  (EU) 
649/2012.  Germany  was  the  second-largest  endosulfan  producer  after  India  (approximately 
4,000 tonnes per  year)  while historic  manufacture in  Europe amounted to 10,000 to  50,000 
tonnes per year136. 

In  the  Union,  the  use  of  endosulfan  in  plant  protection  products  was  prohibited  in  2005. 
However,  by  way  of  derogation  from  the  provisions  of  Regulation  (EC)  No  1107/2009 
concerning  the  placing  of  plant  protection  products  on  the  market  under  special 
circumstances a Member State may authorise for a period not exceeding 120 days the placing 
of plant protection products containing endosulfan on the market for a limited and controlled 
use. Some Member States have made use of this for e.g. the use as an insecticide for hazelnut 
(harmful  organism  –  Curculio  nucum),  the  use  as  rodenticide  for  rape,  orchards,  stalky 
cereals crops (harmful organisms – Microtus arvalis) or the use in plant protection products 
and in antifouling products. 

As  a  consequence  of  listing  of  Endosulfan  in  Annex  A  of  the  Stockholm  Convention,  its 
manufacture, placing on the market and use has been banned by adding it to the appropriate 
Annex of the POP Regulation (Regulation (EC) No 2019/1021). Further information such as 
relating  to  endosulfan  stockpiles  in  the  Member  States  is  not  available.  However,  for 
imported food products, the EFSA OpenFoodTox database reports that in 2012 safe limits for 
residues  within  food  (based  on  an  acute  reference  dose  (ARfD))  were  calculated  at  0.015 
mg/kg bw/day. 

3.2.2.  POP Polybrominated diphenyl ethers (POP PBDEs)  

Polybrominated  diphenyl  ethers  are  a  family  of  chemicals  which  have  been  used  as  flame 
retardants  in  a  range  of  applications  covering  plastics,  textiles,  soft  furnishings,  adhesives, 
sealants, coatings and inks . A number of commercial products containing POP-PBDEs have 
been  placed  on  the  market  in  the  Union  (such  as  DE-71,  Bromkal,  Saytex137),  which  are 
categorised  based  on  their  major  homologue  groups  called  “Commercial  Pentabromo 
diphenyl  ether  (C-PentaBDE)”,  “Commercial  Octabromo  diphenyl  ether  (c-octaBDE)’,  and 
‘Commercial Decabromo diphenyl ether (C-decaBDE)’. While the names for the commercial 
groups of PBDEs bear the name of the major homologue, in practice they are mixtures, which 
can  vary  depending  on  the  specific  manufacturer  /  product.  La  Guardia  et  al.  (2006)  (see 
Table 6) provides a further overview of the typical mixtures for c-pentaBDE, c-octaBDE and 
c-decaBDE based on analysis of DE-71, Bromkal and Saytex. 

A growing concern for the environmental and health effects of PBDEs (based on a weight of 
evidence),  particularly  for  lower  order  homologue  groups,  led  to  a  ban  of  the  C-PentaBDE 
and  c-octaBDE  in  the  Union  in  2004  (by  Directive  2003/11/EC  ).  Since  June  2009,  these 
restrictions  for  c-pentaBDE  and  c-octaBDE  were  included  in  REACH  Annex  XVII  on 

136  Risk  profile  and  risk  management  plan  by 

the  POPRC  (UNEP/POPS/POPRC.5/10/Add.2  and 

UNEP/POPS/POPRC.6/13/Add.1) 

137  Note that Saytex includes a range of different products and compositions. The UIP in this context refers to 

only those specific Saytex products that contained PBDEs. 

65 

 
 
 
                                                           
restrictions  on  the  manufacture,  placing  on  the  market  and  use  of  certain  dangerous 
substances,  preparations  and  articles  by  the  Regulation  552/2009.  Furthermore,  in  2009  the 
chemical homologues tetra, penta, hexa and heptaBDE were added to Annex A (banned) of 
the Stockholm Convention at the fourth conference of the parties (COP-4). 

Table 7  Breakdown of commercial PBDE products on the Union market 

Commercial Penta BDE mixture 
as % wt/wt 

Commercial Octa BDE 
mixture as %wt/wt 

Commercial Deca BDE 
mixture as % wt/wt* 

Tetra 

Penta 

Hexa 

Hepta 

38-42% 

55 – 65% 

5% 

2.7 – 4.5% 

Hexa 

Hepta 

Octa 

Nona 

Deca 

0.2 – 10% 

13 – 44% 

19 – 41% 

1 – 12% 

1.3 – 50% 

*Concentrations of c. decaBDE post 1995 expected to be aligned to OECD voluntary scheme. 

Deca 

Nona/Octa 

>97% 

<3% 

While  the  c-pentaBDE  and  c-octaBDE  were  banned  in  2004,  the  use  of  c-decaBDE  was 
permitted  to  continue.  The  concerns  eluded  to  regarding  environmental  and  human  health 
effects  of  lower  order  PBDE  homologue  groups  were  also  identified  in  the  OECD  risk 
assessment, published in 1994. The discussions around the perceived risks, lead to a global 
voluntary  agreement  by  manufacturers  in  1995  not  to  produce  other  PBDEs  than  those 
already on the market and stricter control over the homologues used in commercial mixtures. 
For C-decaBDE this included an agreement that c-decaBDE should not contain less than 97% 
w/w of the decaBDE homologue. 

Subsequently  a  growing  weight  of  evidence  has  continued  to  develop  around  the 
environmental and health effects  of decaBDE, in particularly its capacity  to  degrade  within 
the environment to form lower order homologue groups through a process of debromination. 
Following  a  nomination  by  Norway  (in  2013)  decaBDE  was  added  to  the  Stockholm 
Convention  under  Annex  A  (banned)  at  the  COP-8  in  2017.  In  the  Union,  decaBDE  was 
added to  the candidate list  for substances of very high concern  (SVHC) under the REACH 
Regulation  in  December  2012.  In  2014  the  Norwegian  Environment  Agency  submitted  a 
proposal for decaBDE to be added to Annex XVII of REACH (Restriction). In February 2017 
decaBDE  was  added  to  Annex  XVII  of  REACH  (by  Commission  Regulation  (EU) 
2017/227). This restriction prohibited the substance decaBDE from being used at greater than 
0.1%  w/w  in  the  manufacture  of  or  placing  on  the  market  in  another  substance  as  a 
constituent, a mixture, or an article or any part thereof after 2 March 2019. Finally, decaBDE 
was listed in the POPs Regulation in 2019, which further restricts the use in the Union in line 
with  the  Stockholm  Convention  and  replaces  the  restriction  in  Annex  XVII  of  REACH. 
Additionally the POPs Regulation sets targets for critical thresholds of PBDEs within wastes. 
This includes the aim to lower the critical threshold (Annex IV) within two years from entry 
into force from 1000 mg/kg to 500 mg/kg. 

Further information on the homologues tetra and penta, hexa and hepta, and decaBDE (POP 
PBDEs) as added to the Stockholm Convention is provided in the following sub-sections. 

66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.2.3.  Tetrabromodiphenyl ether and pentabromodiphenyl ether  

Tetrabromodiphenyl  ether  (tetraBDE)  and  pentabromodiphenyl  ether  (pentaBDE)  were  the 
main homologue groups found in C-PentaBDE. Since 1997, tetraBDE and pentaBDE have no 
longer been produced in the Union (ESWI 2011) but they continued to be used for some time 
after this in certain articles. 

As indicated the use and placing on the market of c-pentaBDE was banned in the Union from 
2004.  Furthermore,  the  RoHS  Directive  2011/65/EC,  inter  alia  restricts  the  use  of  POP-
PBDEs in electrical and electronic equipment (EEE). The maximum concentration values in 
new EEE is 0.1% by weight (1,000 ppm) in homogeneous material and applies to the sum of 
PBDE congeners. Note, however, under Annex IV of RoHS, one exemption was granted for 
spare parts.  

Further, relevant legal documents on Union level addressing PBDE is the Water Framework 
Directive 2000/60/EC and the E-PRTR Regulation (EC) No 2006/166. An annually averaged 
EQS for inland surface waters has been established for the sum of PBDE congeners of 0.0005 
µg/L and 0.0002 µg/L for other surface waters. 

WHO  (1994)  estimates  that  total  Union  manufacture  and  consumption  of  PBDEs  (all 
commercial mixtures) was around 10,000-11,000 tonnes per annum in 1989. The Union risk 
assessment  report  (2001)  comments  that  approximately  10%  (1,000  –  1,100  tonnes)  of  this 
was  c-pentaBDE,  usage  rates  of  c-penta  BDE  began  to  decline  from  the  mid-to-late  1990s, 
with quoted usage rates for 2000 (300 tonnes) and 2001 (150 tonnes) indicating the use in the 
early 2000s had declined significantly before use ceased in 2004. 

The most common use of c-pentaBDE in the Union was in flexible polyurethane foam (95%) 
that was mainly used for upholstery and automotive applications, thus applications with long 
expected  lifetimes  of  10  –  20  years.  For  these  two  sectors  the  overall  discharge  of  c-
pentaBDE  was  estimated  by  ESWI  2011  to  be  355  t/y  with  an  overall  distribution  of  the 
discharge of ~6% (21 t/y) as emissions and ~94% (334 t/y) for waste.  

In 2013 the Ireland EPA had collected 50 samples from 22 end of life vehicles, which were 
tested  for  POP-PBDEs.  Samples  were  taken  from  dashboards,  headrests,  seats,  door  panels 
and bumpers138. A further study by the United Kingdom (2016)139 analysed plastic and foam 
from an automated treatment facility (ATF) based on 30 samples based on vehicles and white 
goods  processed  at  the  facility  (samples  were  taken  from  final  processed  materials)  POP-
PBDE concentrations detected in the Irish and UK studies are listed in Table 8. 

138  Ireland (2018) National implementation plan. 
139  Defra  (2016)  ‘A  Further  update  of  the  UK’s  POPs  multi-media  emission  inventory  –  Work  Package  3: 

‘Analysis of PBDEs from end of life vehicles’, ref CB0489 

67 

 
 
 
 
 
                                                           
Table 8  Results of analysis for POP-PBDE congeners from ELVs and white goods in 

Irish (2015) and UK (2016) studies  

PBDEs 

TetraBDE 

PentaBDE 

HexaBDE 

HeptaBDE 

DecaBDE 

Concentration range 
(mg/kg) Ireland EPA 
(2015) based on ELVs 

Concentration range in 
(mg/kg) UK (2016) 
based on ELVs and 
white goods - Plastics 

Concentration range in 
(mg/kg) UK (2016) 
based on ELVs and 
white goods - Foams 

1.2 - 370 

1.6 - 130 

0.2 - 16.7 

- 

100 - 200 

0.1 - 1.2 

0.1 - 1.4 

0.06 - 3.4 

0.1 - 14 

30 - 260 

0.5 - 9.6 

0.6 - 17 

0.05 - 3 

0.2 - 0.7 

30 - 110 

As for automotive applications, assuming a lifetime of 12 years and a phase out in 2000, the 
majority  of  c-pentaBDE  in  automotive  applications  should  already  have  entered  the  waste 
stream. However, there may be some variability across the Union, for example, in Bulgaria 
over 57% of cars are over 15 years old. ESWI (2011) estimated the amount of  c-pentaBDE 
present in automotive applications in the Union at 28 t in 2015. As for waste, ESWI estimated 
that of the 243.3 t of c-pentaBDE present in automotive waste in 2010, ~98.5 t was landfilled, 
incinerated without energy recovery, ~17 t was incinerated with energy recovery and ~ 29.0 t 
was recycled.  

Additional  information  provided  by  Germany  to  support  the  Stockholm  Convention 
suggested  that  the  stockpile  of  vehicles  manufactured  prior  to  2000  will  decline  gradually 
with  a  significant  proportion  of  the  waste  from  end-of-life  vehicles  being  incinerated.  The 
reuse  of  car  parts  in  Germany  is  thought  to  be  minimal  and  no  recycling  facilities  were 
identified where potentially POP containing material can enter into newly formed products. 
Estimates of the mass flow of POP-PBDEs in the waste stream from the automotive industry 
in 2010 were 1096 kg for tetraBDE and 2109 kg for pentaBDE. Emissions resulting from this 
mass flow were estimated to be 69 kg and 127 kg for petraBDE and pentaBDE, respectively. 

The accumulated amount of c-pentaBDE in upholstery applications for 2014 is estimated at 
0 t, however in 2010 it was estimated to have been 321 t. The ESWI (2011) report stated that 
the upholstery sector  contributed about  97 t/y,  with  approximately 91.3 t  of  c-pentaBDE in 
upholstery applications estimated to have been treated in the Union in 2010. The c-pentaBDE 
entering  the  waste  stream  in  2010  was  landfilled  (~61.3  t),  incinerated  without  energy 
recovery (~18.4 t) and incinerated with energy recovery (~11.6 t). With an assumed lifetime 
of 10 years all c-pentaBDE in upholstery applications should have already entered the waste 
stream (by 2014). 

Additional  information  provided  by  Germany  to  support  the  Stockholm  Convention 
confirmed that 2004 was considered the latest time that POP-PBDEs would have been used in 
products. The mass flow of POP-PBDEs in EEE in the waste stream in 2010 were estimated 
to be 1.4 t, 2.2 t and 13.4 t for pentaBDE, hexaBDE and heptaBDE, respectively. 

As regards the relevant exports, no further information is available. 

68 

 
 
 
 
3.2.4.  Hexabromodiphenyl ether and heptabromodiphenyl ether 

Hexabromodiphenyl  ether  (hexaBDE)  and  heptabromodiphenyl  ether  (heptaBDE)  are  the 
main  homologue  groups  of  c-octaBDE.  Manufacture  of  these  substances  has  ceased  within 
the Union in 1996/98. 

WHO  (1994)  estimates  that  total  Union  manufacture  and  consumption  of  PBDEs  (all 
commercial  mixtures)  was  around  10,000-11,000  t  per  annum  in  1989.  The  Union  risk 
assessment  report  (2003)  comments  that  approximately  15%  (1,500  –  1,650  tonnes)  of  this 
was c-octaBDE, usage rates of c-octaBDE began to decline from the mid-to-late 1990s, with 
quoted  usage  rates  for  2001  (610  t)  indicating  the  use  in  the  early  2000s  had  declined 
significantly before use ceased in 2004. 

The  main  historical  use  of  c-octaBDE  was  as  a  flame  retardant  in  Acrylonitrilebutadiene-
styrene (ABS) polymers with a concentration between 10-18% by weight (95% of its use in 
the Union compared to 70% globally). ABS in turn was mainly used for housing of electrical 
and  electronic  equipment  (EEE),  typically  office  equipment  and  business  machines. 
Throughout  the  90’s  c-octaBDE  in  ABS  was  increasingly  replaced  by  alternative  flame 
retardants such as Tetrabromobisphenol A. There was also a shift from ABS (1990s) towards 
PC/ABS and HIPS for outer casings.  

Additional  information  provided  by  Germany  to  support  the  SC  provided  estimates  of  the 
mass flow of POP-PBDEs in the waste stream from the automotive industry in 2010. These 
were  479  kg  for  heptaBDE  and  1208  kg  for  hexaBDE.  Emissions  resulting  from  this  mass 
flow were estimated to be 23 kg and 32 kg for heptaBDE and hexaBDE, respectively. 

The  placing  on  the  market  of  electrical  and  electronic  equipment  containing  c-octaBDE  is 
regulated  under  the  RoHS  Directive  (2011/65/EU).  Again,  as  with  the  other  PBDEs  one 
exemption was granted under Annex IV of RoHS for spare parts. 

The  annual  amount  of  c-octaBDE  mainly  from  electronics  entering  the  environment  in  the 
Union was estimated by ESWI (2011) to be approximately 131 t in 2010, of which 128 t are 
contained in end-of-life equipment (corresponding to ~8 t/y of pentaBDE, ~8 t/y of hexaBDE 
and ~45 t/y of heptaBDE) and 3 t are emitted directly from the products. According to one 
scenario  included  in  the  ESWI  study,  out  of  these  128  t  of  c-pentaBDE  wastes,  66  t  were 
incinerated, 40 t were landfilled and 23 t recycled.  

A  significant  amount  of  used  and  end-of-life  electrical  and  electronic  equipment  (EEE)  is 
being illegally exported from the Union, most of it being declared as still functioning EEE. 
For  instance,  a  study  published  by  the  German  UBA  and  German  Federal  Ministry  for 
Environment, Nature Conservation and Nuclear Safety indicates that in 2008 between 93,000 
t  and  216,000  t  of  used  and/or  end-of-life  EEE  were  exported  from  the  port  of  Hamburg 
(Germany)  to  non-European  destinations.  Other  studies  carried  out  in  Ghana  and  Nigeria  – 
two of the main destinations of these exports where approximately 85% of the EEE imports 
originate  from  the  Union  –  suggest  that  a  significant  portion  of  these  products  are  either 
repaired locally and reused as second-hand-products (70%) or directly recycled by informal 
scrap metal workers (30%). In both cases, end-of-life management is largely unregulated and 
frequently makes use of open fires to liberate copper from wire insulation or to reduce plastic 

69 

 
 
waste  volumes,  generating  significant  amounts  of  POPs  (Prakash  and  Manhart  2010140; 
Manhart et al. 2011141; Schluep et al. 2011142). 

In  the  Union,  there  are  indications  that  only  a  few  full  scale  e-waste  recycling  facilities 
separate plastics containing PBDE as required by Union legislation. For instance, one facility 
with  automatic  separation  step  for  WEEE  plastic  containing  halogens,including  brominated 
flame  retardants  (BFRs)  is  known  in  Switzerland  (UNEP  2011143).  Based  on  consultation 
with  the  European  Electronics  Recyclers  Association  (EERA)  in  2018,  it  is  estimated  that 
there were approximately 30 specialised WEEE plastic recyclers in the EU144. This suggests 
that there is capacity to manage the flow of waste but that also the market is relatively small 
and specialised. 

Furthermore, thermoplastics (i.e. mainly  outer  casings) separated from  WEEE is  also  being 
exported  on  a  regular  basis,  where  it  is  used  as  recyclate  for  the  plastics  industry,  which 
might  in  some  cases  lead  to  cross-contamination  of  products  and  thus  unintentional  POPs-
manufacture through improper end-of-life treatment of these products (Manhart 2012145).  

Also,  screening  of  plastic  products  in  China  has  revealed  that  even  sensitive  uses  like 
children  toys  (Chen  2009146)  along  with  household  goods  (Chen  2010147)  can  be 
contaminated  with  PBDE  and  other  BFRs.  The  PBDE  concentrations  in  electrical  or 
electronic toys were below the threshold limit (1000 ppm) required by Directive 2011/65/EU 
on  the  restriction  of  the  use  of  certain  hazardous  substances  in  electrical  and  electronic 
equipment  (RoHS),  except  for  one  hard  plastic  toy  with  a  total  PBDE  concentration  of  5.3 
mg/g.  Human  exposure  from  the  presence  of  POP-PBDEs  in  household  products  from  the 
Pearl River Delta region of South China was estimated to be low when compared to exposure 
via the inhalation of indoor air. 
BSEF  (2020)148  estimated  that  55%  of  WEEE  plastics  entering  WEEE  plastic  recycling 
facilities will be converted to regranulates for use as raw material in recycled plastic.  

140  Prakash,  S.;  Manhart,  A.:  Socio-economic  assessment  and  feasibility  study  on  sustainable  e-waste 

management in Ghana. Öko-Institut e.V., Freiburg, 2010. 

141  Manhart,  A.;  Osibanjo,  O.;  Aderinto,  A.;  Prakash,  S.:  Informal  e-waste  management  in  Lagos,  Nigeria  – 
socio-economic impacts and feasibility of international recycling co-operations. Lagos & Freiburg, 2011. 
142  Schluep,  M.;  Manhart,  A.;  Osibanjo,  O.;  Rochat,  D.;  Isarin,  N.;  Müller,  E.:  Where  are  WEee  in  Africa? 

Findings from the Basel Convention E-Waste Africa Programme. Geneva, 2011. 

143  In  the  “Technical  Review  of  the  Implications  of  Recycling  Commercial  Pentabromodiphenyl  Ether  and 
Commercial  Octabromodiphenyl  Ether”  for  the  POP  Reviewing  Committee  (UNEP/POPs/POPRC.6/2  and 
UNEP/POPs/POPRC.6/INF/6)  such  information  has  been  compiled  including  information  on  facilities 
operated. 

144 Ramboll, 2019, ‘Study to support the review of waste related issues in Annex IV and V of regulation (EC) 

850/2004’, Commission study under contract ref 07.0201/2017/767748/ETU/ENV.B.3. 

145  Personal Communication, 24.2.2012 with Andreas Manhart – EEE expert. 
146  Chen  S.-J.,  Ma  Y.-J.,  Wang  J.,  Chen  D,  Luo,  X.-J.  Mai,  B.-X.  (2009).  Brominated  Flame  Retardants  in 
Children's  Toys:  Concentration,  Composition,  and  Children's  Exposure  and  Risk  Assessment.  Environ  Sci 
Technol 43(11): 4200- 4206 

147  Chen, S.-J., Ma, Y.-J., Wang, J., Tian, M., Luo, X.-J., Chen, D. Mai, B.-X. (2010). Measurement and human 
exposure  assessment  of  brominated  flame  retardants  in  household  products  from  South  China.  Journal  of 
Hazardous Materials 176(1-3): 979-984 

148  BSEF,  2020,  ‘study  on  the  impacts  of  brominated  flame  retardants  on  the  recycling  of  WEEE  plastics  in 

Europe’, industry study. 

70 

 
 
 
                                                           
3.2.5.  Decabromodiphenyl ether 

Decabromodiphenyl  ether  (decaBDE)  is  the  main  homologue  of  c-decaBDE.  The  REACH 
Annex  XV  restriction  proposal  (2014)149  comments  that  from  the  1990s  there  were  nine 
major manufacturers of c-decaBDE globally (including three in the Union – The Netherlands, 
France and the United Kingdom), however, that manufacture ceased by 1999, after which the 
Union  continued  to  import  mixtures  and  articles  containing  c-decaBDE.  Earnshaw  et  al. 
(2013)150  comments  that  between  1970  –  2010  around  185,000  –  250,000  tonnes  of  c-
decaBDE was placed on the market in the Union (from manufacture and import), with peak 
consumption at 9,000 t per annum (based on data from BSEF) in the late 1990s.  
The US EPA (2010)151 gave notice that remaining manufacturers of c-decaBDE would cease 
manufacture by 2012, with the only remaining manufacture continuing in China and Japan. 
Xiang  et  al  (2007)152  comment  that  manufacture  of  c-decaBDE  within  China  was  around 
25,000 tonnes per annum in 2004. While manufacture in Japan was estimated at 600 tonnes 
per annum in 2013, with an import of a further 1,000 tonnes for use in vehicle seats (60%), 
construction materials (19%) and textiles (15%).  

The Union risk assessment reports (2001 and 2003) comment that 75% of Union manufacture 
and consumption of all commercial PBDEs was c-decaBDE (7,500 – 8,250 t per annum) in 
1989,  with  consumption  continuing  to  increase  in  the  1990s.  The  REACH  Annex  XV 
restriction proposal (2014) comments that after manufacture ceased in 1999 the import of C-
decaBDE declined from rates of between 9,000 – 11,000 tonnes per annum in 1999 (based on 
data from BSEF and Eurostat respectively) down to 3,600 t per annum in 2012, with a further 
400 tonnes of c-decaBDE within imported articles.  

Earnshaw et al (2013) comment that approximately 75% of C-decaBDE use would have been 
for polymer applications such as plastics (80% electrical goods, 20% non-electrical), with the 
remaining  25%  of  usage  applied  to  textiles  and  foams.  The  REACH  Annex  XV  restriction 
proposal  (2014)  comments  that  in  2002  around  80%  of  all  c-decaBDE  use  in  Europe  had 
been for polymer applications, particularly plastics for electrical applications (based on data 
from  the  2002  risk  assessment  report  (RAR)),  however,  strong  efforts  to  phase-out  C-
decaBDE  from  plastics  commencing  in  the  mid  2000s  meant  that  by  2012  use  was  more 
evenly split (52% textiles, 48% plastics) (based on data from VECAP). 

The  REACH  Annex  XV  restriction  proposal  (2014)  highlights  the  in-use  service  life  is  the 
main phase for emissions to environment (87%) with manufacture (7%) and waste (6%) the 
other  key  points  of  release.  Harrad  et  al.  (2015)153  highlights  in  particular  the  potential  for 
release to indoor environments from dust contaminated with decaBDE through contact with 
treated  soft  furnishings  and  plastics.  Ambient  monitoring  of  indoor  and  outdoor  decaBDE 
concentrations  in  air  for  the  UK  highlighted  these  significant  differences,  with  indoor 

149  REACH, 2014. REACH Annex XV dossier for DecaBDE. 
150  Earnshaw,  M.  R.;  Jones,  K.  C.;  Sweetman,  A.  J.  (2013)  Estimating  European  historical  production, 
consumption and atmospheric emissions of decabromodiphenyl ether. Sci. Total Environ. 447, 133−142. 

151  USEPA, 2010.  An exposure assessment of polybrominated diphenyl ethers. 
152  Xiang, C.-H.et al., 2007. Polybrominated diphenyl ethers in biota and sediments of the Pearl River, Estuary, 

South China. Environmental Toxicology Chemistry, 26(4), pp. 616-623. 

153  Harrad,  S.  2015.  A  meta-analysis  of  recent  data  on  UK  environmental  levels  of  POP-BFRs  in  an 
international  context:  Temporal  trends  and  an  environmental  budget.  Emerging  Contaminants  1:  39-53. 
doi:10.1016/j.emcon.2015.08.001. 

71 

 
 
                                                           
concentrations ranging from 48 – 4,000 pg/m3 and outdoor concentrations ranging from non-
dectable to 1,500 pg/m3 in urban environments. 

The  REACH  Annex  XV  restriction  proposal  (2014)  followed  the  OECD  methodology  for 
emission scenarios and previous Union  assessments  from  2002, 2004 and 2007 to calculate 
potential  annual  emissions  of  decaBDE  against  assumed  stockpiles  and  consumption  rates. 
For  2014,  the  REACH  Annex  XV  restriction  proposal  estimates  annual  releases  of  1.46 
tonnes to air, 2.32 t to water and 0.96 t to soil (total annual release of 4.74 t per annum). As 
an alternative estimate Earnshaw et al. (2013) used a life-cycle source-flow approach to map 
use of C-decaBDE with releases during, manufacture, and waste. Figure 2 provides an outline 
of emission pathways over time showing both the increase in emissions as use of C-decaBDE 
increased and then a decline from 2000 onwards as use also declined. 

Figure 2 

DecaBDE  emissions  to  European  environment  under  the  realistic  scenario 
ERealistic (Earnshaw et al. 2013) 

Earnshaw et al. (2013) highlights the atmospheric pathway as dominant,  while the REACH 
Annex XV restriction proposal highlights water as the dominant pathway. However, review 
of  both  references  highlights  the  importance  of  indoor  dusts  and  exposure.  Washing  of 
textiles  is  identified  as  a  key  pathway  to  transfer  indoor  atmospheric  emissions  to  the 
hydrosphere  as  releases  to  sewer  and  ultimate  loss  to  environment  from  urban  waste  water 
treatment  works.  Earnshaw  et  al.  (2013)  also  highlights  the  importance  of  sewage  sludge 
disposal  to  agricultural  land  as  a  major  pathway  for  environmental  release  of  decaBDE  to 
soil. 

72 

 
 
 
 
 
 
 
Waste handling is also highlighted as potential emission source, particularly the management 
of contaminated dusts during the breaking of electrical goods. Morf (2007)154 comments on a 
study  in  Switzerland  where  samples  from  a  plant  processing  small  sized  WEEE  detected 
concentrations of decaBDE at 510 mg/kg. Whiting et al. (2016)155 comments on a sampling 
study  at  an  Automotive  Shredder  Residue  (ASR)  plant  in  the  UK  managing  end  of  life 
vehicles  and  white  goods.  Pelletised  plastics  produced  at  the  ASR  had  concentrations  of 
decaBDE ranging from 30 – 270 mg/kg. 

Earnshaw  et  al  (2013)  comments  that  the  in-use  stocks  of  decaBDE  peaked  at  around 
75,000 tonnes  in  2000.  Assuming  a  service  life  of  10  years,  and  phase-out  by  2019  would 
mean final in-use stockpiles entering the waste stream in the late 2020s. Assuming a longer 
lifecycle of 15 years would mean final phase-out by the mid-2030s.  

The REACH Annex XV restriction proposal also states that much of the material entering the 
waste  stream  may  end  up  in  landfill,  meaning  that  environmental  burden  may  be  extended 
well beyond 2030.  
Ramboll  (2019)156  estimate  that,  as  of  2015,  1.2  million  tonnes  of  plastics  from  waste 
electrical  and  electronic  equipment  was  generated,  containing  630  tonnes  of  decaBDE 
(estimated  average  concentration  of  525  mg/kg).  For  those  plastics  containing  decaBDE, 
Ramboll (2019) go on to estimate that 534.5 tonnes (84%) (519t high bromine fraction, 15.5t 
other bromine fractions) are destroyed via incineration. A further 89 tonnes (14%) is recycled 
and 6.5 tonnes (2%) is consigned to landfill. 

It  is  important  to  note  that  decaBDE  used  within  plastics  for  electrical  applications  will  go 
through  a  designated  waste  stream  compliant  with  the  waste  electrical  and  electronic 
equipment  Directive  (WEEE  Directive,  2012/19/EU).  DecaBDE  was  also  used  for  textiles 
and  soft-furnishings,  particularly  the  treatment  of  back-coatings,  Ramboll  (2019)  estimate 
that about 10% of total decaBDE use was used in these applications.  

The management of bulky soft furnishings such as sofas, armchairs, mattresses, carpets, other 
commercial  seating  and  soft  furnishings  (such  as  heavy  curtains  and  drapes  from  public 
buildings,  cinemas,  schools,  etc)  may  be  an  area  where  the  detection  and  management  of 
decaBDE  is  weaker  as  it  falls  within  general  muncipal  waste  streams.  Ramboll  (2019) 
comment  that  use  of  decaBDE  was  largely  phased-out  in  the  Union  by  2014,  with  the 
assumed  lifespan  of  the  treated  articles  ranging  from  10-15  years.  This  means  that  final 
phase-out and entry of decaBDE in textiles/soft furnishings to the waste stream would occur 
by the mid-late 2020s and mid 2030s.  
Drage et al. (2018)157 document a sampling survey of waste handling for soft furnishings in 
Ireland in 2018 (covering 122 samples), with mean avearage concentrations varying from 3.7 
mg/kg (curtains) to 6,800 mg/kg (fabric coverings used in sofas and armchairs). Drage et al. 

154  Morf, 2007, ‘Dynamic Substance Flow Analysis Model for Selected Brominated Flame Retardants as a Base 

for Decision Making on Risk Reduction Measures (FABRO)’ 

155  Whiting et al. 2016 Annual Defra Report: A Further Update of the UK’s Persistent Organic Pollutants Multi-

media Emissions Inventory.  

156  Ramboll, 2019, ‘Study to support the review of waste related issues in annexes IV and V of Regulation EC 

850/2004, Report for the European Commission Project No. 352000134  

157  Drage  et  al.  2018.  ‘Brominated  flame  retardants  in  Irish  waste  polymers:  concentrations,  legislative 

compliance, and treatment options’ Science of the total environment, vol 625 pp 1535-1543 

73 

 
 
                                                           
(2018)  comment  that  decaBDE  was  detected  in  75  out  of  122  samples  analysed  with  10 
samples exceeding the current low POP content threshold (1000 mg/kg).   

Based  on  the  results  of  the  sampling  survey  and  national  statistics  for  Ireland,  Drage  et  al. 
(2018) estimate that annually 15 tonnes of decaBDE enter the waste stream from the textiles 
and  soft-furnishings.  Ramboll  (2019)  provide  some  further  comment  on  final  destinattion, 
stating that at Union level, 25% of treated textiles are destroyed by incineration, with 75% of 
treated textiles consigned to  landfill. The Ramboll study assumes no recycling of decaBDE 
treated textiles from the soft furnishings sector. 

3.2.6.  Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds 

PFOA  and  its  salts  are  most  widely  used  as  processing  aids  in  the  production  of 
fluoroelastomers and fluoropolymers. PFOA-related compounds have historically been used 
as  surfactants  and  surface  treatment  agents  (e.g.,  in  textiles,  paper  and  paints,  fire-fighting 
foams)  and  for  the  manufacture  of  side-chain  fluorinated  polymers.  PFOA,  its  salts  and 
PFOA-related compounds are used in a wide variety of applications and consumer products 
across many sectors (see UNEP/POPS/POPRC.12/11/ Add.2).  

Releases  occur  from  past  and  ongoing  production,  use  and  disposal.  Direct  releases  to  the 
environment occur from the production of the raw substances, during the processing, use and 
disposal  of  the  chemical,  and  from  treated  articles  and  from  products  contaminated  with 
PFOA  (see  UNEP/POPS/POPRC.13/3).  Main  emission  vectors  of  PFOA  and  its  salts  are 
expected to be from wastewater and particles/aerosols. 

the  ECHA  Member  State  Committee, 

In  2013, 
identified  PFOA  as  persistent, 
bioaccumulative and toxic substance (‘PBT’) in accordance with REACH Article 57(d) and 
classified as toxic for reproduction category 1B in accordance with the CLP.158 Subsequently, 
ECHA made the decision to include PFOA in the Candidate List of Substances of Very High 
Concern (‘SVHC’) for possible inclusion in Annex XIV to Regulation (EC) No 1907/2006.159 

In  2017,  PFOA  its  salts and  PFOA-related  substances160  were  added  to  Annex  XVII  of  the 
REACH  Regulation  (EC)  No  1907/2006161.  However,  that  listing  in  Annex  XVII  was 
removed in 2020 by Commission Regulation (EU) 2020/2096162 after the listing of PFOA in 
the POPs Regulation for reasons of legal clarity. 

PFOA  was  also  previously  included  in  Annex  VI  of  the  Classification,  Labelling  and 
Packaging  (CLP)  Regulation  (Regulation  (EC)  No  1272/2008),  by  the  Commission 
Regulation (EU) No 944/2013 of 2 October 2013 (index number: 607-704-00-2). PFOA has 

158  See https://echa.europa.eu/documents/10162/8059e342-1092-410f-bd85-80118a5526f5 
159  See https://echa.europa.eu/documents/10162/8059e342-1092-410f-bd85-80118a5526f5 
160  Any related substance (including its salts and polymers) having a linear or branched perfluoroheptyl group 
with  the  formula  C7F15-  directly  attached  to  another  carbon  atom,  as  one  of  the  structural  elements;  Any 
related substance (including its salts and polymers) having a linear or branched perfluorooctyl group with the 
formula C8F17- as one of the structural elements. 

161  Commission  Regulation  (EU)  2017/1000  amending  Annex  XVII  to  Regulation  (EC)  No  1907/2006 of  the 
European Parliament and of the Council concerning REACH as regards perfluorooctanoic acid (PFOA), its 
salts 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32017R1000). 

PFOA-related 

substances 

(see 

and 

162  Commission Regulation (EU) 2020/2096 of 15 December 2020 (OJ L 425, 16.12.2020, p. 3). 

74 

 
 
  
                                                           
as  
classified 
been 
Carc.  2  H351,  Repr.  1B  H360D,  Lact  H362,  STOT  RE  1  (liver)  H372,  Acute  tox  4  H332,  
Acute tox 4 H302 and Eye dam 1 H318.  

In 2015, the Union submitted a proposal to list PFOA, its salts and PFOA-related compounds 
in Annexes A, B, and/or C to the Stockholm Convention (UNEP/POPS/POPRC.11/5). At its 
twelfth meeting in 2016, the POPRC concluded that PFOA fulfilled the screening criteria in 
Annex D of the Convention (i.e., persistent, bioaccumulative and toxic to animals including 
humans). The POPRC recommended that PFOA, its salts and PFOA-related compounds that 
degrade to PFOA are likely, as a result of their long-range environmental transport, to lead to 
significant  adverse  human  health  and/or  environmental  effects  such  that  global  action  is 
warranted (UNEP/POPS/POPRC.12/11 /Add.2).  

salts 

At the COP-9 meeting in May 2019, based on a consideration of the risk profile163, the risk 
management evaluation164 and the addendum to the risk management evaluation165 for PFOA, 
decision 
compounds, 
its 
(UNEP/POPS/COP.9/CRP.14),  to  list  PFOA,  its  salts  and  PFOA-related  compounds  under 
Annex  A  of  the  Convention  with  specific  exemptions  for  its  production  and  use.  These 
specific exemptions are outlined in Table 9  . 

the  COP  made 

and  PFOA 

related 

the 

In  addition,  the  COP  added  Part  X  to  Annex  A  of  the  Convention,  specifying  that,  where 
Parties have registered for a specific exemption for use of PFOA in firefighting foams, these 
Parties shall: 

  ensure that fire-fighting foam that contains or may contain PFOA, its salts and PFOA-
related  compounds  shall  not  be  exported  or  imported  except  for  the  purpose  of 
environmentally sound disposal. 

  not  use  fire-fighting  foam  that  contains  or  may  contain  PFOA,  its  salts  and  PFOA-

related compounds for training 

  not  use  fire-fighting  foam  that  contains  or  may  contain  PFOA,  its  salts  and  PFOA-

related compounds for testing unless all releases are contained. 

  by the end of 2022, if it has the capacity to do so, but no later than 2025, restrict uses 
of fire-fighting foam that contains or may contain PFOA, its salts and PFOA-related 
compounds to sites where all releases can be contained. 

  make determined efforts designed to lead to the environmentally sound management 

of fire-fighting foam stockpiles and wastes that contain or may contain PFOA. 

On  the  use  of  perfluorooctyl  iodide  for  the  production  of  perfluorooctyl  bromide  for  the 
purpose of producing pharmaceutical products, the COP agreed to review at COP-13 and at 
every  second  ordinary  meeting  thereafter  the  continued  need  for  this  specific  exemption, 
which shall in any case expire at the latest in 2036. 

163 UNEP/POPS/POPRC.12/11/Add.2 
164 UNEP/POPS/POPRC.13/7/Add.2 
165 UNEP/POPS/POPRC.14/6/Add.2 

75 

 
 
 
                                                           
Table 9  Amended text of Part I of Annex A to the Stockholm Convention listing 
PFOA, its salts and PFOA-related compounds, and specific exemptions 

Chemical  

Activity 

Specific exemption 

Perfluorooctanoic acid (PFOA), its 
salts and PFOA-related compounds 

Production  

Use 

“Perfluorooctanoic acid (PFOA), its 
salts and PFOA-related compounds” 
means the following: 

(i)  Perfluorooctanoic acid (PFOA; 
CAS No. 335-67-1), including 
any of its branched isomers. 

(ii)  Its salts.  

(iii)  PFOA-related compounds 

which, for the purposes of the 
Convention, are any substances 
that degrade to PFOA, including 
any substances (including salts 
and polymers) having a linear or 
branched perfluoroheptyl group 
with the moiety (C7F15) C as one 
of the structural elements. 

The following compounds are not 
included as PFOA-related compounds: 

(i)  C8F17-X, where X= F, Cl, Br. 

(ii)  Fluoropolymers that are covered 
by CF3[CF2]n-R’, where R’=any 
group, n>16. 

(iii)  Perfluoroalkyl carboxylic and 

phosphonic acids (including 
their salts, esters, halides, and 
anhydrides) with ≥8 
perfluorinated carbons.  

(iv)  Perfluoroalkane sulfonic acids 

(including their salts, esters, 
halides, and anhydrides) with ≥9 
perfluorinated carbons.   

(v)  Perfluorooctane sulfonic acid 

(PFOS), its salts and 
perfluorooctane sulfonyl 
fluoride (PFOSF), as listed in 
Annex B to the Convention. 

  Fire-fighting foam: None 
  For other production, as allowed for the 

Parties listed in the Register in accordance 
with the provisions of part X of this Annex  
In accordance with the provisions of part X of this 
Annex: 

  Photolithography or etch processes in 

semiconductor manufacturing. 

  Photographic coatings applied to films. 
  Textiles for oil- and water-repellency for the 
protection of workers from dangerous liquids 
that comprise risks to their health and safety.  
 
Invasive and implantable medical devices 
  Fire-fighting foam for liquid fuel vapour 
suppression and liquid fuel fires (Class B 
fires) in installed systems, including both 
mobile and fixed systems, in accordance with 
paragraph 2 of part X of this Annex. 
  Use of perfluorooctyl iodide for the 

production of perfluorooctyl bromide for the 
purpose of producing pharmaceutical 
products, in accordance with the provisions of 
paragraph 3 of part X of this Annex. 
  Manufacture of polytetrafluoroethylene 

(PTFE) and polyvinylidene fluoride (PVDF) 
for the production of: 

o  High-performance, corrosion-resistant gas 
filter membranes, water filter membranes 
and membranes for medical textiles 

o  Industrial waste heat exchanger equipment 

o  Industrial sealants capable of preventing 

leakage of volatile organic compounds and 
PM2.5 particulates. 

  Manufacture of polyfluoroethylene propylene 
(FEP) for the production of high-voltage 
electrical wire and cables for power 
transmission 

  Manufacture of fluoroelastomers for the 
production of O-rings, v-belt and plastic 
accessories for car interiors 

76 

 
 
 
 
 
 
The listing of PFOA under the Stockholm Convention has been implemented in the Union by 
adding  PFOA,  its  salts  and  PFOA-related  compounds  to  Annex  I  of  the  POPs  Regulation 
through  Commission  Delegated  Regulation  (EU)  2020/784166.  The  listing  in  the  POPs 
Regulation  is  more  restrictive  than  the  listing  under  the  Stockholm  Convention,  however, 
some uses that cannot be phased-out immediately benefit from an exemption. 

Furthermore,  in  March  2018,  EFSA’s  panel  on  contamination  of  food  (CONTAM)  revised 
the tolerable weekly intake for both PFOA and PFOS167. The panel commented that there was 
still  insufficient  data  on  concentrations  within  food  but  toxicological  data  was  sufficient  to 
lower the values. For PFOA the original limits  set  in  2008 of 1500 ng/kg bw per day (214 
ng/kg bw per week) were proposed to be lowered to 13 ng/kg bw per week. 

3.2.7.  Perfluorooctane  sulfonic  acid  (PFOS),  its  salts  and  perfluorooctane  sulfonyl 

fluoride 

Perfluorooctane  sulfonate  is  a  fully  fluorinated  anion,  which  is  commonly  used  as  a  salt  or 
incorporated into larger polymers.  

The use of PFOS, its salts and other derivatives has been restricted in the EU since 2008 by 
Directive 2006/122/EC168. These restrictions were later taken up in REACH Annex XVII by 
Commission  Regulation  (EC)  552/2009.  Now,  the  manufacture,  placing  on  the  market  and 
use  of  PFOS,  its  salts  and  other  derivatives  is  regulated  under  the  POPs  Regulation. 
Exemptions initially granted by the POPs Regulation were significantly less numerous than in 
the  Stockholm  Convention,  as  alternatives  were  available  for  many  of  those  uses.  The 
derogations  for  PFOS  were  given  for  manufacture  and  placing  on  the  market  for  the 
following  uses  until  26  August  2015  (a)  wetting  agents  for  use  in  controlled  electroplating 
systems;  (b)  photoresists  or  anti-reflective  coatings  for  photolithography  processes;  (c) 
photographic  coatings  applied  to  films,  papers,  or  printing  plates;  (d)  mist  suppressants  for 
non-decorative  hard  chromium  (VI)  plating  in  closed  loop  systems;  (e)  hydraulic  fluids  for 
aviation. 

At  the  POPRC-14  meeting  in  September  2018,  on  the  basis  of  reviewing  an  assessment  of 
alternatives  to  PFOS169,  the  Committee  made  a  number  of  recommendations  regarding  the 
current  exemptions in place under the Stockholm Convention. Several of these relate to the 
exemptions also specified under the POPs Regulation. These recommendations include: 

166  Commission  Delegated Regulation (EU) 2020/784 of 8 April 2020 amending  Annex I to Regulation (EU) 
2019/1021 of  the  European  Parliament  and  of  the  Council  as  regards  the  listing  of  perfluorooctanoic  acid 
(PFOA), its salts and PFOA-related compounds (OJ L 188, 15.6.2020, p. 1) 

167  EFSA  (2018)  ‘Risk  to  human  health  related  to  the  presence  of  perﬂuorooctane  sulfonic  acid  and 

perﬂuorooctanoic acid in food’, opinion of the Contam panel for EFSA. 

168  Directive 2006/122/EC of the European Parliament and of the Council of 12 December 2006 amending for 
the  30th  time  Council  Directive  76/769/EEC  on  the  approximation  of  the  laws,  regulations  and 
administrative provisions of  the Member States relating to restrictions on the marketing and use of certain 
dangerous substances and preparations (perfluorooctane sulfonates);   
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:372:0032:0034:EN:PDF  

169 UNEP/POPS/POPRC.14/INF/13 

(http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC14/Overview/tabid/7398/Def
ault.aspx) 

77 

 
 
 
                                                           
  Based on the steadily declining use of PFOS, its salts and PFOSF for semiconductors 
(photo-resist  and  anti-reflective  coatings  for  semiconductors;  etching  agent  for 
compound  semiconductors  and  ceramic  filters)  and  the  commercial  availability  of 
alternatives,  the  acceptable  purpose  for  the  use  of  PFOS  for  photo-resist  and  anti-
reflective  coatings  for  semiconductors  and  as  etching  agent  for  compound 
semiconductors  and  ceramic  filters  should  no  longer  be  available  under  the 
Convention. 

  Based on the assessment and the availability of alternatives and the withdrawal of a 
number of Parties from the register of acceptable purposes, the acceptable purpose for 
the use of PFOS for aviation hydraulic fluids should no longer be available under the 
Convention. 

  Based  on  the  availability  of  alternatives  to  PFOS  for  metal  plating  (hard  metal 
plating)  only  in  closed-loop  systems  and  their  assessment,  and  the  fact  that  some 
Parties have indicated that the use of PFOS is either declining or has been completely 
phased  out,  while  others  have  indicated  a  continued  need  for  the  use  of  PFOS,  the 
Committee recommends that the use of PFOS, its salts and PFOSF for metal plating 
(hard  metal  plating)  only  in  closed-loop  systems  be  amended  from  an  acceptable 
purpose to a (time-limited) specific exemption. 

At  the  COP-9  meeting  in  April/May  2019,  based  on  a  consideration  of  the  alternatives 
assessment report on PFOS and an evaluation report on PFOS170, the COP decided to revise 
the current listing of PFOS under Annex B, part I of the Convention. This revision removes a 
substantial number of the specific exemptions or acceptable purposes, previously allowed for 
the use of PFOS (e.g. for photo imaging, for photo resist and anti-reflective coatings for semi-
conductors,  for  etching  agent  for  compound  semi-conductors  and  ceramic  filters,  in  photo 
masks in the semiconductor and liquid crystal display (LCD) industries, in metal plating, in 
electrical  and  electronic  parts  for  some  colour  printers  and  colour  copy  machines,  in 
insecticides for control of red imported fire ants and termites, in aviation hydraulic fluids, in 
chemically  driven  oil  production,  and  in  certain  medical  devices),  or  converts  previous 
acceptable  purposes  into  time-limited  specific  exemptions  (e.g.  in  fire-fighting  foams  and 
metal plating (hard metal plating) only in closed-loop systems). The revised listing in shown 
in Table 10. 

At the COP-9, the decision was also made to to amend part III of Annex B to the Convention, 
outlining  specific  requirements  for  Parties  registering  for  the  specific  exemption  on 
firefighting foams. This includes the requirement to:  

  ensure that fire-fighting foam that contains or may contain PFOS, its salts and PFOSF 
shall  not  be  exported  or  imported  except  for  the  purpose  of  environmentally  sound 
disposal;  

  not use fire-fighting foam that contains or may contain PFOS, its salts and PFOSF for 

training or testing (unless all releases are contained); 

170 UNEP/POPS/COP.9/INF/12, 

http://chm.pops.int/TheConvention/ConferenceoftheParties/Meetings/COP9/tabid/7521/Default.aspx 

78 

 
 
                                                           
 
  by the end of 2022, if it has the capacity to do so, restrict uses of fire-fighting foam 
that contains or may contain PFOS, its salts and PFOSF to sites where all releases can 
be contained;  

  make determined efforts designed to lead to the environmentally sound management 
of fire-fighting foam stockpiles and wastes that contain or may contain PFOS, its salts 
and PFOSF as soon as possible.  

Table 10  New listing of perfluorooctane sulfonic acid (CAS No. 1763-23-1), its salts and 

perfluorooctane sulfonyl fluoride (CAS No. 307-35-7) in part I of Annex B to 
the Stockholm Convention as set out in the decision SC 9/4 of the COP-9 

Chemical  

Activity 

Acceptable purpose or specific exemption 

Perfluorooctane sulfonic acid (CAS 
No. 1763-23-1), its saltsa and 
perfluorooctane sulfonyl fluoride 
(CAS No. 307-35-7) 
a For example: potassium 
perfluorooctane sulfonate (CAS 
No. 2795-39-3); lithium 
perfluorooctane sulfonate (CAS 
No. 29457-72-5); ammonium 
perfluorosulfonate (CAS No. 
29081-56-9); diethanolammonium 
perfluorooctane sulfonate (CAS 
No. 70225-14-8); 
tetraethylammonium 
perfluorooctane sulfonate (CAS 
No. 56773-42-3); 
didecyldimethylammonium 
perfluorooctane sulfonate (CAS 
No. 251099-16-8) 

Production  Acceptable purpose: 

Use 

In accordance with part III of this Annex, 
production of other chemicals to be used solely 
for the use below. Production for uses listed 
below. 
Specific exemption: 
None 

Acceptable purpose: 
In accordance with part III of this Annex for the 
following acceptable purpose, or as an 
intermediate in the production of chemicals with 
the following acceptable purpose: 
 

Insect baits with sulfluramid (CAS No. 4151-
50-2) as an active ingredient for control of 
leaf-cutting ants from Atta spp. and 
Acromyrmex spp. for agricultural use only 

Specific exemption: 
  Metal plating (hard-metal plating) only in 

closed-loop systems.  

  Fire-fighting foam for liquid fuel vapour 
suppression and liquid fuel fires (Class B 
fires) in installed systems, including both 
mobile and fixed systems, in accordance with 
paragraph 10 of part III of this Annex 

In  the  Union,  two  acceptable  purposes  listed  under  the  Convention  before  the  COP-9 
amendment  in  2019  were  reported  to  be  used  until  2018:  i)  photo  resist  and  anti-reflective 
coatings  for  semi-conductors;  ii)  metal  plating  (hard  metal  plating)  only  in  closed-loop 
systems. As of July 2019, only the use as mist suppressant for non-decorative hard chromium 
(VI)  plating  in  closed  loop  systems  is  still  allowed.  Estimates  of  use  within  the  Union  for 
2013-2015 are dominated by use in the metal plating industry (~ 4 tonnes in 2013, 7 tonnes in 
2014,  ~200  kg  in  2015),  the  photographic  industry  (several  tens  kg/year)  and  the 
semiconductor  industry.  No  Member  States  (between  2013-2015)  mentioned  its  use  in 

79 

 
 
 
 
 
hydraulic fluids in the aviation industry. Germany have reported using the most PFOS in both 
2013  and  2014,  followed  by  the  Netherlands  and  Sweden  who  have  reported  using  150 kg 
and  140  kg  in  2013,  respectively.  During  the  2013-2015  reporting  period  use  has  fallen  in 
Sweden (from 140 kg in 2013 to 25 kg in 2016), however the Netherlands have not updated 
their  reporting  since  so  current  use  is  unknown  but  it  is  expected  to  have  decreased  since 
2009  (~390  kg).  Germany  indicate  no  further  use  of  PFOS  in  2015  howevery they  are still 
producing approximtaely 9 tonnes per annum. 

After expiration of the derogation for wetting agents for the use in controlled electroplating 
systems in 2015, the only specific exemption on the use of PFOS in electroplating applies to 
‘mist  suppressants  for  non-decorative  hard  Cr(VI)  plating  in  closed  loop  systems’.  During 
hard metal plating, a significant amount of gases may be released from the process tanks. The 
generated gases rise to the surface as bubbles and form aerosols. If no mist suppressant agents 
or  other  technology  is  used,  aerosols  consisting  of  process  liquids  containing  for  instance 
chromic  acid  may  expose  workers  and  the  environment.  Therefore,  a  closed-loop  system 
needs to be utilized when using PFOS or PFOS-related substances as mist suppressants.  

In  the  Union,  it  is  obligatory  to  apply  a  closed-loop  system  when  using  PFOS-related 
substances as mist suppressants for non-decorative hard Cr(VI) metal plating. In addition, the 
Industrial  Emissions  Directive  (2010/75/EU)  is  applicable  to  installations  for  surface 
treatment  of metals  or plastic materials  using an electrolytic or  chemical  process  where the 
volume  of  the  treatment  vats  exceeds  30  m³.  These  installations  must  apply  best  available 
techniques (BAT) for the prevention and minimisation of emissions of PFOS described in the 
relevant BREF. 

The definition of a closed-loop system has been much discussed in recent years and still plays 
an  important  role  in  individual  cases  for  authorizations  of  new  projects  and  for  change  of 
authorizations  as  well  as  regarding  chromium(VI),  for  the  authorization  under  REACH. 
However, so far, there is no harmonised definition for a closed-loop system regarding PFOS 
or  Cr(VI).  A  recent  industry  survey  commissioned  by  the  German  Environment  Agency 
documented  that  there  is  a  variety  of  processing  equipment  and  many  processes  to 
manufacture for different end uses and that there is not a “one fits all” closed-loop-system for 
metal plating. 

PFOS  has  also  been  present  in  fire  fighting  foams  (90  t  in  stocks)  although  these  stocks 
should  have  been  destroyed  by  27  June  2011.  There  are  also  historical  stockpiles  of  PFOS 
from use in the photographic industry (1,280 kg) (ESWI 2011). In the past PFOS was used as 
a  surface-active  agent  in  different  applications  and  products,  in  coatings  and  coating 
additives,  in  carpets  and  textiles,  in  rubber  and  plastics,  in  upholstery  and  in  the  leather 
industry. Such products with an expected long lifetimeare likely to eventually enter the waste 
stream i.e. carpets or (leather) upholstery.  

The carpet sector dominates the major waste streams accounting for ~93% of the total PFOS 
generated  from  all  sectors.  The  waste  stream  generated  from  use  of  fire  fighting  foams 
accounts  for  ~4%  although  all  stocks  should  have  been  disposed  of  by  2011.  Leather 
manufacture and the metal plating industry each account for ~1% of the PFOS waste stream 
with  the remainder  generated by the photographic industry  and hydraulic fluids  used in  the 
aviation industry (ESWI 2011)171.  

171  All figures in this section are estimations made by ESWI 2011 

80 

 
 
                                                           
The  majority  of  PFOS  waste  is  currently  disposed  of  to  landfills  for  non-hazardous  waste 
(63%) followed by non-hazardous incineration (31%). It is estimated that only 1.31% of all 
PFOS  containing  waste  is  currently  reused  or  recycled.  The  remaining  PFOS  containing 
waste is destroyed in hazardous waste incineration plants (ESWI 2011)172.  

Furthermore,  in  March  2018,  EFSA’s  panel  on  contamination  of  food  (CONTAM)  revised 
the  tolerable  weekly  intake  for  both  PFOA  and  PFOS.  For  PFOS  the  original  limits  set  in 
2008 of 150 ng/kg bw per day (21.4 ng/kg bw per week) were proposed to be lowered to 6 
ng/kg bw per week. 

3.2.8.  Pentachlorobenzene (PeCB)  

Pentachlorobenzene  (PeCB)  was  listed  as  new  POP  in  Annex  A  and  C  of  the  Stockholm 
Convention  in  May  2009.  It  is  now  regulated  by  the  POPs  Regulation  which  bans  its 
manufacture, placing on the market and use.  

Therefore, it is not being intentionally produced or used anymore within the Union. Historic 
intentional uses comprised the application together with polychlorinated biphenyls (PCBs) in 
electrical  equipment,  as  flame-retardant  and  as  intermediate  in  the  manufacture  of  the 
pesticide quintozene. ESWI (2011) estimated that the current most relevant source of PeCB 
manufacture  and  emission  are 
incineration  and  combustion  processes  of  different 
wastes/materials including coal173. Emissions of PeCB to the environment (mainly air and to 
a lesser degree soil) were estimated from ESWI to approximately 2,324 kg/y with the main 
contribution  resulting  from  power  manufacture  from  coal  (ca.  83%)  followed  by  domestic 
burning of solid fuels, wood and mixed wastes (8%).  

Within the E-PRTR data-set only a limited number of sites across Europe report the emission 
of  pentachlorobenzene  to  air  for  the  period  2007  –  2017.  For  the  years  when  data  are 
reported,  emissions  have  been  linked  to  manufacture  of  iron  and  steel,  particularly  the 
manufacture  of  pig  iron.  The  other  reported  minor  sources  were  a  waste  water  treatment 
works, and a plant for the processing of vegetable and animal matter.  

The reported releases to air for pentachlorobenzene in the iron and steel manufacture sector 
range  from  0.3  to  1.8  t  per  annum,  based  on  three  metal  facilities  reporting  per  annum  for 
2008 to 2010, and two in 2011. No emissions of PeCB  to air have been reported to  the E-
PRTR after 2012.  

A small number (five) of Member States report emissions of PeCB under the requirements of 
Article  12  .  Overall  emission  estimates  indicate  the  levels  of  PeCB  in  Member  States  vary 
from <0.01 kg/y to >50 kg/y. 

PeCB  releases  to  water  reported  in  the  E-PRTR  (2007-2015)  illustrate  a  small  number  of 
sources. Waste water treatment  works,  petroleum refineries,  and hazardous waste treatment 
report  in  almost  every  year  (oil  and  gas  refineries  were  not  reported  in  2013  or  2015). 
However  the  inventory  for  the  2007-2015  period  is  dominated  by  one  facility  within  the 
organic chemicals manufacture sector which reported releases of PeCB to water of 640 kg in 

172  ESWI (2011): Study on waste related issues of newly listed POPs and candidate POPs. Service request under 

the framework contract No ENV.G.4/FRA/2007/0066. Final report of 13 April 2011 

173  If waste incinerators and coal boilers would have the estimated emission of ESWI (2011) they would have to 

report to PRTR. This inconsistency should be clarified. 

81 

 
 
 
                                                           
2009.  From  the  E-PRTR  information  it  could  not  be  decided  whether  this  release  stemmed 
from current manufacture or from deposits of the site. However, the associated water release 
of 88 kg of HCH from the same site indicate that larger releases stem from deposits and thus 
most  probably  the  PeCB  releases  also  stem  from  deposits.  It  is  known  that  organochlorine 
manufacture  of  certain  solvents  (tetrachlorometane,  tetrachloroethene  and  trichloroethene) 
have generated and often deposited tonnes of HCB/PeCB waste (UNEP 2010)174.  

The  E-PRTR  data  show  that  these  solvents  are  also  being  released  from  the  same  factory, 
which  further  supports  the  hypothesis  that  the  reported  case  is  a  release  of  PeCB  from  a 
HCB/PeCB  deposit  from  former  tetrachlorometane,  tetrachloroethene  and  trichloroethene 
manufacture.  

The importance to inventory and to assess HCB/PeCB waste deposits was emphasised in the 
POPs  inventory  session  at  Dioxin  2011  in  Brussels  (Weber  et  al.  2011)175.  These  releases 
constitute most of the E-PRTR 2009 water releases and more than 50% of total E-PRTR 2009 
PeCB  releases.  Furthermore,  a  recent  review  on  the  future  relevance  of  POPs  deposits 
highlighted the necessity to assess the impact of flooding risks of such sites in particular in 
the context of increased flooding in recent years and in future occurring in Europe triggered 
by climate change (Weber et  al.  2011)176 .This  is also  underpinned by  a case from  Czechia 
where the releases of HCB and PeCB have, and are, contaminating the river Elbe sediments 
(Heinisch et al. 2006)177. For this site the releases have not been included yet in the E-PRTR. 
The possible high impact of PeCB release from organochorine manufacture and deposits (in 
particular  specific  solvents)  was  also  highlighted  by  a  recent  POP  Reviewing  Committee 
Document (UNEP 2010).  

As a comparison to the reported release from organic chemicals manufacture, the emissions 
from  waste  water  treatment  works  across  the  Union  contributed  between  15  and  88  kg  of 
PeCB  per  year  with  an  average  of  56  kg  per  annum  for  the  period  2007-2015.  Petroleum 
refineries  contributed  between  2  and  120  kg  per  annum  with  an  average  of  40  kg  for  the 
timeframe 2007-2015 within the E-PRTR data. 

3.2.9. 

SCCPs – short chain chlorinated paraffins 

Short chain chlorinated paraffins (SCCPs) are already regulated in the Union since 2002 by a 
restriction of the use of SCCPs for metal working fluids and fat liquoring as substances or as 
constituents  of  other  substances  or  preparations  in  concentrations  higher  than  1%178.  This 

174  Stockholm  Convention  (2010):  Information  document  for  the  6th  POP  Reviewing  Committee  meeting 

(UNEP/POPs/POPRC/6/INF/21). 

175  Weber R, Watson A, Malkov M, Costner P, Vijgen J (2011) Unintentionally produced hexachlorobenzene 
and pentachlorobenzene POPs waste from solvent production – the need to establish emission factors and 
inventories. Organohalogen Compounds 73. 

176  Weber R, Watson A, Forter M, Oliaei F. (2011) Persistent Organic Pollutants and Landfills  – A Review of 

Past Experiences and Future Challenges. Waste Management & Research 29 (1) 107-121. 

177  Heinisch E, Kettrup A, Bergheim W, Wenzel S. (2007) Persistent chlorinated hydrocarbons, source-oriented 
monitoring  in  aquatic  media.  6.  Strikingly  high  contaminated  sites.  Fresenius  Environ  Bull  16(10):  1248-
1273. 

178  Directive  2002/45/EC  of  the  European  Parliament  and  of  the  Council  of  25  June  2002  amending  for  the 
twentieth  time  Council  Directive  76/769/EEC  relating  to  restrictions  on  the  marketing  and  use  of  certain 
dangerous substances and preparations (short-chain chlorinated paraffins) 

82 

 
 
 
                                                           
restriction  was  taken  up  in  REACH  Annex  XVII.  Furthermore,  SCCPs  (Alkanes,  C10-13, 
chloro)  were  included  in  the  candidate  list  of  REACH  because  of  their  PBT  and  vPvB 
properties.  Following  the  inclusion  of  SCCPs  in  the  POPs  Protocol,  SCCPs  were  listed  in 
Annex I of the POPs Regulation (Commission Regulation (EC) No 519/2012179). 

Since July 2012, the manufacture, use and placing on the market of SCCPs is forbidden by 
the  POPs  Regulation.  Uses  for  SCCPs  have  included  application  in  paints,  adhesives  and 
sealants, plastics and rubber, flame retardants as well as textiles and polymeric materials (e.g. 
PCB substitute in gaskets).  

There are on-going derogations contained in the POP Regulation, which include the on-going 
manufacture, placing on the market and use of substances or preparations containing SCCPs 
in  concentrations  lower  than  1%  by  weight.  There  are  also  derogations  allowing  the  use  of 
SCCPs as fire retardants in rubber used in conveyor belts in the mining industry and in dam 
seleants.  In  order  to  make  use  of  these  derogations  Member  States  have  to  report  to  the 
Commission by no later than 2015 (and every four years thereafter) progress to eliminate the 
use of SCCPs. The listing of SCCPs was amended in 2015 by Commission Regulation (EU) 
2015/2030180, in order to further restrict their use. 

The  rubber  industry  (conveyor  belt,  gaskets,  hoses)  was  the  main  application  of  SCCPs 
(1,254 t/y)  followed  by  the  sealants  and  adhesives  sector  (459  t/y)  and  by  the  paints  and 
varnishes  sector  (337  t/y).  The  textile  industry  covered  only  a  small  fraction  of  the  overall 
used amount of SCCPs (31 t/y).  

The relevant waste flows have been established for all of the sections and the corresponding 
figure represents that the highest share of non-hazardous waste comes from landfilling (66%) 
followed by incineration with about 20%.  

Also leather which has been impregnated with SCCPs in the past can enter the waste stream 
due to its long lifetime. 

Additionally, concerns have been raised over the presence of SCCPs within recycled plastics, 
where SCCPs have been used in the past as a softener within plastic materials. Miller and Di 
Gangi  (2017)181 comment  on a survey of plastic products  from  10 countries (including two 
Member States) where SCCPs were detected. The study targeted in particular children’s toys 
based on 60 articles. For the Member State samples, concentrations ranged from 13 to 9,715 
mg/kg  (reported  as  ppm),  noting  that  the  LPCL  for  SCCPs  within  waste  under  the  POPs 
regulation  (2019/1021)  is  10,000  mg/kg.  The  European  Commission  (2019)182  review  of 
LPCLs  for  POPs  (including  SCCPs)  further  noted  that  the  legal  limit  for  placing  of  new 
articles  or  mixtures  on  the  market  was  1%  w/w.  However,  the  report  (by  DiGangi  (2017)) 
comments that SCCPs concentrations above the legal limits are regularly detected in various 
kinds  of  consumer  products,  largely  through  recycled  materials  in  imported  products.  The 
study  also  commented  that,  even  though  a  limit  of  10,000  mg/kg  could  be  adopted  for 
SCCPs, it would not be possible to rule out exceeding this limit for some articles where POPs 
may be unintentionally in products that are recycled.  

179  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:159:0001:0004:en:PDF  
180  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R2030&rid=1  
181  Miller  and  DiGangi  (2017)  ‘Toxic  industrial  chemical  recommend  for  global  prohibition  contaminates 

children’s toys’, Publication by IPEN, ACAT and Arnika 

182  European Commission (2019) ‘Study to support the review of waste related issues in annexes IV and V of 

regulation EC 850/2004’, Contract number: No 07.0201/2017/767748/ETU/ENV.B.3 

83 

 
 
                                                           
The total SCCPs containing waste amount (without sewage sludge) sums up to about 44 kt/y.  

The relative distribution of environmental emissions from investigated sectors in the Union is 
as follows: The most important source of emissions is volatile and particulate releases from 
sealants and adhesives (42% or 36 t/y) followed by rubber (31% or 25 t/y) as well as from 
paints and varnishes (21% or 17.4 t/y) and textiles (5% or 4.1 t/y) (ESWI 2011). 

3.2.10.  HCBD – hexachlorobutadiene 

HCBD is listed as priority hazardous substance in the Water Framework Directive, for which 
discharge,  emission  or  loss  must  cease  or  be  phased  out.  Nevertheless,  the  inclusion  of 
HCBD  in  the  POPs  Protocol  has  triggered  the  obligation  to  take  up  HCBD  in  the  POPs 
Regulation which is however still to be implemented.  

The  intentional  use  and  manufacture  of  HCBD  has  not  occurred  in  Europe  for  many  years 
(UNECE  2007).  HCBD  is  mainly  formed  as  an  unintentional  by-product  during  several 
industrial processes (as a solvent for rubber and other polymers, in heat transfer fluids, as a 
transformer liquid  or hydraulic fluid). However  available information about  these industrial 
processes is scarce.  

Nowadays,  the  most  important  source  of  HCBD  is  due  to  the  manufacture  of  chlorinated 
solvents through chlorolysis of tri- and tetrachloroethene, tetrachloroethylene and tetrachloro-
methane.  The  estimated  amount  of  HCBD  produced  during  this  process  varies  between 
~0.7 kg/y up to possible ~500 kg/y (ESWI 2011).  

Urban  waste-water  treatment  plants  are  a  second  main  source  of  HCBD  (E-PRTR  2007  - 
2017).  The  releases  from  urban  waste-water  treatment  plants  (based  on  E-PRTR)  vary 
between 42 and 1,100kg per annum.  

Unintentional manufacture and releases from the plastic (PVC) industry may be relevant, but 
specific data is not available yet.  

HCBD  is  and  has  been  produced  as  by-product  of  certain  chlorinated  solvent  manufacture 
and  is  among  the  prime  pollutants  of  “Hexachlorobenzene”  wastes  deposited  in  10,000 
tonnes  scale  from  such  manufactures  in  the  past.  Therefore  such  waste  deposits  can  be 
considered to be the largest stock of HCBD (ESWI 2011).  

3.2.11.  PCN – polychlorinated naphthalenes 

PCN was added to the POPs Regulation by Regulation (EC) 519/2012 which coincides with 
addition of PCN to the UNECE POPs Protocol. Wastes containing PCN are characterised as 
hazardous waste under Annex VIII entry A3180 of the Basel Convention. Furthermore as of 
2014 Regulation (EC) 1342/2014 amending Annexes IV and V of the POPs Regulation sets 
in  place  critical  thresholds  for  PCN  to  identify  those  wastes  characterised  as  being  POPs-
contaminated and requiring destruction or irreversible transformation of PCN.   

PCNs  are  a  group  of  substances  based  on  the  naphthalene  ring  system  and  they  are 
structurally  similar  to  the  PCBs.  PCNs  are  no  longer  commercially  produced  in  the  Union. 
They were produced in the past as mixtures of several congeners and with different product 

84 

 
 
 
names e.g. Halowax, Nibren Waxes, Seekay Waxes and Cerifal Materials (UNECE 2007)183. 
The  main  use  of  PCNs  was  in  the  electrical  industry  as  separators  in  storage  batteries, 
capacitor  impregnates,  as  binders  for  electrical  grade  ceramics  and  sintered  metals,  and  in 
cable covering compositions. They have also been used for impregnation of wood, paper and 
textiles to attain water proofness, flame resistance and protection against insects, moulds and 
fungi.  Furthermore,  they  were  used  as  additives  in  gear  and  cutting  oils,  in  lacquers  and 
underwater paints and as raw material for dyes184.  

PCN are currently formed mainly unintentionally during various thermal processes (UNECE 
2007). As PCNs exhibit similar formation properties as PCDD/Fs, unintentional manufacture 
during incineration processes as municipal solid waste incineration (MSWI), hospital waste 
incineration, domestic burning, or different metal processing steps such as secondary copper 
manufacture,  secondary  aluminium  manufacture,  magnesium  manufacture  as  well  as  iron 
sintering  and  electrical  arc  furnace  processes  for  iron  manufacture  are  of  relevance. 
Moreover,  the  accumulation  in  sewage  sludge  from  diffuse  sources  is  a  relevant  pathway 
(ESWI 2011).  

The total waste amount is estimated about 3,200 kg of PCN (ESWI 2011). The main waste 
stream  found  its  way  into  the  recycling  and  recovery  channel  (about  90%).  Emissions  of 
polychlorinated naphthalenes to the environment amount to approximately 12 kg/year. 

3.2.12.  Hexabromocyclododecane (HBCDD) 

HBCDD  is  a  brominated  flame  retardant  which  has  been  in  use  since  the  1960s,  primarily 
within  the  Union  for  expandable  polystryrene  (EPS)  and  extruded  polystyrene  (XPS) 
insulation boarding used within roof and cavity wall insulation (greater than 90% of the use). 
It has also been used as a flame retardant in the textiles sector (found in polymer-dispersion 
coating  agents  used  in  textiles  for  upholstered  fabric,  furniture,  mattress  ticking  and  for 
seating in vehicles accounting for 9% of all use). HBCDD also has been used (around 1% of 
total HBCDD use) as a flame retardant for use in high impact polystryrene  (HIPS) used for 
mouldings  and  housings  of  electrical  goods  such  as  computer  monitors  and  CRT  based 
televisions.  

Total global HBCDD manufacture in 2011 was 31,000 tonnes, with manufacture ongoing in 
Europe, the USA and China185. For Europe the REACH Annex XV report (2016) comments 
that in 2009, demand for HBCDD was 12,000 t (6,000 t imported and 6,000 t manufactured), 
with one manufacture site based in the Netherlands.  

Following  the  Stockholm  Convention  review  process  for  proposals  to  list  substances, 
HBCDD  was  added  to  Annex  A  of  the  Convention  in  2013  at  the  fifth  conference  of  the 
Parties (COP-5) with full entry into force in November 2014. HBCDD was also listed in the 
POP Regulation by Commission Regulation (EU) 2016/293. 

183  UNECE (2007): Exploration of management options for Polychlorinated Naphthalenes (PCN) Paper for the 
6th meeting of the UNECE CLRTAP Task Force on Persistent Organic Pollutants, Vienna, 4-6 June 2007. 
https://www.unece.org/index.php?id=4897  

184  Jakobosson,  E.;  Asplund,  L.  (2000):  Polychlorinated  Naphthalenes  (PCNs),  The  Handbook  of  Environ-

mental Chemistry Vol. 3 Part K, New Types of Persistent Halogenated Compounds, Chapter 5, 2000. 

185  UNEP,  Guidance  for  the  inventory,  identification  and  substitution  of  Hexabromocyclododecane  (HBCD), 

April 2015 

85 

 
 
 
                                                           
Furthermore under the REACH Regulation, HBCDD had already been identified as a SVHC 
at the time of its addition to the Stockholm Convention, and was subject to the authorisation 
process  (Annex  XIV),  meaning  permissions  for  specific  applications  were  required  for 
continued  use  in  the  Union.  In  January  2016  a  time-limited  authorisation  was  given  to  13 
companies for two specific applications for use as a flame retardant in expanded polystyrene 
boarding  and  use  as  a  flame  retardant  in  the  manufacture  of  expanded  polystyrene  beads 
(Commission  Implementing  Decision  C(2015)  9812  final).  This  authorisation  expired  in 
August 2017 after which no further legal use of HBCDD was permitted in the Union.  
The  Netherlands  (2016)186  comment  that  working  concentrations  for  insulation  boarding 
containing  EPS  were  between  0.5  and  1%  and  for  XPS  between  0.8  and  2.5%  w/w.  The 
REACH  Annex  XV  report  (2016)  comments  that  the  demand  for  HBCDD  in  2009  was 
12,000 tonnes.  Based  on  the  working  concentrations  stated  this  equates  to  between 
480,000 tonnes and 2.4 million tonnes of HBCDD insulation boarding placed on the market 
per  annum  in  the  Union.  As  a  comparison,  the  Netherlands  (2016)  comments  that  in  2016, 
62,500 tonnes of insulation boarding containing  HBCDD  (50,000 t  EPS and 12,500 t  XPS) 
was placed on the market in the Netherlands. 

ECHA (2009) states that the service life of EPS and XPS can be several decades (greater than 
30  years).  Therefore  a  potentially  significant  stockpile  of  in-use  materials  may  exist  in  the 
Union  with  ongoing  waste  management  for  many  years  to  come.  Annex  IV  and  V  of  the 
[initial] POPs Regulation were amended in 2016 (by Commission Regulation (EU) 2016/460) 
to provide a low POP concentration limit of 1,000 mg/kg for HBCDD, above which all waste 
must be destroyed or irreversibly transformed. 

Drage et al (2018) comment on a sampling and analysis study of PBDEs in waste in Ireland, 
including  HBCDD.  Based  on  analysis  of  EPS  and  XPS  insulation  materials  (60  samples), 
HBCDD was detected in 100% of the samples analysed with mean average concentrations of 
2,100 mg/kg in EPS and 27 mg/kg in XPS. The study goes on to estimate that annually 4,200 
tonnes  of  EPS/XPS  enter  the  waste  stream  in  Ireland,  containing  5.5  tonnes  of  HBCDD. 
Based on their analysis Drage et  al comment that 23% of this (966 tonnes  of waste) would 
exceed the low POP concentration limit for HBCDD. 

Another  important  source  of  HBCDD  within  wastes  identified  by  Drage  et  al  (2018)  is  the 
former  use  of  HBCDD  within  textiles  and  soft-furnishings.  While  these  applications  were 
only  a  secondary  use  (≤9%  of  all  use187),  the  analytical  results  from  Drage  et  al  (2018) 
suggest higher concentrations may have been used at time of application (five times greater 
than  EPS/XPS).  HBCDD  was  detected  in  32  of  the  122  samples  of  textile/soft  furnishings 
analysed,  with  low  POP  concentration  limits  exceeded  in  11  samples  (six  textile  coverings 
and  five  foams).  HBCDD  was  detected  in  textiles/soft  furnishings  with  concentrations 
ranging  from  1-400  mg/kg,  with  a  median  value  of  4  mg/kg.  Drage  et  al  (2018)  further 
comment  that  based  on  analytical  results  many  samples  below  the  low  POP  concentration 
threshold may represent migration and contact with treated articles in the waste stream rather 
than  intentional  treatment  of  the  article  itself.  Where  multiple  different  brominated  flame-

186  Ministry  of  Infrastructure  and  the  Environment  2016  -  HBCDD  in  EPS/XPS  waste  in  the  Netherlands. 

GR20161222 

187  Data  taken  from  EBFRIP  in  2010  estimated  >90%  by  wt  of  all  HBCDD  was  used  in  EPS/XPS.  The 
remaining  quantities  were  used  in  textiles  and  high  impact  polystyrene  (HIPs)  applications,  with  HIPs  a 
minor use (≤1%). Textiles are therefore assumed as a maximum of 9% of all use.   

86 

 
 
                                                           
retardants  (including  those  not  listed  under  the  POP  Regulation  or  REACH  authorisation) 
have  been  used  on  both  construction  materials  and  textiles/soft  furnishings,  this  poses  a 
challenge for waste handling operators to identify and appropriately manage HBCDD wastes 
above the low POP concentration limit. Schlummer et al. (2015)188 highlights that analysis of 
specific  species  of  brominated  chemicals  in  demolition  waste  can  be  both  expensive  and 
time-consuming  (analysis  and  provision  of  results  at  laboratory  facilities  taking  days),  and 
therefore  a need  for  rapid analysis is  necessary.  The study undertaken by Schlummer et  al. 
(2015)  investigated  the  possibility  of  handheld  XRF  equipment  to  identify  bromine  as  a 
proxy marker for HBCDD and means of assessing wastes for low POP content and suitable 
management.  This  assumes  that  if  the  concentration  of  bromine  (assuming  all  brominated 
species present are HBCDD) is below the low POP concentration limit further action is not 
needed. If the bromine concentration exceeds the low POP concentration limit this could be 
due to HBCDD or due to a combination of brominated flame-retardants (including those that 
are not POPs), suggesting further investigation might be needed. 

The  study  by  Schlummer  et  al.  further  comments  that,  for  the  construction  sector  in 
particular, handheld XRF is a valuable screening tool based on the fact that HBCDD can be 
extracted  from  insulation  foams  while  the  polymeric  bromine  replacement  for  HBCDD 
cannot. This allowed extraction and XRF analysis for bromine (as a proxy for HBCDD) as a 
means of testing for HBCDD concentration in insulation boarding. 
Jeannerat  et  al  (2016)189  provide  details  of  an  alternate  approach  to  the  separation  and 
identification of HBCDD from polystrene insulation foams using nuclear magnetic resonance 
(NMR). During 2013/14 field studies used laboratory analysis to place samples under liquid 
chromatography  coupled  with  mass  spectroscopy  (LC-MS),  which  demonstrated  different 
HBCDD  isomers  (α/  γ)  for  EPS  and  XPS,  but  also  highlighted  cases  where  handheld  XRF 
detected bromine and LC-MS demonstrated no presence of HBCDD. NMR was then used to 
further determine which brominated flame-retardant species were present. 
Sharkey et al. (2018)190 provides a further study on the wider application of handheld XRF 
for  POP  BFRs  (including  HBCDD).  The  study  took  555  samples  from  a  waste  handling 
facility  in  Ireland,  which  included  plastics,  textiles,  foams  and  insulation  materials  and 
completed  analysis  by  both  handheld  XRF  and  mass  spectroscopy  (MS)  for  POP-PBDEs, 
HBCDD,  and  tetra  tetrabromobisphenol-A  (TBBP-A).  The  results  showed  a  strong 
correlation between XRF and MS as a linear regression for waste plastics used in electricals. 
However, the results also showed that for plastics, textiles and foams XRF may over-estimate 
concentrations  (by  a  factor  of  up  to  1.9)  likely  due  to  matrix  effects  influencing  the  XRF. 
However, for HBCDD used in  insulation boarding a stronger correlation  between XRF and 
MS  was  seen,  possibly  due  to  fewer  bromine  based  compounds  in  use  for  this  application. 
Even  where  over-estimation  of  brominated  POP  flame-retardants  was  identified  (based  on 
bromine  content  of  the  sample),  the  study  results  showed  of  the  555  samples  analysed,  the 
XRF  approach  only  mistakenly  identifies  6%  (34/555)  of  samples  as  exceeding  the  limits. 

188  Schlummer M, Vogelsang J, Fiedler D, Gruber L, Wolz G. 2015.  Rapid identification of polystyrene foam 
wastes  containing  HBCD  or  its  alternative  polymeric  brominated  flame  retardant  by  x-ray  fluorescence 
spectroscopy, Waste Management & Research. 33(7):662-70. 

189  Jeannerat et al, 2016, ‘Discrimination of hexabromocyclododecane  from  new polymeric brominated flame 

retardant in polystyrene foam by nuclear magnetic resonance’, Chemosphere vol 144 pp1391-1397 

190  Sharkey  M,  Abdallah  MA, Drage DS,  Harrad S,  Berresheim H. 2018. Portable X-ray  fluorescence  for the 

detection of POP-BFRs in waste plastics. Sci Total Environ. 639:49-57. 

87 

 
 
                                                           
Therefore the use of handheld  XRF may prove a valuable tool (particularly for  HBCDD in 
construction and demolition) as a ‘pass/fail’ screening tool for low POP content in wastes. 
However,  one  further  issue  highlighted  by  a  2019  industry  paper191  is  that,  while  good 
advances  are  being  made  in  the  development  and  refinement  of  XRF  as  a  screening  tool, 
standards for laboratory practice are still needed. The paper asserts that currently only ISO or 
DIN standards for laboratory analysis of HBCDD exist for water and textiles. Further work is 
needed  to  develop  and  agree  standards  for  foams  and  plastics,  with  industry  currently 
implementing a range of analytical methodologies. 

3.2.13.  Pentachlorophenol (PCP) 

Pentachlorophenol  was  first  produced  as  wood  preservative  as  early  as  the  1930s,  but  has 
been  used  as  a  biocide,  pesticide,  disinfectant,  defoliant,  anti-sapstain  agent,  and  anti-
microbial agent in the treatment of wood since that time (UNECE, 2010192). Furthermore, the 
ester  pentachlorophenyl  laurate  (PCP-L)  has  had  application  as  a  biocide  and  pesticide  for 
textiles, particularly heavy textiles such as tent canvass,  where it was used to  prevent  mold 
and  fungus,  particularly  for  military  applications.  The  Stockholm  Convention  risk  profile 
(UNEP/POPS/POPRC.9/6)  highlights  that  once  released  PCP-L  degrades  to  form  PCP  as 
does  the  sodium  salt  of  PCP  (NaPCP),  hence  the  listing  under  the  Stockholm  Convention 
covers PCP, its salts and esters. 

Globally, manufacture and use peaked at around 50,000-60,000 tonnes per annum in the mid-
1980s before declining (UNEP/POPs/POPRC.9/6). The  manufacture of PCP and its sodium 
salt (NaPCP) ceased in the Union by 1992, although import of PCP and NaPCP, primarily for 
timber  treatment  and  synthesis  of  PCP-L  continued  after  this  period  (OSPAR,  2004193).  In 
1996, 378 tonnes of NaPCP and 30 tonnes of PCP were imported into Europe from the USA, 
primarily into France, Portugal, Spain, and the United Kingdom (OSPAR, 2004). 

Restriction  on  the  use  of  PCP  within  the  Union  entered  into  force  in  1991  under  Council 
Directive 91/173/EEC and a ban was placed with respect to the use of PCP as a synthesising 
or  processing  agent  in  industrial  processes  (including  use  a  wood  preservative)  under 
Commission Directive 1999/51/EC. Since 2008 PCP has been controlled under the REACH 
Regulation  with  a  restriction  limiting  the  placing  on  the  market  of  PCP  as  a  constituent, 
mixture or in articles above 0.1 % w/w. 

Convention 

While the use of PCP, its salts and esters has ceased in the Union now for over a decade, the 
Stockholm 
PCP 
(UNEP/POPs/POPRC.10/2) highlights that the service life of treated timbers can be up to 50 
years. This includes primarily utility poles, but also railway sleepers, with those goods treated 
in the 1980s the most likely to contain PCP. 

risk  management 

evaluation 

(RME) 

for 

Treated  timbers  can  also  emit  PCP  during  their  service  life,  this  includes  both  emissions 
directly  to  air,  but  also  contamination  of  rain  water  which  can  then  reach  ground.  The 
UNECE (2010) suggest that in the first 12 months after treatment as much as 30% of the PCP 

191  Industry  paper  (2019)  ‘Current  state  of  affairs  of  HBCDD  analysis  in  polystyrene  foams  EPS  and  XPS’, 

paper produced by Plastics Europe, Exiba, and the International Bromine Council (BSEF). 

192  UNECE, 2010, ‘Exploration of management options for PCP’, paper presented to the UNECE task force on 

POPs. 

193  OSPAR, 2004, Hazardous substance series – pentachlorophenol’ ISBN 0 946956 74 X 

88 

 
 
 
                                                           
used in treatment can be volatised to air as equilibrium is reached, after the 12 month period 
the rate of emissions slow down considerably.  
Pohlandt et al (1995194) comments on a sampling study within the Union of waste wood from 
a  variety  of  sources.  In  total  207  samples  were  analysed  with  the  highest  concentrations  of 
PCP found in window frames (163 mg/kg) and interior wood structural materials (11 mg/kg). 
The remaining wood types (fences, pallets, recycled wood chips, and wooden beams) ranged 
from 0.4 – 4.4 mg/kg of wood. 

End of life options for timber treated with  PCP include landfill,  incineration  or re-use (e.g. 
the  use  of  railway  sleepers  for  ornamental  purposes  in  domestic  gardens).  The  Stockholm 
Convention  RME  highlights  the  potential  risk  of  dioxin  and  furan  emissions  linked  to 
incomplete  combustion  of  wood  treated  with  PCP.  ESWI  (2011)  provides  some  further 
comment  that wood treated with  PCP in  Sweden and Germany is  primarily disposed of via 
incineration as concentration limits prevent disposal via landfill. No information is available 
on how PCP is primarily managed in other Member States.  

No  current  manufacture  or  use  of  PCP,  its  salts  or  esters  exists  within  the  Union,  while 
stockpiles  of  treated  timbers  and  textiles  mainly  from  the  mid-1980s  to  early  1990s  can  be 
expected  to  be  declining.  Appropriate  management  of    waste  materials  contaminated  with 
PCP may still pose an issue, particularly for incomplete combustion and re-use, particularly 
where identification of PCP treated wood in waste streams poses challenging. However, no 
available data on potential quantities has been identified.  

3.2.14.  Dicofol  

Dicofol is an organochlorine miticidal pesticide, that has been used since the 1950s to control 
mites on a variety of crops including fruits, vegetables, ornamentals, field crops, cotton, tea, 
and  Christmas  tree  plantations,  as  well  as  on  non-agricultural  outdoor  buildings  and 
structures.  

Dicofol is chemically related to another Stockholm Convention POP, DDT. Production of the 
commercial dicofol mixture contains two isomers, o,p’dicofol (15-20%) and p,p’dicofol (80-
85%),  along  with  variable  levels  of  DDT  as  an  impurity.  However,  since  1998  agreements 
under the FAO limited DDT concentrations to no higher than 0.1%.  

At  its  twelfth  meeting  the  POPRC  concluded  that  dicofol  is  likely,  as  a  result  of  its  long-
range environmental transport, to lead to significant adverse human health and environmental 
effects  such 
its  decision 
(UNEP/POPS/COP.9/13),  the  COP  decided  to  amend  part  I  of  Annex  A  to  the  Stockholm 
Convention to list dicofol without exemptions. 

that  global  action 

is  warranted.  At 

the  COP-9, 

in 

In Europe dicofol usage was  estimated to  have  decreased from 317 t  to  32 t  between 2000 
and  2009195.  According  to  estimated  emission  data196,  the  major  consuming  countries  in 

194  Pohlandt  et  al,  (1995)  ‘Concentrations  of  pentachlorophenol  and  lindane  in  various  assortments  of  waste 

wood’, volume 31, Issue 9, November 1995, Pages 4025-4031 

195  Li,  L.,  Liu,  J.,  Hu,  J.  (2014)  Global  inventory,  long-range  transport  and  environmental  distribution  of 

dicofol. Environmental Science and Technology, 49: 212-222. 

196  Van  der  Gon,  H.D,  Bolscher,  M.,  Visschedijk,  A.,  Zandveld,  A.  (2007)  Emissions  of  persistent  organic 
pollutants  and  eight  candidate  POPs  from  UNECE–Europe  in  2000,  2010  and  2020  and  the  emission 

89 

 
 
 
                                                           
 
Europe  in  2000  were  Spain,  Italy,  Turkey,  Romania,  and  France.  However,  data  regarding 
current concentrations in different environmental vectors is lacking due to the lack of regular 
monitoring of dicofol concentrations.  

The permitted use of dicofol for plant protection products in the Union expired by 2010 at the 
latest according to Commission Decision 2008/764/EC. In addition, all non-agricultural uses 
were prohibited according to the Biocidal Products Regulation (EU) No 528/2012. 

In 2020, dicofol has been listed in Annex I to the POPs Regulation by Commission Delegated 
Regulation  (EU)  2020/1204197  in  order  to  implement  the  decision  adopted  under  the 
Stockholm  Convention.  The  POPs  Regulation  prohibits  all  manufacture,  placing  on  the 
market and use of dicofol in the Union. 

Dicofol  is  also  included  in  Directive  2013/39/EU  as  a  priority  hazardous  substance  in  the 
field of water policy. This sets environmental quality standards for dicofol, for inland surface 
waters  (1.3  ×  10–3  μg/l);  other  surface  waters  (3.2  ×  10–5  μg/l);  and  biota  (33  μg/kg  wet 
weight). Additionally, because dicofol is a priority hazardous substance there is an obligation 
under the Water Framework Directive (Directive 2000/60/EC) for cessation of all discharges 
to the environment, which goes beyond the EQS target thresholds. 

Data taken from the EFSA OpenFoodTox database indicates that in 2012 safe limit values for 
pesticide residues of dicofol (based on an accute reference dose (ARfD)) were calculated to 
be 0.15 mg/kg bw/day. 

3.3. 

Unintentionally produced POPs 

Releases of unintentionally produced POPs (UPOPs) remain an important POP source in the 
Union.  Where  regulation  and  policy  have  identified  and  reduced  the  emissions  from 
industrial sources over the past two decades, diffuse sources linked to for example domestic 
combustion or open burning of waste become increasingly important UPOPs sources.  

However such sources can be more difficult to monitor and tackle. Reduction and phase out 
of these emissions is complex, indeed impossible in the case of most thermal sources and of 
emissions from open burning. Furthermore, the sources of unintentionally produced POPs are 
rather  disperse  and  thus  measures  cannot  be  as  targeted  as  for  intentionally  produced  and 
used POPs.  

Member  States  extensively  reported  monitoring  data  for  the  release  of  unintentionally 
produced  POPs  into  the  air,  water  and  soil  using  three  methodologies:  Stockholm 
Convention’s  emission  inventories,  E-PRTR's  and  EMEP's.  A  remarkable  amount  of 
information  is  available  on  air  and  water  emissions,  in  particular  from  the  E-PRTR  and 
EMEP  databases  that  are  standardised,  user-friendly  and  are  readily  available  in  electronic 
form for analysis. Yet, however, there have been comparitively fewer cases of Member States 
reporting  data  using  the  Stockholm  Convention  methodology.  One  possible  reason  for  this 
lack of reported data may relate to the difficulty in accurately accounting for activity data in 

reduction  resulting  from  the  implementation  of  the  UNECE  POP  protocol.  Atmospheric  Environment,  41: 
9245–9261. 

197  Commission Delegated Regulation (EU) 2020/1204 of 9 June 2020 amending Annex I to Regulation (EU) 
2019/1021  of  the  European  Parliament  and  of  the  Council  as  regards  the  listing  of  dicofol  (OJ  L  270, 
18.8.2020, p. 4). 

90 

 
 
 
                                                                                                                                                                                     
diffuse sources e.g. quantity of waste burnt on open fires for an entire nation. The Stockholm 
Convention  has  aimed  to  assist  inventory  compilers  through  the  provision  of  guidance 
material such as the dioxins and furans toolkit198. 

3.3.1.  Estimation and monitoring of emissions 

in  Annex  III  of 

the  Stockholm  Convention  or 

The regulated emissions to air, water and soil of the unintentionally produced POPs listed in 
the  POP  Protocol 
Annex C  of 
(hexachlorobenzene,  pentachlorobenzene,  polychlorinated  biphenyls,  polychlorinadetd 
dibenzo-p-dioxins and dibenzofurans and polycyclic aromatic hydrocarbons) are registered in 
the  European  Pollutant  Release  and  Transfer  Register  (E-PRTR).  Furthermore,  EMEP  is 
monitoring and modelling UPOPs levels in air for the EMEP region and is compiling the air 
inventories  (EMEP  2011)199.  This  inventory  data  for  the  air  vector  is  made  publically 
available through the webdab database: http://www.ceip.at.  
The  E-PRTR  database200  contains  reported  data  for  point  source  emissions  from 
approximately 34,000 facilities from the Union  and Iceland, Liechtenstein, Norway, Serbia, 
Switzerland  and the United Kingdom  in  65 economic activities for 91 pollutants, including 
the unintentionally produced POPs that are covered under the Stockholm Convention and the 
POP  Protocol  from  2007  to  2017.  Table  11  presents  the  current  data  from  Union  facilities 
(above the reporting thresholds).  

Table 11  Releases of unintentionally produced POPs according to the E-PRTR (PCDD 

+ PCDF as TEQ) (for the EU27)201 

POP substance 

Year 

Air  

Water  

Soil 

Units 

kg I-TEQ unless indicated 

g I-TEQ unless indicated 

g-ITEQ unless indicated 

Polychlorinated 
dibenzo-p-dioxins 
(PCDD) and 
Polychlorinated 
dibenzofurans (PCDF) 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

1.2  

1.2  

0.7   

0.8  

0.5  

0.4  

1.09  

1.16  

0.94  

1.11  

10.8 

22.4 

14,3 

296 

33.5 

75 

40.9 

242 

249 

47.7 

213  

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

198  UNEP, 2005, ‘Standardized Toolkit for Identification and Quantification of Dioxin and Furan Releases’ 
199  Gusev A., Dutchak S., Rozovskaya O., Shatalov V., Sokovykh V., Vulykh N. Aas W., Breivik K. Persistent 

Organic Pollutants in the Environment. EMEP Status Report 3/2011; June 2011. 

200  https://prtr.eea.europa.eu/ 
201 Data was derived using the “EU28” search function in the E-PRTR and subtracting the national total for the 

United Kingdom. PRTR accessed on 02/02/2021 

91 

 
 
 
 
 
                                                           
POP substance 

Year 

2017 

Air  

Water  

Soil 

12.3* 

22.9 

No data reported 

Main sources of PCDD/PCDF 

Manufacture and 
processing of metals 

Manufacture and 
processing of metals 

Manufacture and 
processing of metals 

Kg unless indicated otherwise 

120.0 

No data reported 

Hexachlorobenzene 
(HCB) 

Main sources of HCB 

Pentachlorobenzene 

Units 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

Units 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

86.0 

68.1 

42.3 

20.5 

125 

No data reported 

42.2 

59.2 

32.0  

84.0 

68.5 

93.0 

63.9 

72.5 

82.8 

88.3 

25.2 

25.4 

27.7 

13.1 

27.7 

Chemical industry, waste 
and wastewater 
management 

Waste and wastewater 
management 

Kg unless indicated otherwise 

No data reported 

1780 

347 

569 

508 

1.5 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

16.5  

36.1 

661.0 

387.0 

24.0 

222.5 

90.3 

86.3  

78.9 

97.9 

66.8 

Main sources of 
pentachlorobenzene 

Manufacture and 
processing of metals 

Polychlorinated 
Biphenyls (PCBs) 

Units 

2007 

2008 

2009 

2010 

179.6  

151.7 

547.0 

541.8 

92 

Chemical Industry, 
Waste and waste water 
management, Energy 
sector 

Kg unless indicated otherwise 

36.2  

184.1 

221.6  

76.2 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

- 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

No data reported 

- 

24.4 

29.5 

516.0 

20.0 

 
 
POP substance 

Year 

Air  

Water  

Soil 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

Units 
2007 
2008 
2009 
2010 
2011 
2012 
2013 
2014 
2015 
2016 
2017 

508.0 

54.4 

81.8 

49.8 

52.9 

180.2 

79.9  

69.6  

89.5 

31.1  

22.1  

25.6 

184.3 

346.4 

16.3 

4.1  

0.5  

0.9  

1.0 

0.4  

0.1  

Manufacture and 
processing of metals, 
mineral industry 

Waste and waste water 
management (urban 
waste-water treatment 
plants) 

Waste and waste water 
management, Animal and 
vegetable products from 
the food and beverage 
sector 

tonnes 
177.9 
132.8 
68.7 
79.7 
81.1 
58.1 
37.0 
34.2 
50.2 
45.0 
44.4 
Combustion processes 
linked to power 
generation, metals 
production and cement 
clinker 

tonnes 
8.3 
5.9 
4.4  
3.2 
2.9 
4.9 
2.3 
2.4 
0.7 
1.9  
1.8 

Urban wastewater 
treatment plants, power 
stations, and hazardous 
waste management 

kg 
18.4 
17.4 
130.0 
98.3 
32.6  
No data reported 
No data reported  
No data reported  
No data reported  
15.7 
No data reported  
- 

Main sources of PCBs 

Polycyclic aromatic 
carbons (PAHs) 

Main sources of PAHs 

# Release values stated are the aggregated total for all E-PRTR reporting countries across 34,000 facilities 
*possible errors have been identified in the reported data 

E-PRTR can be used for trend analysis over the time frame (2007-2017); however, some care 
is needed in the interpretation, noting that the E-PRTR uses reporting thresholds. This means 
that in some cases a release is not reported for a given facility, not because there is no release 
but because it is below the reporting threshold. Even for those facilities above the reporting 
threshold  the  datasets  held  by  the  E-PRTR  are  also  rather  incomplete  at  least  for  several 
UPOPs. This can be seen e.g. for PeCB with just 4 facilities reporting  emission to water in 
2015 or for HCB where just 1 facility reported emissions to air in 2015. Part of the reason for 
this  incomplete  picture  may  relate  to  the  level  of  understanding  for  UPOPs  substances  by 
operators  that  complete  E-PRTR  returns.  This  is  particularly  important  for  operators  when 
assessing whether a source exists or not, and to aid with making sense of the values derived 
for real world emissions. 

For  a  number  of  the  UPOPs  released  to  given  vectors  (air,  water,  land)  and  years  a  small 
number of sites  with  unusally high reported emissions can have  a  significant  impact  on the 
overall annually reported data. In some cases the data reported suggests potential errors such 
as  unit  errors.  For  example,  as  shown  in  Table  11,  the  emissions  to  water  of  PCDD/Fs  in 

93 

 
 
 
2009 was 14.3 kg I-TEQ, due almost entirely to the emissions reported by one iron and steel 
plant. This would appear to be an error.  

On  other  occasions  the  reporting  of  data  could  be  due  to  problems  at  the  plant  or  genuine 
reasons for why an emission might be high. For example one facility  with a high release of 
PeCB to  water of 640 kg  reported  in  2009  had,  for all other  years in  the E-PRTR  database 
(2007-2015),  PeCB  emissions  from  this  facility  below  the  reporting  threshold  (1  kg). 
Comparison  to  other  inventories  such  as  those  reported  to  the  European  Commission  for 
Article  12  of  Regulation  (EC)  No  850/2004  suggests  this  value  is  high  but  not  outside  the 
bounds  of  possibility.  However,  it  is  unclear  whether  in  this  case  the  reported  value  is 
genuine or an error.  

Furthermore  the  E-PRTR  makes  use  of  reporting  thresholds  below  which  operators  are  not 
required to submit data. However it is less clear when examining data for UPOPs why some 
facilities  provide  data  where  others  do  not.  For  example  looking  at  2009  data  where  two 
metal manufacturing facilities in Belgium and Finland report emissions of PeCB amounting 
to  107 and 240  kg respectively, while other facilities did  not report any  PeCB emissions at 
all,  which  assuming  the  reported  data  are  correct  would  mean  that  all  other  metal 
manufacturing facilities have emissions of PeCB less than 1 kg per annum.  

The examples alluded to highlight why examining time trends within the E-PRTR dataset are 
currently difficult and need a detailed systematic assessment of reporting facilities.  

According to the official and unofficial emission data considered by EMEP, total emissions 
of PCDD/Fs within the EMEP domain decreased by  62% in the period from 1990 to  2015. 
PCDD/F  emissions  within  the  Northern  Hemisphere  (EMEP  region,  the  USA  and  Canada) 
declined  by  50%  during  the  same  period.  Based  upon  the  UNECE  data  for  2015  on  air 
emissions  covering  PCDD/F,  maximum  emission  reduction  within  the  1990  to  2015  period 
took place in the Netherlands (97%), Luxembourg, (96%), Belgium (95%), Romania (95%), 
and France (94%). 

As  regards  the  estimated  emissions  by  EMEP  reporting  nations,  it  should  be  noted  that 
despite strong improvements in reducing the uncertainty of the estimates in recent years, the 
overall  uncertainties  in  the  emission  estimations  remain  relatively  high,  particularly  in 
relation  to  emission  factors  and  activity  rates.  A  review  of  the  POPs  emission  inventories 
submitted previously under the UNECE in 2012202 highlighted that a number of inventories 
had key source gaps, particularly for HCB and PCB. The same review also identified issues 
with  transparency  with  a  range  of  emission  factors  in  use  for  similar  sources  which 
highlighted differences between data reported by different Member States. 
More  recently  the  EMEP203  provide  a  comparitive  analysis  of  predicted  ambient  air 
concentrations  and  measured  data  for  HCB  and  PCBs  for  EMEP  countries  in  2014.  The 
results  suggest  that  there  was  agreement  between  predicted  and  measured  concentrations, 
within a factor of 2 in 75% of cases for HCB and 85% of cases for PCBs. However, model 
predictions tend to underpredict concentrations. According to EMEP, the underprediction can 
be  explained  by  the  uncertainty  of  applied  emission  data,  namely,  spatial  distribution  of 

202  Whiting,  2012,  ‘Inventory  Review  2012  -  Review  of  POP  emission  inventories’,  report  by  the  Centre  for 

Emission Inventories and Projections (CEIP) 

203  EMEP 2016, Persistent Organic Pollutants: Assessment of Transboundary Pollution on Regional and Global 

Scales, Status Report 3/2016.  

94 

 
 
                                                           
emissions  and  their  seasonal  variability  that  requires  more  detailed  analysis.  Thorough 
analysis of contemporary and historical emissions is thus needed to refine the assessments of 
pollution levels.  

The  exposure  of  the  population  to  unintentionally  produced  POPs  is  addressed  by  the  food 
and feed regulations and by the Directive 2004/107/EC on ambient air pollutants (see section 
2.2.5). 

The EMEP/EEA air pollutant emission inventory guidebook was updated in 2016  including 
updated emission factors for several POPs. The emission factors currently used for the 2016 
guidebook are made availabel through the EEA’s Emission Factor Database204. 

3.3.2.  Addressing industrial sources 

The  core  instrument  covering  the  environmental  performance  of  industrial  installations 
(covering  emissions  to  air,  water  and  land  and  generation  of  waste)  is  the  Industrial 
Emissions Directive 2010/75/EU (IED). The emission limit values, parameters or equivalent 
technical  measures  to  be  set  in  the  operating  permits  for  installations  have  to  be  based  on 
BAT.  The  BAT  are  described  and  defined  at  Union  level  in  Commission  Implementing 
Decisions  which  can  be  downloaded  from  EurLex  or  the  website  of  the  European  IPPC 
Bureau, along with the BAT reference documents205. The BAT conclusions describe the best 
available  techniques  for  each  industrial  sector  together  with  information  on  their 
applicability, their associated emission levels, monitoring and consumption levels and, where 
appropriate, relevant site remediation measures. 

BAT  conclusions  are  the  reference  for  permitting  authorities  in  setting  conditions  for 
installations covered by the IED. In this context, emission limit values have to be set by the 
competent authorities for all relevant pollutants that can be emitted from the installations. The 
technical working groups involved in the BAT information exchange leading to the drafting 
or revision of the BREFs and the Commission co-ordinating the process will for each of the 
sectors concerned assess which pollutants are to be dealt with (so-called Key Environmental 
Issues) and exchange information on the techniques to prevent or reduce emissions of those 
pollutants,  including  their  performance  and  costs.  However,  the  information  exchange  is  a 
voluntary process, so it will depend on the information that is provided by the stakeholders or 
can  be  gathered  by  the  European  IPPC  Bureau.  It  may  not  always  be  the  case  that  all 
'relevant' pollutants in the context of an individually permitted installation will be covered by 
the  BREFs  and  it  will  be  up  to  the  competent  authorities  concerned  to  determine  the 
additional pollutants for which an emission limit value may need to be set at the installation 
level. 

All  waste  incineration  and  co-incineration  facilities  are  covered  by  Chapter  IV  of  the  IED 
which  includes  special  minimum  provisions  for  waste  incineration  and  co-incineration 
plants206. Under the BAT conclusions adopted in November 2019, the  IED  sets BAT-AELs 
for emissions of PCDD/F and dioxin-like PCBs to air. Table 12 provides details of the new 

204http://efdb.apps.eea.europa.eu/?source=%7B%22query%22%3A%7B%22match_all%22%3A%7B%7D%7D

%2C%22display_type%22%3A%22tabular%22%7D 

205  http://eippcb.jrc.ec.europa.eu/reference 
206  Since  7  January  2014  Directive  2010/75/EU  on  industrial  emissions  repealed  and  replaced  the  Directive 

2000/76/EC on incineration of waste.  

95 

 
 
                                                           
BAT associated emission levelss for air. The BAT-associated emission level for water from 
incineration remains unchanged at 0.3 ng WHO-TEQ/l207. 

207  From the cleaning of waste gases 

96 

 
 
 
 
 
                                                           
Table 12 

BAT associated emission levels for waste incineration in Commission 
Implementing Decision (EU) 2019/2010 

Parameter 

Unit 

BAT-AEL 

Averaging period 

New plant 

Existing plant 

TVOC 

Mg/Nm3 

< 3 – 10 

< 3 - 10 

Daily average 

PCDD/F(1) 

Ng-ITEQ/Nm3 

< 0,01 – 0,04 

<0,01 – 0,06 

Average over the sampling 
period 

<0,01 – 0,06 

< 0,01 – 0,08 

Long-term sampling period(2) 

PCDD/F + 
dioxin-like 
PCBs (1) 

Ng WHO-
TEQ/Nm3 

<0,01 – 0,06 

< 0,01 – 0,08 

Average over the sampling 
period 

<0,01 – 0,08 

< 0,01 - 0,1 

Long-term sampling period(2) 

(1)  Either the BAT-AEL for PCDD/F or the BAT-AEL for PCDD/F + dioxin-like PCB applies 

(2)  The BAT-AEL does not apply if the emission levels are proven sufficiently stable. 

Definitions from the Waste Incineration BREF (2019) for right hand column of Table 12: 
Average over the  sampling period  – Average  value of three consecutive  measurements  of at  least 30  minutes 
each. 
Long-term sampling period – Value over a sampling period of 2 to 4 weeks.   

In 2010, the European Committee for Standardization (CEN) adopted part 4 of the standard 
EN 1948 for the determination of the mass concentration of PCDDs/PCDFs and dioxin-like 
PCBs  from  stationary  source  emissions  (covering  sampling  and  analysis  of  dioxin-like 
PCBs)208. 

Combustion  plants  (other  than  those  incinerating  waste)  with  a  rated  thermal  input  of  less 
than 50 MW are not covered by the IED209. The IED includes a review clause in Article 73(2) 
according  to  which  the  Commission  shall  review  the  need  to  control  emissions  from  these 
installations  and  shall  report  the  results  to  the  European  Parliament  and  the  Council 
accompanied by a legislative proposal, if appropriate. The review has already been performed 
and the Commission has submitted a new Directive on the limitation of emissions of certain 
pollutants  into  the  air  from  medium  combustion  plants,  the  directive  was  adopted  on  25 
November  2015210.  The  proposed  directive  targets  combustion  plants  with  a  rated  thermal 
input greater than 1 MW and less than 50 MW. It aims to reduce emissions of SO2, NOx and 
particulate matter but does not covers POPs. 

208  https://standards.globalspec.com/std/1663048/bs-en-1948-4 
209  For  installations  with  multiple  combustion  activities  with  a  rated  thermal  input  <50MW,  if  the  total  rated 
thermal  input  of  all  those  combustion  activities  within  the  installation  is  50  MW  or  more,  then  the  whole 
installation is covered by the IED’s provisions (Chapter II) (aggregation rule). 

210  http://eur-lex.europa.eu/resource.html?uri=cellar:a66f7f82-77a9-11e3-b889-

01aa75ed71a1.0023.04/DOC_1&format=PDF 

97 

 
 
 
 
 
                                                           
3.3.3.  Addressing domestic sources 

Domestic sources are also important for the release of unintentional POPs. The Commission 
has  issued  a  study  on  “Information  Exchange  on  Reduction  of  Dioxin  Emissions  from 
Domestic  Sources”211.  The  key  messages  regarding  labelling  were:  “Eco-labelling  schemes 
for solid fuel fired domestic appliances are established or planned in 10 Member States. The 
focus is on energy efficiency, low CO and dust (PM) emissions. Effects on dioxin and furan 
emissions are only indirect (reduced fuel consumption via increased energy efficiency).” The 
Commission published the results of the study in a brochure in order “to stimulate awareness 
raising, exchange of good practice as well as to encourage development of new solutions and 
measures”212. 

In this  respect,  currently under the EuP  Directive a preparatory study on “Solid Fuel  Small 
Combustion  Installations”  (Lot  15)  has  been  undertaken.  The  study  concluded  that  no 
measures with regards dioxins and furans will be taken.  
Grochowalski  (2009)213  describes  the  importance  that  use  of  copper  catalysts  marketed  in 
some European countries for cleaning domestic ovens may have for increasing the dioxin and 
furan emission from a domestic source by several orders of magnitude. Even assuming that 
only a small percent of the population would use such a catalyst, the release from this already 
relevant source could considerably increase. Therefore, the desirability of such practice might 
need to be examined. 
According to EMEP emissions data214 submitted by Member States under the Convention on 
Long-Range Transboundary  Air Pollution, the proportion  of PCDD/F emissions  to air from 
residential combustion for the total EU28 rose from 7% in 1990 to 23% in 2015. A number of 
Member States, notably eastern European countries (e.g. Poland, Hungary, Czechia, Poland, 
Romania),  note  increases  in  PCDD/F  emission  between  2000  to  2015.  The  proportion  of 
emissions  to  air from  residential  combustion in  2015 is  substantially  higher than the Union 
average for a number of eastern European or Baltic states (e.g Poland, 51%; Lithuania, 79%; 
Bulgaria, 75%; Croatia, 70%; Hungary, 65%; Slovenia, 65%).   

3.4. 

Information on the state of knowledge on stockpiles and contaminated sites 

Since the manufacture of most POPs ended some years ago, only a minor part is still in use in 
the  anthroposphere.  However,  exposure  of  humans  and  the  environment  can  continue  from 
landfills,  dumps,  stockpiles  or  contaminated  sites  where  a  large  part  of  the  POPs 
environmental  burden  has  been  deposited  or  stored  (Weber  et  al.  2008215,  Weber  et  al. 

211  BIPRO  (2009):  Information  Exchange  on  Reduction  of  Dioxin  Emissions  from  Domestic  Sources. 

REFERENCE: 070307/2007/481007/MAR/C4. FINAL REPORT. 09 April 2009.  
https://ec.europa.eu/environment/archives/dioxin/pdf/brochure09.pdf  
212  https://ec.europa.eu/environment/archives/dioxin/pdf/brochure09.pdf 
213  Grochowalski,  2009,  'UNEP  -  4-th  Toolkit  Expert  Meeting,  Preliminary  report  from  the  determination  of 
PCDDs/PCDFs,  PCBs  and  HCB/PeCB  and  HBCDD  from  combustion  of  coal  and  biomass',  Krakow 
University of Technology. 

214  http://www.ceip.at/ms/ceip_home1/ceip_home/webdab_emepdatabase/ 
215  Weber R, Tysklind M., Gaus C. et al. (2008) Dioxin- and POP-contaminated sites—contemporary and future 

relevance and challenges. Env Sci Pollut Res 15, 363-393. 

98 

 
 
 
                                                           
 
2011216).  Secondary  sources  of  POPs,  such  as  PFOS  and  PFOA,  may  also  include  the 
spreading of sewage sludge on agricultural land and discharge of waste water; alongside the 
disposal of air pollution control residues from waste incinerators to landfill which can contain 
POPs such as dioxins and dioxin-like PCBs, and which contribute to contamination of landfill 
leachate.  Therefore  the  identification  and  assessment  of  POPs  contaminated  sites,  deposits, 
their on-going presence in products such as sealants and paints along with an assessment of 
their current impact is a crucial part of assessing POPs exposure risk and management needs.  

The  European  Environmental  Agency  estimated  that  potentially  polluting  activities  have 
occurred  at  nearly  3  million  sites  and  stressed  that  investigation  is  needed  to  establish, 
whether  remediation  is  required  (European  Environment  Agency  2007).  The  European 
Commision  has  also  tentitively  estimated  that  a  total  number  of  2.5  million  potential 
contaminated sites exist across Europe, with around 14% expected to be highly likely to be 
contaminated and hence require remediation (European Commission 2014)217.  

There  is  no  Union  policy  or  Directive  that  specifically  addresses  the  issue  of  soil 
contamination218.  Indirect  protection  for  soils  is  provided  through  several  items  of  Union 
legislation,  such  as  the  Water  Framework  Directive,  Environmental  Liability  Directive, 
Industrial  Emissions  Directive  and  REACH  (Ecologic  Institute  2017219  European 
Commission  2014217).  For  example,  monitoring  under  the  Water  Framework  Directive, 
particularly if done in biota and/or sediment, should increasingly contribute to knowledge of 
the contamination of water bodies with several of the POPs and thus support the targeting of 
remediation. 

A  lack  of  specific  Union  legislation  on  soils  and  contaminated  land  means  that  there  is  no 
coherent and consistent approach to the discovery and investigation of POP contaminated soil 
sites  across  the  Union.  This  is  not  helped  by  the  fact  that  there  is  no  agreed  definition  for 
contaminated land or soils in Union policy or between Member States. 

The Soil Inventory report found that approximately 50% of Member States appear to have a 
register  of  contaminated  sites  in  place;  however,  it  was  recognised  that  the  existence  of  a 
register could not be linked to proactive action on soil protection (Ecologic Institute 2017209). 
This was supported by the JRC report on the management of contaminated sites in Europe, 
which found that 28 of the 39 countries surveyed maintained comprehensive inventories for 
Contaminated Sites, with only 12 out of 39 countries having made signficant progress since 
2011  in  the  mapping  of  polluting  activities  and  potentially  contaminated  sites.  The  most 
frequent contaminants were identified as mineral oils and heavy metals, accounting for nearly 
60%  of  contaminated  soil  sites,  with  PAHs  identified  for  11%  of  the  sites.  It  was  not 
mentioned how many of these sites have others POPs as a main contaminant, although ‘other’ 
contaminants accounted for 10%.   

216  Weber  R,  Watson  A,  Forter  M,  Oliaei  F.  Persistent  Organic  Pollutants  and  Landfills  -  A  Review  of  Past 

Experiences and Future Challenges. Waste Management & Research 29 (1) 107-121 (2011). 

217  European Commission (2014) Joint Research Centre (JRC) Reference Reports, Progress in the management 

of Contaminated Sites in Europe, Report EUR 26376 EN 

218  Note  that  the  POPs  Regulation  does  give  greater  onus  to  the  issue  of  contaminated  sites  encouraging 
Member States to include information within national reports and national implementation plans. However, 
there are no specific mandatory requirements to develop such data. 

219  Ecologic Institute, Berlin (2017) Updated Inventory and Assessment of Soil Protection Policy Instruments in 

EU Member States, Final Report 08 February 2017 

99 

 
 
                                                           
A  number  of  Member  States  have  national  policies  in  place  which  specifically  looks  at 
dealing  with  land  contamination,  with  the  identification,  prioritisation,  and  remediation  of 
sites.  In  Austria,  the  Law  on  the  Remediation  of  Contaminated  Sites  required  the 
prioritisation of polluted sites according to the severity of risks. In Germany, the Federal Soil 
Conservation Act and Federal Soil Conservation and Contaminated Land Regulations provide 
the  standards  and  procedural  steps  for  the  investigation  and  management  of  contaminated 
sites with  the aim of protecting  and restoring  soil functions. The Netherlands have the Soil 
Protection  Act  which  focuses  on  the  remediation  of  contaminated  sites  and  sets  out  a 
programme  of  actions  to  improve  knowledge  and  understanding  on  risk  assessment  and 
remediation.  In the UK,  Part 2A of the Environmental  Protection Act  covers Contaminated 
Land and places the responsibility of identifying, prioritising,  assessing, and determining of 
site as Contaminated Land by local authorities at a regional level. The remediation of the sites 
then aims to follow the ‘polluter pays’ principle. 

In several Member States there are no apparent binding policy instruments in place which go 
beyond the Union Directives on waste, industrial installations, and water. However, this is an 
evolving area of policy focus with some Member States, such as Poland, Portugal, and Spain 
undergoing  developments  in  policy  to  specifically  address  contaminated  soils  (Ecologic 
Institute  2017219).  There  is  also  a  strong  reliance  in  some  Member  States  on  the  link  to 
development, with contamination issues addressed under the planning regime, particularly for 
the redevelopment of brownfield sites. For all Member States, the remediation of sites tends 
to be closely linked to the availability of state funding and broader development needs.   

Investigations  tend  to  involve  the  comparison  of  contaminant  concentrations  against 
screening values (SVs), which are referred to under a diverse variety of terms (for example, 
soil  quality  standards,  guidance  values,  target  and  intervention  values,  trigger  values, 
maximum, acceptable concentrations etc.). The SVs are based on the application of exposure 
and  toxicological  modelling  for  varying  receptors  (human  health,  controlled  waters,  and 
ecology),  although  these  is  no  coherent  framework  across  Europe  for  the  derivation.  JRC 
found  that  the  main  methodologies  adopted  by  Member  States  were  the  European 
Commission Technical Guidance Document on Risk Assessment220, the procedures adopted 
by  RIVM  in  The  Netherlands,  methods  developed  in  the  United  States (such as ASTM221), 
and  the  former  Soviet  Union  procedures  and  values  (mainly  Central  and  Eastern  European 
Countries).  The  use  of  SVs  are  often  based  on  requirements  established  under  the  national 
regulatory framework, with the type and number of substances with SVs varying by country 
and hence do not always include POPs. 

A  number  of  Member  States  appear  to  be  reviewing  their  SVs  in  relation  to  POPs.    The  
Environment Agency of England (2017)222 has recognised the need for SVs for various POPs 
to support the Environmental Permitting Regulations and appraisal of standard rules permits 

220  European Commission, Joint Research Centre, European Chemicals Bureau, Technical Guidance Document 
on Risk  Assessment in support of Commission Directive  93/67/EEC on Risk  Assessment for new  notified 
substances,  Commission  Regulation  (EC)  No.  1488/94  on  Risk  Assessment  for  existing  substances, 
Directive  98/8/EC  of  the  European  Parliament  and  of  the  Council  concerning  the  placing  of  biocidal 
products on the market, Part II, EUR 20418 EN/2 

221  ASTM  International,  Guide  for  Risk-Based  Corrective  Action  (PS104-98  (1998)  –  now  superseded  by 

E2081-00 (2015)) 

222  Environment  Agency  (2017),  Derivation  and  use  of  soil  screening  values  for  assessing  ecological  risk, 

Report – ShARE id26, November 2017, Environment Agency, Bristol 

100 

 
 
                                                           
for the application of waste materials to land. This has included an update in the approach for 
the derivation and use of soil screening values for assessing ecological risk, with published 
soil  screening  values  for  POPs,  including  benzo(a)pyrene,  HBCDD,  HCB,  PCP,  PeCB, 
PCBs, PCDDs/PCDFs, PFOS and PFOA.   
The JRC223 indicate that the preferred use of SVs by many countries is as trigger levels for 
site  investigations,  with  the  final  decision  of  remediation  based  on  site  a  site-specific 
assessment,  taking  account  of  site-specific  land  use  and  environmental  conditions.  Some 
Member States have derived generic SVs using models and/or software that can be adapted 
on a site-by-site basis and utilised as part of a site-specific quantitative risk assessment, such 
as  contaminated  land  exposure  assessment  (CLEA)  model  derived  by  the  Environment 
Agency  of  England224  and  exposure  model  CSOIL  developed  by  the  RIVM225  for  the 
Netherlands.  

3.4.1.  PCB contaminated sites and deposits 
Weber et  al.  (2011)226  note that the legacy of previous industrial  manufacture coupled with 
(historically) poor waste management and landfill management has resulted in an important 
and  long-term  source  of  POPs  to  the  environment.  Such  previously  ongoing  practises  can 
result in an on-going source of POPs to the wider environment (particularly groundwater and 
rivers) via leaching and flooding.  

Measurement data for PCBs in  ambient  air has  suggested that urban  areas represent an on-
going source of POPs to the environment. Diefenbacher et al. (2016)227 carried out a passive 
air sampling campaign in Zurich in 2011 and 2013 reporting concentrations of a range of six 
indicator PCB congeners ranging from 54 to 3160 pgm-3. A correlation between ambient air 
concentrations and the number of buildings built between 1955 and 1975 was suggested by 
the authors to demonstrate that PCB containing building materials such as sealants represent 
on-going important primary sources. 
Jartun et al. (2009)228 undertook a study involving the analysis of PCBs in old paint samples 
from  Bergen,  Norway,  and  reported  concentrations  of  PCBs  up  to  3.4  g/kg.  Estimates  of 
historical use of PCBs in Norway suggested that out of the 1140 tonnes used in applications, 
approximately 5% (7.8 tonnes) were used in paint applications. PCB samples collected from 
a concrete bridge previously coated with PCB-containing paint were separated into outer- and 
inner samples indicating that PCBs are still present in high concentrations despite renovation.  

223  JRC  (2007)  ‘Derivation  methods  of  soil  screening  values  in  Europe.  A  review  and  evaluation  of  national 

procedures towards harmonisation’, EUR 22805 EN - 2007 

224  Environment  Agency  (2009)  Updated  technical  background  to  the  CLEA  model,  Science  Report: 

SC050021/SR3 

225  Brand, E. Otte, P. F, Lijzen, J.P.A. (2007) CSOIL 2000: an exposure model for human risk assessment of 

soil contamination. A model description, RIVM report 711701054/2007 

226  Weber, R., Watson, A., Forter, M. and Oliaei, F. (2011) Persistent organic pollutants and landfills – a review 

of past experiences and future challenges. Waste Management and Research, 29, 107–121 

227  Diefenbacher,  P.S.,  Gerecke,  A.C.  Bogdal,  C.  and  Hungerbühler,  K.  (2016)  Spatial  Distribution  of 
Atmospheric  PCBs  in  Zurich,  Switzerland:  Do  Joint  Sealants  Still  Matter?  Environmental  Science 
Technology, 50, 232−239 

228  Jartun,  M.,  Ottesen  R.T.,  Steinnes,  and  Volden  T.  (2009)  Painted  surfaces  –  Important  sources  of 
polychlorinated  biphenyls  (PCBs)  contamination  to  the  urban  and  marine  environment.  Environmental 
Pollution, 157, 295-302 

101 

 
 
 
                                                           
Concentrations  of  PCBs  in  near  surface  soils  (top  20  cm)  were  found  to  be  of  concern  in 
central  Romania.  The  ‘background’  levels  of  PCBs  were  believed  to  be  as  a  result  of  the 
deposition  of  PCB  emissions  from  industry  (primarily  the  metal  industry,  including  lead 
manufacture,  pig  iron  and  steel  manufacture  centres).  Although,  the  levels  of  PCB  release 
were  considered unlikely  to increase, the  concentrations  of PCBs identified in  surface soils 
were deemed to require continued monitoring (Science Communication Unit 2013)229. 
In several European rivers, the maximum level set for dioxin-like PCBs in food230 was found 
to  have  been  exceeded  in  fish  (e.g.  BUWAL  2010231,  NIP  Germany232).  In  a  study  in 
Switzerland  –  considering  this  European  maximum  levels  for  dioxin-like  PCBs  –  such  fish 
contamination  could  be  tracked  back  to  PCB  point  sources  (e.g.  landfill  containing 
condensers  or  metal  smelting  industry  having  used  and/or  processed  PCB  containing 
equipment) (Zennegg et al. 2010233). Due to the experiences with PCB contaminated sites and 
their impact on fish in surface waters the Swiss environmental agency (BUWAL) is currently 
establishing a manual for competent authorities to track potentially PCB contaminated sites 
(Tremp  2011234).  No  similar  mapping  approach  to  track  directly  the  point  sources  for  PCB 
contamination  has  been  discovered  in  the  assessment  of  NIPs  of  Member  States  and  any 
Union agency reports. The only other example identified is a comprehensive mapping of PCB 
contaminated  sites  established  for  France  by  a  NGO235.  Wimmerová  et  al.  (2015)236 
investigated  the  relationship  between  blood  serum  PCB  concentrations  and  distance  for 
residents  living  around  a  former  major  PCB  manufacture  site  in  Slovakia.  The  authors 
reported  that  elevated  serum  concentrations  could  be  linked  to  the  manufacture  site  at 
distances of up to 70km which demonstrates the importance of historical contamination hot-
spots as on-going sources of contamination. 
A review carried out by Weber et al. (2014)237 of data on the transfer of PCBs and PCDD/Fs 
from soil to meat products highlighted that regulatory limits can be exceeded even under free 
range grazing conditions. While most of the meat and milk samples on the European market 
meet  regulatory  limits,  the  study  discussed  a  number  of  cases  where  meat  from  free  range 
manufacture entering the food-chain has exceeded regulatory limits. Whilst there have been a 
number  of  incidents  in  the  past  when  contaminated  feed  has  entered  the  food  manufacture 

229  Science Communication Unit, University of the West of England, Bristol (2013) Science for Environmental 
Policy In-depth Report: Soil Contamination: Impacts on Human Health. Report produced for the European 
Commission DG Environment, September 2013. 

230  (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs. 
231  BUWAL  Schweizer  Bundesamt  für  Umwelt  (2010)  Polychlorierte  Biphenyle  (PCB)  in  Schweizer 

Gewässern. Abschlussbericht 26.04.2010.  

232  Federal Republic of Germany (2006) National Implementation Plan. Berlin, 03 April 2006. 
233  Zennegg  M,  Schmid  P,  Tremp  J.  PCB  fish  contamination  in  Swiss  rivers  –  tracing  the  point  sources. 

Organohalogen Compounds, 72, 362-365 (2010).   

234  Tremp J. (BUWAL; Schweizer Bundesamt für Umwelt), Personal communication 20.06. 2011. 
235  http://www.robindesbois.org/PCB/PCB_hors_serie/ATLAS_PCB.html 
236  Wimmerová, S., Watson, A., Drobná, B., Šovčíková, E., Weber, R., Lancz, K., Patayová, H., Richterová, D., 
Koštiaková, V., Jurečková, D., Závacký, P., Strémy, M., A. Jusko, T.A., Murínová.  L.P., Hertz-Picciotto, I. 
and Trnovec, T. (2015). The spatial distribution of human exposure to PCBs around a former production site 
in Slovakia. Environmental Science and Pollution Research, 22, 14405–14415. 

237  Weber, R., Albrecht, M., Ballschmiter, K., Berger, J., Bruns-Weller, E., Kamphues, J., Körner, W., Malisch, R., 
Nöltner, T., Schenkel, H., Severin, K., Vossler, C. and Wahl, K. (2014) Safe food production from free range 
beef – minimizing TEQ-levels in meat by tracking PCB sources. Organohalogen Compounds, 76, 815-818. 

102 

 
 
                                                           
chain resulting in exceedance of regulatory levels (e.g. Malisch and Kotz, 2014)238 the source 
of the contamination was known and could be traced. However, the source of contamination 
of  foodstuffs  from  free  range  manufacture  is  more  challenging  as  the  supply  chain  is  more 
complex. A survey of German meat samples collected between 2009 and 2012 revealed that 
animals grazing on flood plains impacted by historical industrial chemical manufacture could 
result  in  exceedance  of  regulatory  limits.  Weber  et  al.  (2014)  also  discussed  a  number  of 
other  possible  sources  of  contamination  that  may  result  in  meat  products  becoming 
contaminated. These included ingestion of dredged sediments, application of sewage sludge, 
use of contaminated paints on silos and rubber belts used for feeding calves. These findings 
suggest that identification and monitoring of potential contamination sources would form an 
important part of European food surveillance. 

3.4.2.  HCH contaminated sites and waste deposits  

Technical HCH (comprised chiefly of the α and β isomers) was used as a pesticide within the 
Union as an alternative to DDT from the 1940s onward239. However concerns over the safety 
of HCH meant that it was gradually replaced by lindane which contains 99% wt/wt of the -
isomer of HCH. The International HCH and Pesticides Association (IHPA) (2006a)240,241 note 
that  the  inefficient  manufacturing  processes  for  lindane  meant  that  for  every  one  tonne  of 
commercial  lindane  produced  up  to  ten  tonnes  of  hazardous  waste  containing  the  α  and  β 
isomers  was  also  produced,  requiring  final  treatment  or  disposal.  Vijgen  et  al.  2011242 
provides an estimate of 300,000 tonnes of lindane used within the Union between 1950 and 
2000,  which  would  equate  to  1.8  to  3  million  tonnes  of  HCH-contaminated  wastes  which 
required safe disposal. 

The identification of contaminated sites of former manufacture or waste disposal represents a 
signficiant  challenge.  Wycisk  et  al.  (2013)243  provides  a  case  study  detailing  such  a  site  in 
Bitterfeld, Germany. The site at Bitterfeld in the Eastern part of Germany was formerly used 
for  the  manufacture  of  a  number  of  chloro-organic  substances  including  lindane  and  DDT, 
which were produced there between 1951 and 1982. Waste materials containing the isomers 
α and β-HCH were disposed of on site as part of the manufacture process. Wycisk et al. detail 
a  sampling  and  analysis  campaign  over  a  ten  year  period  which  indicates  contamination  of 
both  soil  and  ground  water  within  Bitterfeld  requiring  remediation  over  an  area  of 
approximately 40 km2. Analysis reported in  the Wycisk  et  al. paper also  quotes a sampling 

238  Malisch, R. and Kotz, A. (2014) Dioxins and PCBs in feed and food — Review from European perspective. 

Science of The Total Environment, 491–492, 2–10. 

239  Whiting et al, 2012, ‘A further update of the UK source inventories for emissions to air, land and water of 
dioxins,  dioxin-like  PCBs,  PCBs  and  HCB,  incorporating  multimedia  emission  inventories  for  nine  new 
POPs under the Stockholm Convention’, Report for Defra, UK CB0429. 

240  International  HCH  and  Pesticide  Association  (2006a)  The  legacy  of  lindane  HCH  isomer  production. 
Mainreport; http://www.ihpa.info/docs/library/reports/Lindane%20Main%20Report%20DEF20JAN06.pdf  
241  International  HCH  and  Pesticide  Association  (2006b)  The  legacy  of  lindane  HCH  isomer  production. 

Annexes; http://ew.eea.europa.eu/Agriculture/Agreports/obsolete_pesticides/lindane_annexes.pdf/ 

242   Vijgen et al. (2011). HCH as new Stockholm Convention POPs – a global perspective on the management of 

Lindane and its waste isomers. Env Sci Pollut Res. 18, 152-162.  

243  Wycisk  et  al,  2013,  ‘Integrated  methodology  for  assessing  the  HCH  groundwater  pollution  at  the  multi-
source  contaminated  mega-site  Bitterfeld/Wolfen’,  Environmental  Science  and  Pollution  Research  (2013) 
20: 1907–1917. 

103 

 
 
 
                                                           
and  analysis  study  for  fish  in  the  nearby  Mulde  and  Elbe  rivers,  where  elevated  levels  of 
HCH were detected in biological samples.    
Two  further  European  case  studies  are  quoted  by  the  IHPA  2006244  on  HCH  in  the 
Netherlands  and  Spain  (Basque  country).  These  cases  have  proven  that  often  the  original 
waste  problem  has  additionally  resulted  in  a  huge  soil  problem.  For  example,  the  original 
amount  of  5  500  tonnes  of  HCH  waste  in  the  Netherlands  has  created  a  regional  soil 
contamination of nearly 400,000 m3. Similar experiences can be stated from Basque Country 
where nearly 90,000 tonnes of HCH waste has led to a soil pollution of 500,000 to 1 million 
tonnes of soil contaminated with HCH. 

A review on global perspective on the management of lindane and its waste isomers (Vijgen 
et  al.  2011)245  identifies  the  following  Member  States  with  former  lindane  manufacture: 
Austria,  Czechia,  France,  Germany,  Hungary,  Poland,  Romania,  Slovakia,  Spain  and  The 
Netherlands. Additionally in Europe Macedonia and Switzerland have produced lindane. 

A recent review on the current status of sites that are potentially contaminated with lindane in 
the Union found that many Member States have not fully identified sites of concern (ERA-
Consult, 2016)246. In their study no information was provided on HCH contaminated sites by 
Bulgaria  and  Croatia  where  the  manufacture  of  lindane  is  understood  to  have  been 
undertaken.  Several  Member  States,  such  as  Austria,  Hungary,  Spain  and  Slovakia  have 
identifed  potentially  contaminated  sites,  but  little  or  no  further  investigations  have  been 
undertaken  to  date  and/or  remediation  is  still  pending.  Other  countries,  such  as  Czechia, 
Germany,  Italy,  Poland,  Romania  and  The  Netherlands  are  more  advanced,  and  have  been 
remediating  some  sites  for  many  years,  although  not  all  sites  have  been  subject  to  the  full 
investigatory process.  However, despite this a large contamination  reservoir, in  the scale of 
100s of 1000s of tonnes of HCH waste is still belived to be present across the Union (ERA-
Consult, 2016). 

The  chemical  manufacture  sites  were  typically  located  near  rivers  and  river  flood  areas, 
which has contributed to the diffuse mobilisation of contamination, such as that identified at 
the Sabinaniog and Vitoria site and the Ebro River in Spain and Bitterfield-Wolfen site and 
Elbe River in Germany (ERA-Consult, 2016). This provides so called ‘mega sites’ in need of 
remediation,  with  the  high  associated  financial  cost  and  potential  cross  boundary  migration 
acting as constaints to the investigation and clean up of these areas. 

In August 2019 the Lindanet project was launched to join the efforts across European regions 
to  work  towards  the  identification  and  improvement  of  contaminated  HCH  (Lindane)  sites, 
including  the  sharing  of  best  practice,  development  of  an  action  plan  for  each  region,  and 
stakeholder groups for knowledge exchange. The Lindanet project is led by the government 
of Aragon (Spain), with partners in  Germany, Italy, Poland and Czechia. The first thematic 
workshop was  hosted in  November 2019, with  further workshops  planned for Spring 2020. 

244  http://www.ihpa.info/docs/library/reports/Lindane%20Main%20Report%20DEF20JAN06.pdf 
245  Vijgen,  J.,  Abhilash,  P.  C.,  Li  Y.F.,  Lal,  R.,  Forter,  M.,  Torres,  J.,  Singh,  N.,  Yunus,  M.,  Tian,  G.  and 
Schäffer,  A.  (2011).  Hexachlorocyclohexane  (HCH)  as  new  Stockholm  Convention  POPs—a  global 
perspective  on  the  management  of  Lindane  and  its  waste  isomers,  Environmental  Science  and  Pollution 
Research Vol. 18(2), 152- 162. 

246  ERA  Consult.  (2016)  Lindane  (persistent  organic  pollutant)  in  the  EU,  study  for  the  PETI  Committee, 

European Union, 2016. 

104 

 
 
                                                           
The  project  is  due  to  complete  on  31  January  2023  and  has  an  associated  budget  of  €1.3 
million. 

3.4.3.  Other POPs Pesticides 

Sites  contaminated  with  POP  pesticides  are  particularly  a  challenge  in  East  European 
countries  and  are  associated  with  POP-pesticide  stockpiles  and  former  sites  where  POP 
pesticides have been stored. These sites pose critical exposure risk for local population (IHPA 
2011)247 and can contribute to contamination of food in the Union.  

3.4.4.  Contaminated sites from unintentionally formed POPs (PCDD, PCDF, PCB,  HCB, 

PeCB, PAHs)  

A  review  study  by  Weber  et  al  (2018)248  highlights  the  importance  of  identifying  and 
managing sites contaminated by dioxins and dioxin-like PCB to prevent ingress back into the 
food chain. This includes how wastes containing dioxins and PCBs are managed to prevent 
loss to land leading to effects in the food chain. The review comments on a number of cases 
where contamination of eggs and meat by dioxins and furans have occurred, particularly free 
range  chickens,  with  identification  of  the  main  sources  of  contamination  coming  from 
historically  contaminated  soils,  PCBs  present  at  farms  (including  use  if  open  applications 
such as paint and sealants). The study concludes that further research is needed. 

Similarly at Union level a review of the risks associated with dioxins and dioxin-like PCBs 
by  EFSA  resulted  in  a  reduction  of  the  safe  tolerable  weekly  intake  (TWI)  to  2  picograms 
WHO-TEQ/kg  bw249.  This  represents  a  reduction  in  the  TWI  by  a  factor  of  seven.  The 
reduction in the TWI has primarily been applied in order to reduce the risk of health effects 
on  human  semen  quality.  The  authors  comment  that  the  main  dietary  exposure  within  the 
Union came from fish, cheese and red meat. 

At country level Sweden has comprehensively assessed PCDD/PCDF contaminated sites and 
started with remediation and securing activities.  

In  respect  to  PeCB  and  HCB,  an  UNEP  report  from  the  POP  Reviewing  Committee  also 
highlights  the relevance  of deposited HCB/PeCB wastes from organochlorine  manufactures 
which amounted to 10,000 tonnes for individual factories (UNEP 2010)250.Within the Union, 
only one such case has been documented, including the resulting releases to water (Heinisch 
et  al.  2006)251.  The  other  key  point  of  release,  urban  wastewater  treatment  works,  is  more 
likely  to  be  attributed  to  a  range  of  minor  sources  as  contamination  in  the  waste  flows, 
ratherthan to manufacture itself. 

247  www.ihpa.info 
248  Weber et al (2018) ‘Reviewing the relevance of dioxin and PCB sources for food from animal origin and the 
need for their inventory, control and management’, Environmental science for Europe Vol 30 issue 42. 

249  https://www.efsa.europa.eu/en/press/news/dioxins-and-related-pcbs-tolerable-intake-level-updated 
250  Stockholm  Convention  (2010):  Information  document  for  the  6th  POP  Reviewing  Committee  meeting 

(UNEP/POPs/POPRC/6/INF/21). 

251  Heinisch E, Kettrup A, Bergheim W, Wenzel S. (2007) Persistent chlorinated hydrocarbons, source-oriented 
monitoring  in  aquatic  media.  6.  Strikingly  high  contaminated  sites.  Fresenius  Environ  Bull  16(10):  1248-
1273. 

105 

 
 
 
 
                                                           
Further relevant contaminated sites concern the former disposal of residues from chloralkali 
plants  highly  contaminated  with  PCDD/F,  PCN,  PAH  and  Barium.  One  case  revealed  the 
significance of such contaminations252. This case was subsequently remediated253. 
In the UK, the Food Standard Agency254 has identified the need for further investigation into 
the levels of PCDD/F (which are not currently routinely analused) in rural sections of canal 
systems. These are commonly dredged and recycled directly to agricultural land. The impact 
of  this  on  soil  concentrations  and  on  the  foodchain,  particulalry  through  the  ingestion  of 
herbage and soil by animals reared on these areas, is currently poorly understood. 

3.4.5.  PBDE contaminated sites 

POP-PBDEs  contaminated  sites  or  hot  spots  have  mainly  been  reported  from  primitive 
treatment  of  electronic  waste  (Wong  et  al.  2007)255  and  from  the  release  of  PBDE  from 
landfills (Weber et al. 2011)256. The assessed landfills were located in the US, Canada, Japan 
and  South  Africa.  PBDE  have  been  detected  in  the  leachates  or  ground  water  in  all  the 
landfills  under  investigation.  There  are  also  studies  that  have  been  made  in  European 
countries and in which PBDE has been analysed in landfill leachates (COHIBA 2011)257.  

For  PBDE  manufacture  sites  or  areas  where  PBDE  have  been  used,  e.g.  in  the  plastic 
industry,  no  reports  on  contaminated  sites  have  been  found  in  the  public  domain.  A 
systematic assessment of environmental contamination in the life cycle of PBDE is missing 
in this respect.  

Canada, under the National Chemicals Management Plan, provided additional information to 
the SC on the potential of landfill leachate to provide an ongoing source of  POP-PBDEs to 
the environment. A survey was carried out at 10-12 Canadian municipal solid waste landfills 
to  determine  leachate  PBDE  concentrations  and  the  potential  for  removal  with  remedial 
treatment.  The  survey  revealed  a  100%  detection  rate  for  POP-PBDEs  in  leachate  with 
median concentrations of 93 ng/L, 28 ng/L and 9 ng/L for tetra-BDEs, penta-BDEs and hexa-
BDEs, respectively. The survey also assessed treatment efficiencies for the removal of POP-
PBDEs  from  leachate  and  reported  an  85%  removal  rate.  Based  on  an  approximate  total 
volume of landfill leachate collected in 2011, the cumulative annual loadings to the Canadian 
environment were estimated to be 0.3 kg, 0.1 kg and 0.03 kg for tetra-, penta- and hexa-BDE, 
respectively. 

252  Lutz,  G.;  Otto,  W.;  Schoenberger,  H.;  Neue  Altlast  –  hochgradig  mit  polychlorierten  Dibenzofuranen 
belastete  Rueckstaende  aus  der  Chlorerzeugung  gelangten  jahrzehntelang  in  die  Umwelt,  Muellmagazin 
4(3), pp 55-60. 

253  Otto, W. et al.; Case study on remediation of a  German city contaminated by a chloralkali plant and PCP 

production, Organohalogen Compounds 68, pp 880-885. 

254  Nicholson, F, Metcalf, P, Gale, P, Taylor, M, Tompkins, D, Tyrrel, S, Longhurst, P, Weeks, J and Hough, R. 
(2016) Final Report – Identification and Proritisation of risks to food safety and quality associated with the 
use  of  recycled  waste-derived  materials  in  agriculture  and  other  aspects  of  food  production,  FS301020, 
Prepared for the Food Standards Agency, 3 August 2016. 

255   Wong MH et al. (2007) Export of toxic chemicals  – A review of the case of uncontrolled electronic-waste 

recycling. Environmental Pollution 149, 131-140. 

256  Weber  R,  Watson  A,  Forter  M,  Oliaei  F.  Persistent  Organic  Pollutants  and  Landfills  –  A  Review  of  Past 

Experiences and Future Challenges. Waste Management & Research 29 (1) 107-121 (2011). 

257  https://www.isi.fraunhofer.de/content/dam/isi/dokumente/ccn/2011/COHIBA-WP4-Final-report_1.pdf  

106 

 
 
 
                                                           
3.4.6.  PFOS contaminated sites 

The  landfilling  of  waste  originating  from  the  manufacture  and  use  of  PFOS  and  other 
perfluorinated compounds has generated large contaminated sites (Bantz 2011258, Kroefges et 
al.  2007259,  Oliaei  et  al.  2011260,  Weber  et  al.  2011256).  Therefore,  the  need  of  a 
comprehensive  assessment  of  PFOS  contaminated  sites  along  the  life  cycle  of  PFOS  is 
reflected also in the recommendations of the COP-5261. 

A systematic assessment on PFOS contaminated sites has not yet been reported by any of the 
Member  States.  However,  some  ad  hoc  work  has  started  in  Europe  in  recent  years.  For 
example,  in  2015  Sweden  undertook  a  national  screening  programme  for  environmental 
toxins, including PFASs in surface and groundwater with over 2,000 potential sites identified. 
Five hundred samples were collected, which were combined with 5,600 older samples and a 
survey of potential sources of PFASs. The results revealed over 2,000 potential local sources 
of contamination, although insufficient information was available to identify individual point 
sources (KEMI 2016)262. 

In one instance, drinking water was polluted for more than 4 million people (Kroefges et al. 
2007).  The  PFOS/PFOA  within  contaminated  sludge  was  imported  into  Germany  from  the 
Netherlands  as  a  hazardous  waste  conforming  to  the  Waste  Shipment  Regulation  for  final 
treatment  and  disposal.  However,  in  a  criminal  act,  the  receiving  company  re-labelled  the 
sludge  as  bio-solid  for  soil  improver  and  sold  it  to  farmers  which  treated  the  agricultural 
fields with it thereby contaminating many areas around Soest, in the North Rhine-Westphalia 
part of Germany. From there, perfluorinated compounds leached into rivers and the drinking 
water reservoir (Skutlarek et al. 2006).263 

Other  PFOS  contaminated  sites  have  been  described  for  application  sites  of  fire  fighting 
foams (Norwegian Pollution Control Agency264, State of Jersey 2004265, Weber et al. 2011). 
The  Danish  Environmental  Protection  Agency  (DEPA)  found  that  fire  training  at  civil  and 
military  airports  was  a  high  potential  source  of  PFAS  contamination  (Concawe  2016)266. 
Concawe noted that the PFAS profiles on contaminated sites can vary in response to different 
fire-foam types and compositions being utilised. 

258  Bantz I, Valentin I, Weber R (2011) Monitoring of PFOS and PFC Pollution in Düsseldorf/Germany. 11th International 

HCH and Pesticide Forum, Baku, Azerbaijan 7-9. September 2011.  

259  Kröfges  P  et  al.  (2007)  PFOS/PFOA    Contaminated  Megasites  in  Germany  Polluting  the  Drinkingwater  Supply  of 

Millions of People. Organohalogen Compd. 69, 877–880 (2007). 

260  Oliaei,  F.,  Kriens,  K..  Kessler,  K.  (2006)  investigation  of  perfluorochemical  (PFC)  contamination  in Minnesota  phase 

one. Report to Senate Environment Committee February 2006. 

261  UNEP  (2011)  Work  programmes  on new  persistent  organic  pollutants.  5th  Conference  of  Parties,  Geneva  21-25  April 

2011 (UNEP./POPS/COP.5/15). 

262  KEMI  (Swedish  Chemicals  Agency)  (2016)  Strategy  for  reducing  the  use  of  highly  fluorinated  substances,  PFAS. 

Interim report as part of a Government assignment. Report 11/16. 

263  Skutlarek D, Exner M, Färber H (2006) Perfluorinated Surfactants in Surface and Drinking Waters Environ Sci Pollut 

Res 13 (5) 299–307 (2006). 

training areas. TA- 2444/2008. 

264   Norwegian  Pollution  Control  Agency  (2008)  Screening  of  Polyfluorinated  Organic  Compounds  at  four  firefighting 

265   State of Jersey (2004) Jersey Airport Fireground Remediation – Deed of settlement. Lodged au Greffe on 19th October 

2004. 

266  Concawe (2016) Environmental fate and effects of poly- and perfluoroalkyl substances (PFAS), June 2016 

107 

 
 
 
                                                           
A further study by the Finnish Environment Agency (Syke, 2019)267 assessed four sites used 
for  training  of  fire-fighters  using  PFAS-based  foams.  Monitoring  of  groundwater  and 
assessment of environmental fate concluded that the use of PFAS (which includes PFOS and 
PFOA)  within  an  open  dispersive  application  like  fire-fighting  meant  the  possible 
contamination  of  the  environment  with  the  very  high  mobility  of  PFAS  to  penetrate  to 
groundwater  bodies.  The  study  notes  that  further  recommendations  are  needed  for 
remediation of the sites following the contamination identified. 

A  study  of  perfluoroalkyl  acids  (PFAAs)  contamination  around  Stockholm  Arlanda  airport 
demonstrated  contamination  of  water,  sediment  and  biota  (Perch)  as  a  result  of  the  use  of 
aqueous  fire  fighting  foams  at  the  airport  fire  training  facilities  (Ahrens  et  al.  2015)268.  An 
analysis  of  water  samples  covering  a  period  from  2009  to  2013  showed  no  significant 
decreasing  trend  and  suggested  that  the  airport  may  represent  a  long-term  source  into  the 
local environment. 

The distribution of a range of PFAAs, including PFOS, was determined in soil, groundwater, 
surface  water,  a  drinking  water  supply  well  and  fish  muscle  around  a  decommissioned 
military airfield in Stockholm, Sweden (Filipovic et al. 2015)269. The study reported that the 
site, which was abandoned in 1994, could still represent a point source of PFAAs. PFOS and 
PFOA were found to be ubiquitous in soils at the site with concentrations up to 8520 ng/g and 
in groundwater up to 51,000 ng/l and surface waters up to 79 ng/l. This suggests that previous 
use of PFAAs at the site has resulted in the contamination of the local aquifer. 
The  analysis  of  leachate  from  municipal  solid  waste  landfills  in  Denmark  (Bossi  2008270), 
Germany  (Busch  2010271)  and  Sweden  (Woldegiorgis  2006272)  has  revealed  that  leachates 
can  contain  high  levels  of  PFCs  including  PFOS.  An  assessment  of  deposited  wastes  and 
related releases has not been performed up to now.  

A Europe-wide study of 90 waste water treatment plant effluents, in 27 countries, identified 
PFOA, PFHpA and PFOS in 90% of the waters (Loos et al. 2012)273. The discharge of waste 
waters is one of the principal routes of entry of PFOS into surface waters, with waste water 
being a major contributor to river flows. There is also the potential for the contamination  of 
soil and water resources by the application of contaminated sewage sludge (solid waste of the 
waste water treatment process) to agricultural land. A study in Bayreuth, Germany, found that 
PFOA was fully discharged into the river, while about half of the PFOS was retained in the 

267  SYKE 

‘Environmental 
http://hdl.handle.net/10138/301524. 

(2019), 

studies 

and 

risk 

assessment 

of 

perfluorinated 

alkyl 

compounds’, 

268  Ahrens, L., Norström K., Viktor, T., Palm Cousins, A. and Josefsson, S. (2015) Stockholm Arlanda Airport as a source 

of per- and polyfluoroalkyl substances to water, sediment and fish. Chemosphere, 129, 33-38. 

269  Filipovic,  M.,  Woldegiorgis,  A.,  Norström,  K.,  Bibi,  M.,  Lindberg,  M.  and  Österås,  A-H  (2015)  Historical  usage  of 
aqueous film forming foam: A case study of the widespread distribution of perfluoroalkyl acids from a military airport to 
groundwater, lakes, soils and fish Chemosphere, 129, 39-45. 

270   Bossi, R., Strand, J., Sortkjær, O. Larsen, M.M. (2008) Perfluoroalkyl compounds in Danish wastewater treatment plants 

and aquatic environments. Environment International 34(4): 443–450. 

271   Busch,  J.  (2009)  Analysis  of  poly-  and  perfluorinated  compounds  (PFCs)  in  landfill  effluent  using  HPLC-MS/MS. 

Lüneburg. Bachelor thesis (Diplomarbeit). 

272   Woldegiorgis,  A.,  Anderson,  J.,  Remberger,  M.,  Kaj,  L.  (2006).  Results  from  the  Swedish  National  Screening 

Programme 2005. Subreport 3: Perfluorinated Alkylated Substances (PFAS) IVL report B1698. Stockholm. 

273  Loos, R. Carvalho, R. Comero, S., Antonio, D.C. Ghiani, M. Lettieri, T. Locoro, G. Paracchini, B. Tavazzi, S. Gawlik, 
B.M. Blaha, L. Jarosova, B. Voorspoels, S. Schwesig, D. Haglund, P. Fick, J., Gans, O. (2010) European Commission 
JRC Scientific and Policy Reports, EU Wide Monitoring Survey on Waste Water Treatment Plant Effluents, European 
Union, Luxembourg. 

108 

 
 
                                                           
sewage  sludge  (Becker  et  al  2010)274.  PFAAs  are  also  known  to  be  produced  during  waste 
water treatment as break down products, with the degradation of precursors (polyfluoroalkyl 
compounds)275. 

In 2005 a severe fire at the Buncefield oil storage terminal, UK, required the UK Fire Service 
to  make  use  of  all  available  fire  fighting  foams  to  put  the  blaze  out.  The  use  of  AFFF  fire 
fighting foams containing PFOS which had been retained for destruction were used as part of 
the stocks to  bring the incident  to  a close, causing  ground and surface  water contamination 
with PFOS. Control and remediation of the site included extensive groundwater monitoring. 
Data from 2007276 two years after the incident still recorded high PFOS concentrations of 3 
µg/l in ground water at Buncefield. 

A systematic assessment on PFOS contaminated sites has been reported on the city level for 
Düsseldorf, Germany (Bantz et al. 2011). Measured concentrations in the environment show 
that  humans  and  the  environment  risk  exposure  to  PFAS  at  levels  that  may  cause  adverse 
effects.  PFAS  have  been  analysed  in  raw  water  or  drinking  water  from  35%  of  the  public 
water supplies in Sweden. The water supplies with confirmed levels above 90 nanograms per 
litre are located close to a fire training site at an airport277. 

In 2013, PFOS and its derivatives were includes in the Directive on Environmental Quality 
Standards  (2013/39/EU  amending  2008/105/EC).  The  date  set  for  Union-wide  compliance 
with the EQS is 22 December 2027, with Member States required to submit a supplementary 
monitoring programme and preliminary programme of measures to achieve compliance by 22 
December 2018.  

Monitoring  of  surface  water  across  Europe  has  identified  widespread  occurance  of  PFAS 
(including PFOS), with the EQS often being exceeded. In a Union-wide survey undertaken in 
2007,  122  water  samples  were  collected  in  streams  and  rivers  of  27  European  countries. 
PFOS  was  identified  in  93%  of  samples  analysed,  with  the  highest  concentration  of  1,371 
µg/l found in the River Krka in Slovenia (Concawe 2016).   

In 2018 the drinking water directive (98/83/EC) was reviewed following a regulatory fitness 
evaluation278.  This  included  the  introduction  of  new  measures  for  PFAS  chemicals.  The 
proposed  recast  directive  takes  into  account  the  WHO  recommended  limits  for  PFOS 
(0.4µg/l)  and  PFOA  (4µg/l),  but  also  that  the  EQS  limits  for  PFOS  within  the  water 
framework directive is lower (0.00065 µg/l) than the WHO recommendations. The proposal 
for  a  recast  directive  also  identifies  the  emerging  issue  with  other  PFAS  species  such  as 
PFHxS  and  therefore  includes  proposed  drinking  water  limits  for  each  indiviudal  PFAS 
species of 0.1µg/l and 0.5µg/l for PFAS in total279. A provisional agreement on the recast of 
drinking  water  directive  was  reached  between  the  European  Parliament  and  European 
Council  at  a  December  2019  trilogue.  The  European  Parliament  further  formally  approved 

274  Becker, A.M, Suchan, M. Gerstmann, S. Frank, H. (2010) Perflorooctanoic acid and perflurooctance sulfonate released 
from a wastewater treatment plant in Bavaria, Germany, Environment Science and Pollution Research 17, 1502-1507. 
275  Hamid,  H.  and  Li,  L.  Y.  (2016)  Role  of  Wastewater  treatment  plant  in  environmental  cycling  of  poly-  and 

perfluroroalkyl substances, Ecocycles, 2 (2), 43-53. 

276  Environment Agency of England and Wales (2007) ‘Investigation of PFOS and other perfluorochemicals in groundwater 

and surface water in England and Wales’.  

277  PFAS monitoring: Report 6709, March (2016). Swedish Environmental Protection Agency. 
278  https://ec.europa.eu/environment/water/water-drink/pdf/SWD_2016_428_F1.pdf 
279  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2017%3A753%3AFIN 

109 

 
 
                                                           
the recast of the drinking water directive in February 2020280, paving the way for approval by 
the Council and likely entry into force in July 2020. 

Additionally,  the  CONTAM  Panel  at  EFSA  undertook  a  review  of  the  human  health 
toxicology  of  PFOS  and  PFOA  and  25  other  prioritised  PFAS  substances  as  part  of  a  risk 
assessment for human health from exposure to presence of PFAS in food. The study assessed 
20,000  analytical  results  for  dietary  exposure,  noting  very  large  differences  between  upper 
and lower bound exposure data. The study estimated human half-lives for PFOS and PFOA 
of  around  5  years  and  2-4  years,  respectively.  Based  on  this  analysis,  the  CONTAM  Panel 
made recommendations in March 2018 for tolerable weekly intake (TWI) of 13 ng/kg body 
weight  for  PFOS  and  6  ng/kg  per  week  for  PFOA281.  In  March  2020  at  the  stakeholders 
meeting on the draft scientific opinion on the risks to human health related to the presence of 
PFAS  in  food  the  CONTAM  Panel  further  endorsed  the  draft  opinion,  and  proposed  a 
mixture approach to focus on the most relevant PFAS for human bioaccumulation. The draft 
opinion has  also  been  the  subject  of  an 8-week  public consultation, which was  launched in 
February 2020, including a group TWI for PFAS substances. 

The need for  further research into the potential transfer of  contaminants  from  the recycling 
and use of waste materials has been previously identified by the UK Food Standards Agency. 
This included the need to fully understand the implications of uptake in the foodchain from 
the  application  of  non-source  segregated  compost/digestate  which  may  contain  a  wide 
spectrum of POPs (Nichloson et al. 2016). The Commission further conducted a Regulatory 
Management  Option  Analysis  (RMOA)  study  on  the  use  of  digestate  and  compost  as 
fertilisers  in  2017/2018,  which  included  consideration  of  the  potential  transfer  of 
contaminants  from  17  substance  groups,  including  POPs  (dioxins  and  furans,  PCBs, 
HBCDD, PAHs and PFAS), into the environment282. The study includes assessments of the 
contribution  of  different  material  flows  and  applications  of  compost  and  digestate  for 
concentrations  of  the  different  contaminants  against  background  concentrations  and/or  safe 
limits. The study also draws conclusions on the merits of possible control options, including 
setting concentration limits for contaminants in commercial compost and digestate including 
POPs  substances,  as  well  as  greater  control  over  specific  material    flows  such  as  sewage 
sludge.  

In  summary,  these  examples  show  that  the  production  and  use  of  PFOS  (and  other 
perfluorinated compounds) can result in PFAS contaminated sites and – due to their mobility 
–  in  water,  too,  thus  impacting  the  wider  environment.  Hence,  a  systematic  assessment  of 
such sites  including contaminated  groundwater bodies  is  necessary.  This  is  beginning to  be 
looked  at  by  some  Member  States,  with  Sweden,  Denmark  and  Germany  currently 
developing  legislation  and  technical  approaches  for  PFOS  and  PFOA  in  soil,  groundwater, 
and  sediments,  with  collaboration  taking  place  between  the  three  countries  (KEMI  2016, 
Witteveen and Bos 2016283). 

280  https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/ENVI/DV/2020/02-

17/1198614EN.pdf  

281  https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2018.5194  
282https://ec.europa.eu/environment/chemicals/reach/pdf/40039%20Digestate%20and%20Compost%20RMOA

%20-%20Final%20report%20i2_20190208.pdf  

283  Witteveen+Bos (2016) Inventory of awareness, approaches and policy, Insight in emerging contaminants in 
Europe  Final  version  03  RW2034-1/16-003.303  prepared  on  behalf  of  Ministry  of  Infrastructure  and 
Environment, the Netherlands and Public Waste Agency of Flanders, Belgium. 

110 

 
 
                                                           
3.4.7.  Hexachlorobutadiene contaminated sites 

Hexachlorobutadiene  formerly  had  a  number  of  commercial  applications 
including 
applications  such  as  a  solvent  (for  rubber  and  other  polymers),  as  a  “scrubber”  to  recover 
chlorine-containing  gas  or  to  remove  volatile  organic  components  from  gas,  as  hydraulic, 
heat  transfer  or  transformer  fluid,  in  gyroscopes,  in  the  manufacture  of  aluminium  and 
graphite  rods  and  as  a  plant  protection  product284.  It  was  however  also  produced  as  a 
contaminant in waste streams linked to the manufacture of chlorinated solvents, in particular 
trichloroethylene, 
tetrachloride.  Depending  on  how 
contaminated wastes have been previously managed, there is a potential risk of contaminated 
sites both at the former sites of manufacture of these solvents, but also for waste landfill sites. 
Knowledge  on  the  number  of  sites  and  level  of  contamination  within  Europe  is  limited. 
However,  examples  do  exist  where  HCBD  has  been  discovered  warranting  action;  this 
includes one site in the UK near a former site of manufacture. HCBD was detected as a gas 
emanating from contaminated land in a quarry near the village of Weston, UK, in 2000 which 
required properties to be evacuated and remediation work to be conducted285. 

tetrachloroethylene  and  carbon 

3.4.8.  Hexabromocyclododecane in waste stream 

HBCDD  has  been  extensively  used  as  a  flame-retardant,  primarily  for  polystyrene-based 
insulation  materials  (90%  of  all  use),  but  also  within  moulded  plastics  and  textiles  (see 
section 3.2.12). HBCDD has been in use since the 1960s, with estimated annual use of 12,000 
tonnes in 2009. The Netherlands (2016) comments that in 2016 this equated to 62,500 tonnes 
of insulation boarding containing HBCDD, this is extrapolated to estimates between 480,000 
and 2.4 million tonnes for the whole Union. While new use of HBCDD has now ceased (as of 
August  2017),  a  very  significant  bank  of  ‘in-use’  material  can  be  expected  to  exist.  This 
poses a significant challenge for the construction and demolition sector to manage HBCDD 
contaminated wastes. 

The  POPs  Regulation  was  amended  in  2016  (Commission  Regulation  2016/460  amending 
Regulation  850/2004)  to  update  Annex  IV  with  a  threshold  value  of  1,000  mg/kg  for 
HBCDD.  This  threshold  provides  a  critical  value  for  how  waste  should  be  managed. 
However,  where  a  range  of  different  brominated  flame-retardants  have  been  used,  some  of 
which are POPs and others not, correct identification is of high importance.   

The  correct  identification  of  brominated  chemical  species  and  concentrations  requires 
laboratory  analysis,  which  represents  both  a  costly  and  timing  consuming  process 
(laboratories can take days/weeks to turnaround analysis). Therefore, research is developing 
around new approaches for quick identification and appropriate management. Section 3.2.12 
provides further discussion around the role of handheld XRF to identify bromine as a marker 
and screening tool for critical thresholds.  

284  UNEP/POPS/POPRC.12/6 – Information on the listing of HCBD in Annex C of the Stockholm Convention. 
285  https://cot.food.gov.uk/committee/committee-on-

toxicity/cotstatements/cotstatementsyrs/cotstatements2000/hexachlorobutadiene-  COT 
hexachlorobutadiene. 

statement 

on 

111 

 
 
 
 
                                                           
Ramboll  (2019)  provide  some  additional  commentary  on  material  flows,  commenting  that 
based  on  studies  by  Giraf,  (2018)286  in  the  Netherlands  that  70%  of  EPS/XPS  from 
construction  waste  contained  HBCDD  above  the  1000  mg/kg  low  POP  content  threshold. 
However, 96% of this came from EPS. Furthermore, the study by Conversio (2018)287 noted 
that  for  the  EU28+2  in  2017  a  total  of  138.7  kt  of  EPS  within  construction  waste  was 
generated. This included 40kt (29%) of off-cuts from new installation (free of HBCDD) and 
98.6 kt (71%) from demolition, which included waste containing HBCDD.  

Ramboll  (2019)  calculate  waste  flows  for  EPS  in  2017  assuming  690  tonnes  of  HBCDD 
contained within 98.6kt of EPS. This assumes 68.6 kt of EPS (480t HBCDD) is incinerated, a 
further  28.7  kt  EPS  (200t  HBCDD)  is  consigned  to  landfill  and  1.3kt  EPS  (9t  HBCDD)  is 
recycled within the EU28+2. 

Ramboll (2019) also calculate waste flows for XPS in 2017 assuming 636 tonnes of HBCDD 
within 32.8kt of XPS. This assumes 70% (23.2kt of XPS) is incinerated, with 30% (9.6kt of 
XPS) consigned to landfill, and no recycling of XPS within the EU28+2.  

While the new use of HBCDD in  XPS/EPS is no longer permitted, the significant previous 
use and long lifespan of treated articles means that HBCDD in demolition and construction 
waste  will  continue  to  require  management.    This  is  an  area  for  further  research  to  better 
understand and manage how construction and demolition companies control HBCDD in the 
waste stream. 

3.5. 

Emerging risks from POPs 

Both international agreements on POPs foresee listing of additional substances in the annexes 
of  substances  to  be  banned,  restricted  or  otherwise  controlled.  Any  Party  may  propose 
amendments  to  this  end,  and  criteria  and  procedure  for  review  of  the  proposals  have  been 
established.  

The  Union  has  submitted  two-thirds  of  the  proposals  for  new  POPs  under  the  Stockholm 
Convention (endosulfan, commercial octabromodiphenyl ether, pentachlorobenzene, SCCPs, 
HCBD, PCNs, PCP, PFOA, dicofol and methoxychlor) and PFOS and trifluralin in addition 
under the POP Protocol.  

In  May  2019,  at  COP-9,  it  was  decided  to  list  two  new  chemicals  which  had  been 
recommended  by  the  POPs  Review  Committee  (POPRC),  namely  dicofol  and  PFOA  in 
Annex A.  

Three  substances  (perfluorohexane  sulfonic  acid  (PFHxS),  its  salts  and  PFHxS-related 
compounds,  dechlorane  plus,  and  methoxychlor)  are  currently  under  review  by  the 
Stockholm Convention for addition to the Convention Annexes as POPs.  At the POPRC-15 
meeting in 2019288, a draft risk management evaluation (RME) of PFHxS was presented and 
adopted. POPRC recommendation is to list PFHxS, its salts and PFHxS related compounds in 
Annex  A  without  exemptions.  Furthermore  screening  dossiers  for  dechlorane  plus  and 

286  Giraf,  2018,  HBCDD  concentrations  in  EPS/XPS  products  and  waste  streams,  Inventory  in  the  307/390 
Netherlands, Final Report, Ministry of Infrastructure and Water Management Netherlands, 15 March 2018. 
287  Conversio,  2018,  Post-Consumer  Waste  Generation  and  Management  in  European  Countries  2017.  EPS 

Packaging Waste & EPS Construction Waste, Final Report for Eumeps, July 2018. 

288  UNEP/POPS/POPRC.15/7 

112 

 
 
 
                                                           
methoxychlor  were  presented  and  adopted,  with  agreement  from  the  POPRC  members  that 
both substances meet the Annex D criteria (of the Convention) to be considered POPs. It is 
expected  that  PFHxS  will  be  listed  under  Annex  A  of  the  Convention  (as  per  the  POPRC 
recommendation) at the next Conference of the Parties, COP10. 

The registration of chemicals  under the REACH Regulation  may serve as a main source of 
information for screening for identification of POP-candidate substances. Although there are 
tonnage  triggers  for  registration  below  which  the  data  submitted  to  the  authorities  are  not 
necessarily  sufficient  for  POP  assessment,  the  REACH  Regulation  addresses  specifically 
PBT or vPvB substances (see section 2.2.3). 

Since  2013,  together  with  the  Member  States,  ECHA  has  developed  a  common  screening 
process,  which identifies  (groups of) substances that  have the  greatest potential  for adverse 
impacts on human health and the environment, including substances that meet the PBT/vPvB 
criteria. This process also aims at identifying candidates for SVHCs, which may be added to 
Annex  XIV  to  REACH  and  would  then  be  subject  to  authorisation289.  The  results  of  the 
screening are going to be used also for the identification of POPs candidates. Under the POPs 
Regulation,  ECHA  has  also  a  central  role  for  the  development  of  scientific  and  technical 
dossiers for substances  proposed by the Union for listing under the Stockholm Convention. 
The strong synergies between the REACH Regulation and the POPs Regulation and the new 
more  central  role  of  ECHA  within  the  POPs  Regulation  will  maximise  the  synergies  with 
REACH processes for identification of candidate POPs. 

Work  has  also  been  undertaken  to  help  develop  strategies  for  identification  of  those 
substances  that  may  meet  the  Annex  D  criteria  under  the  Stockholm  Convention  to  be 
considered  a  POP.  This  includes  work  led  by  RIVM290  to  help  develop  an  approach  for 
analysis of substances presented at the POPRC meeting. Studies have also been carried out in 
Norway291  to  assess  potential  candidate  substances  against  the  Stockholm  Convention 
criteria. 
A  2018  study  by  McLachlan292  suggests  the  criteria  to  screen  for  new  POPs  under  the 
Stockholm Convention can lead to false negative and false positive conclusions when applied 
to  chemicals  that  lie  outside  of  the  basic  criteria  set  down  in  Annex  D  of  the  Stockholm 
Convention. In particular, McLachlan (2018) comments that trying to apply simple indicators 
to complex processes of chemical transport, fate and exposure will not be successful across a 
wide spectrum of chemicals. For example, the authors note that bioconcentration in fish and 
biomagnification,  the  Annex  D  criteria  primarily  used  to  assess  bioaccumulation,  are  of  no 
relevance in the case of PFOA and PFOS. Furthermore, the authors noted that the reliance on 
tissue  levels  in  humans  or  top  predators  as  a  substitute  for  bioaccumulation  metrics  can  be 
problematic,  as  chemicals  can  be  rapidly  metabolized  or  excreted  and  still  have  adverse 
effects, therefore bioaccumulation will not necessarily be a requirement for adverse effects of 
chemicals  in  remote  regions.  It  is  that  suggested  that  consideration  of  persistence  is 

289  https://echa.europa.eu/documents/10162/19126370/screening_definition_document_en.pdf/e588a9f8-c55e-

4412-a760-49ddbf7ac687 

290  RIVM,  2011, 

Identifying  potential  POP 

and  PBT 

substances:  Development  of 

a  new 

Persistence/Bioaccumulation-score, Report No. Report 601356001/2011. 

291  Bergfeld, 2011, Identifying POP candidates for the Stockholm Convention, Report No. TA-2871/2011. 
292  McLachlan, M.S., 2018, Can the Stockholm convention address the spectrum of chemicals currently under 
regulatory  scrutiny?  Advocating  a  more  prominent  role  for  modelling  in  POP  screening  assessment. 
Environmental Science: Processes & Impacts, 20, 32. 

113 

 
 
                                                           
particularly significant in POPs screening as this can provide an indication as to the potential 
for non-reversible exposure for humans to these chemicals.  
The  German  Environment  Agency293  has  developed  a  persistency,  mobility  and  toxicity 
(PMT)  as  well  as  very  persistent  and  very  mobile  (vPvM)  criteria  and  an  assessment 
procedure to  identify substances that pose  a hazard to  drinking water. An initial  list  of  167 
substances registered under REACH were assessed for the PMT/vPvM criteria. A total of 134 
substances  based  on  suspected  PMT  properties  combined  with  expected  environmental 
emissions are recommended294. A workshop was held by the German Environment Agency in 
2018 to  discuss how this initiative can best serve industry in  fulfilling its obligations under 
REACH295.  

Since  the  work  of  the  German  Environment  Agency  in  2017  to  develop  the  concept  of 
“PMT” and mobility as  a potential criterion to assess substances which spread ubiquitously 
through the environment to reach higher trophic levels of the food chain, additional work has 
been completed to assess its validity as a method of identifying POPs. A study on behalf of 
the  European  Commission  (2019)296  evaluated  the  use  of  mobility  as  a  supporting  piece  of 
evidence for Annex D criteria c(ii)297 of the Stockholm Convention. It concluded that, based 
on analysis of a range of substances using modelled approaches underpinned by monitoring 
data,  mobility  may  be  important  depending  on  receiving  environment  and  times  taken  to 
reach  higher  trophic  levels.  The  study  goes  on  to  suggest  possible  criteria  for  developing 
critical thresholds of mobility alongside other PBT criteria for the identification of POPs.The 
use  of  PMT  and  mobility  as  a  criteria  to  identify  chemicals  of  concern,  particularly  for 
drinking  water,  has  also  been  increasingly  recognised  by  industry  groups.  In  particular 
EurEau (2019)298 highlights  within their August  2019 briefing note  the importance of early 
identification and management of PMT substances to avoid health effects and costing impacts 
for the water treatment industry. EurEau highlight in particular the concerns around per and 
poly  fluorinated  alkyl  substances  (PFAS),  regulation  of  which  has  to  date  included  PFOS, 
PFOA and PFHxS, with growing potential concerns for shorter chain PFAS substances in the 
environment. 

4. 

PART II – IMPLEMENTATION PLAN 

This section presents the Union’s implementation plan, including actions to address the issues 
identified within the Party Baseline (Part I of the UIP). The Union Implementation Plan is an 

293  German  Environment  Agency,  2017. Protecting  the  sources  of  our  drinking  water,  A  revised  proposal  for 
implementing criteria and an assessment procedure to identify Persistent, Mobile and Toxic (PMT) and very 
Persistent, very Mobile (vPvM) substances registered under REACH. 

294  https://www.umweltbundesamt.de/sites/default/files/medien/1410/publikationen/2018-02-12_texte_09-

2018_pmt-of-167-reach-substances_v3.pdf 

295  https://psi.ul.com/en/resources/article/german-environment-agency-proposes-pmt-and-vpvm-criteria-under-

reach-and-clp/ 

296  Evaluation  of  using  mobility  of  chemicals  in  the  environment  to  fulfil  bioaccumulation  criteria  of  the 

Stockholm Convention. https://ec.europa.eu/environment/chemicals/reach/publications_en.htm 

297  Annex  D,  c(ii):  “Evidence  that  a  chemical  presents  other  reasons  for  concern,  such  as  high  bio-

accumulation in other species, high toxicity or ecotoxicity”. 

298  EurEau  briefing  note,  August  2019,’Moving  Forward  on  PMT  and  vPvM  substances’,  EurEau  industry 

publication. 

114 

 
 
 
                                                           
evolving  document  which  develops  alongside  the  emerging  science  and  policy  through 
periodic  updates.  The  actions  included  within  the  implementation  plan  include  both  more 
general  activities  which  will  always  be  needed  to  meet  the  obligations  of  the  POPs 
Regulation, and actions aimed at addressing specific issues. 

As part of the update to the current version of the UIP (presented here) any actions from the 
previous version which are now obsolete have been removed and are presented in Section 9. 
This is because the action has either been completed or the further evolution of the science 
and policy means that the action is no longer needed. 

Section  5also includes new actions added for the first time; where this is the case it is clearly 
stated in the text. 

5. 

5.1. 

IMPLEMENTATION OF THE BASIC OBLIGATIONS OF THE STOCKHOLM CONVENTION 

Elimination of intentional manufacture and use of POPs (Article 3(1)) 

5.1.1.  POP  pesticides,  plus  decabromodiphenyl  ether,  HBB,  HBCDD,  HCBD,  PeCB, 

PCNs, and SCCPs. 

Obligation:  Article  3,  paragraph  1(a)(i)  of  the  Convention:  prohibit  and/or  take  legal  or 
administrative measures necessary to eliminate the manufacture and use of aldrin, alpha and 
beta  hexachlorocyclohexane,  chlordane,  chlordecone,  decabromodiphenyl  ether,  dicofol, 
dieldrin,  endosulfan,  endrin,  heptachlor,  hexabromocyclododecane,  hexabromobiphenyl, 
hexachlorobenzene, hexachlorobutadiene, lindane, mirex, PCP, PeCB, PCNs, SCCPs, as well 
as toxaphene (additions to the POPs Regulation since 2009 are underlined).299 

Implementation so far: Manufacture, placing on the market and use of the above-mentioned 
substances  as  such,  in  mixtures  or  in  articles  is  prohibited  in  the  Union  by  the  POPs 
Regulation. 

Analysis:  Legal  measures  regarding  manufacture,  placing  on  the  market  and  use  are 
sufficiently comprehensive. There is no need for further legislative measures at Union level. 
No  Member  State  currently  reports  the  intentional  manufacture  of  any  of  the  POPs  listed 
above.   

Border and market surveillance by the Member States remain necessary and following recent 
findings  of  HCB  presence  in  fireworks.  It  is  desirable  to  intensify  compliance  controls  of 
products  in  line  with  Regulation  (EC)  No  765/2008  setting  out  the  requirements  for 
accreditation  and  market  surveillance  relating  to  the  marketing  of  products.  Cases  of  non-
compliance need to be reported to the Commission. 

In  March  2016  HBCDD  was  added  to  Annex  I  of  the  [initial]  POPs  Regulation  (by 
Commission  Regulation  (EU)  2016/293).  This 
two 
authorisations for HBCDD under the REACH  Regulation, both of which expired in August 
2017.  While  new  use  of  HBCDD  is  prohibited,  the  lifespan  of  previously  treated  mixtures 
and  articles  means  that  presence  of  HBCDD  within  in-use  mixtures  and  articles  is  still  an 
issue,  and  this  will  further  present  legacy  issues  for  the  waste  cycle  and  management  of 
wastes  containing  HBCDD.  It  is  still  necessary  to  gather  more  information  to  support  the 

included  exemptions 

to  cover 

299  Those  substances  that  have  been  added  to  the  Convention  in  2009,  2011,  2013,  2015,  and  2017,  are 

underlined. 

115 

 
 
 
                                                           
exchange  of  information  on  methods  for  identification  of  that  chemical  within  the  waste 
stream.  

Similarly,  dicofol  was  only  added  to  Annex  I  of  the  POPs  Regulation  in  June  of  2020 
(Commission  Delegated  Regulation  (EU)  2020/1204).  In  the  Union,  there  was  one 
manufacturer based in Spain (with some further formulation in Italy) with production and use 
in the Union declining over time from 317t per annum to 32t per annum between 2000 and 
2009300. According to the EFSA pesticide database301, that one manufacturer based in Spain 
(Dow)  had  reapplied  for  dicofol  to  be  added  to  Annex  I  of  the  Plant  Protection  Products 
Regulation (as an approved active substance). This was rejected in 2008 (over concerns for 
human  health  and  environment  and  lack  of  substantiating  data),  with  the  existing  approval 
expiring  in  2010.  On  that  basis,  manufacture  and  use  of  dicofol  in  the  Union  has  not  been 
allowed  for  at  least  a  decade,  with  a  strong  decline  in  use  preceding  the  phase-out. 
Additionally, under the Regulation for maximum residues of pesticides in or on food and feed 
(Regulation  (EC)  No  396/2005),  thresholds  for  dicofol  have  been  in  place  since  2008  (see 
Regulation  (EC)  No  149/2008),  and  under  the  Environmental  Quality  Standards  Directive 
(Directive 2013/39/EU) dicofol was identified as a priority substance with thresholds set for 
surface water in 2013. 

It  is  possible that, like the other obsolete POP  pesticides,  limited remaining stockpiles may 
exist within  the Union. However,  given the significant  period of time that  has passed since 
legal use has ceased, it is likely that quantities will be small, even if such stockpiles exist. 

The public consultation on the draft UIP completed in 2019 (August-November) did further 
specifically  highlight  that  the  general  public  had  high  concerns  regarding  stockpiles  of 
obsolete  pesticides,  with  no  publicly  available  central  repository  containing  information  on 
quantities and management. 

Action 1: Commission to gather available information on validated methods for 
identification of HBCDD in products/articles/wastes and facilitate exchange of 
information among the Member States. (ongoing action) 

Action 2: Commission to explore options for the best method to facilitate the 
compilation of information on stockpiles of obsolete pesticides. In particular this should 
include a public facing component to address concerns raised in UIP consultation. (new 
action) 

300 Li, L., Liu, J., Hu, J. (2014) Global inventory, long-range transport and environmental distribution of dicofol. 

Environmental Science and Technology, 49: 212-222. 

301 https://ec.europa.eu/food/plant/pesticides/eu-pesticides-database/public/?event=homepage&language=EN 

116 

 
 
 
                                                           
 
 
 
 
 
5.1.2.  PCBs 

Obligation:  Article  3,  paragraph  1(a)(i)  and  Annex  A,  Part  II  of  the  Convention:  prohibit 
and/or take legal or administrative measures necessary to eliminate the manufacture and use 
of PCBs. 

Implementation so far: Manufacture, placing on the market and use of PCBs as such and in 
mixtures is fully prohibited by the POPs Regulation. Articles containing PCBs already in use 
are  covered  by  specific  provisions  laid  down  in  Directive  96/59/EC  (PCB  Directive)  (cf. 
section  2.2.3).  The  Directive  requires  Member  States  to  compile  inventories  of  equipment 
with  PCB  volumes  of  more  than  5  dm3,  and  to  phase-out  and  destroy  such  PCB  (larger) 
equipment  before  the  deadline  of  31  December  2010.  Furthermore,  the  POPs  Regulation 
requires all remaining PCBs within contaminated equipment (greater than 0.005% and larger 
than  0.05  dm3)  to  be  identified  and  removed  for  irreversible  destruction  by  31  December 
2025. 

Analysis: Legal measures on manufacture, marketing and new use of PCBs (and PCTs) are 
sufficiently  comprehensive  and  there  is  no  need  for  further  legislative  measures  at  Union 
level.  

Directive 96/59/EC addresses the main application areas of PCBs and lays down a timetable 
for  specific  essential  control  actions,  with  one  further  final  target  detailed  within  the  POPs 
Regulation. In conformity with the PCB Directive, inventories of PCB containing equipment, 
as well as action plans for their disposal and collection were compiled by all Member States. 
The  Commission  has  gathered  information  about  current  amounts  of  PCB  equipment  and 
PCB wastes in the Union given that the information on PCB inventories had become obsolete 
(cf. section 3.1.4). The survey showed that there are still quantities of PCB equipment in use. 
In addition, only three Member States achieved to decontaminate or to dispose of large PCB 
equipment by the end of 2010 as required by the Directive.  

In a study for the European Commission on “Support to selected Member States in improving 
hazardous  waste  management  based  on  assessment  of  Member  States'  performance” 
(2017)302,  the  PCB/  PCB  waste  management  situation  in  14  selected  Member  States  was 
investigated. The study  indicated that major shares of PCB equipment have been identified 
and eliminated. Nevertheless, the overarching challenge in most Member States is that further 
identification of PCB equipment does not seem to be on top of the priorities of the competent 
authorities  in  the  Member  States.  This  means  that  in  many  cases  neither  targeted  actions, 
inspections and controls, nor further awareness raising campaigns are carried out anymore in 
order to inform companies concerning their responsibilities for PCB equipment. By contrast, 
Member  States  actively  and  continuously  searching  for  further  PCB  equipment  report 
ongoing  identification  and  elimination  of  such  equipment  which  indicates  that  not  all 
equipment may have been identified yet in the Member States. Furthermore, it was concluded 
that  although  most  Member  States  already  substantially  addressed  PCB  from  ‘closed’ 
applications,  activities  in  this  direction  should  not  be  abandoned  as  some  holders  of  PCB 
equipment have not yet been identified. 

302  BiPro,  2017.  Support  to  selected  Member  States  in  improving  hazardous  waste  management  based  on 
European  Commission 

assessment 
(070201/2016/736294/ENV.B.3): http://ec.europa.eu/environment/waste/studies/index.htm   

of  Member 

performance. 

States' 

Study 

the 

for 

117 

 
 
                                                           
In  those  cases  where  the  deadline  for  the  disposal  and  decontamination  of  large  PCB 
equipment  has  not  been  met  and  in  those  cases  where  Member  States  did  not  provide  any 
information, the Commission will consider the need to take legal steps. 

This is particularly relevant given that the POPs Regulation sets a target for full final removal 
of  all  PCBs  in  dielectric  equipment  (containing  more  than  0.005%  w/w  PCB  in  volumes 
greater  than  0.05  dm3)  by  no  later  than  31  December  2025,  to  meet  the  same  target  listed 
under  the  Stockholm  Convention.  Based  on  contact  with  Member  States  from  the  recent 
request, this final deadline may prove challenging. While significant progress has been made 
towards  elimination,  identification  of  remaining  stockpiles  within  networks  is  likely  to 
require  significant  additional  efforts,  as  evidenced  in  part  by  the  industry  feedback  on  the 
recast of the initial POPs Regulation303.  

PCBs have been used in several open applications (e.g. sealants, anti-corrosion paints, flame 
retardants,  specific  paper).  Open  applications  are  highlighted  by  the  PCB  Elimination 
Network  in  the  Stockholm  Convention  context  due  to  the  relevance  of  human  exposure  in 
kindergarten,  schools  and  other  public  buildings  such  as  swimming  pools,  but  also  private 
housing  and  farm  buildings  constructed  in  the  1950s  to  the  early  1970s.  The  quantities  of 
PCB  that  were  used  in  open  applications  is  unknown,  as  is  the  quantities  of  products 
containing PCBs still in use or capable of emitting to the natural environment. For paints and 
sealants there is also a potential issue of replacement paint or sealant to be added on top of 
the  existing  layers,  causing  secondary  contamination  and  extending  the  lifespan  of  product 
use. Understanding the magnitude of PCB use for open applications and as a potential source 
of emission is an important component for the management and elimination of PCBs. 

Action 3: The Commission and the Member States shall work to identify products, 
substances and materials containing PCB in open applications and raise awareness about 
environmental release from open applications of PCBs (paints and sealants) within the 
European Union. (ongoing action) 

Another  potential  issue  for  PCBs  that  have  been  used  in  open  applications,  particularly  in 
anti-corrosion paints included bridges and other constructions as well as electric poles, is the 
end of life legacy impacts. When this equipment reaches the end of its useful life, the large 
metal  parts  are  recycled  in  electric  arc  furnaces  (EAF).  Since  the  combustion  processes  in 
these batch operations are incomplete, a considerable share of these PCBs will most probably 
evaporate and not  be destroyed. Furthermore, these  conditions  promote the development  of 
PCDF  which  is  associated  with  an  increased  toxicity.  Currently,  there  is  no  assessment 
available as to how much PCB painted scrap is entering the waste stream and the secondary 
metal treatment. Also, there is no data on dedicated testing of associated releases. However, it 
is known from measurements in EAF that considerable PCB loads are emitted which only can 
be explained by PCB input from material treated with it304. 
Member  States  are  required  to  develop  a  register  of  larger  (>5  dm3)  size  equipment 
containing  PCBs  and  adopt  a  plan  for  disposal  of  inventoried  equipment.  In  addition,  they 

303 https://ec.europa.eu/info/law/better-regulation/initiatives/com-2018-144/feedback_en?p_id=198418 
304  Also, the PCB pattern from EAF have often a congener finger print of industrial PCBs demonstrating that 

the main PCB release stem from the input material and are not unintentionally formed.  

118 

 
 
                                                           
have  to  define  processes  for  the  collection  and  disposal  of  non-inventoried  equipment  (e.g. 
small electrical equipment that can be present in household appliances). Member States were 
required  to  dispose  of  larger  equipment  by  the  end  of  2010.  However,  this  work  was  still 
ongoing in many cases. Several Member States reported a downward trend in stockpiles with 
PCB-containing equipment.  

Acknowledging  the  levels  of  uncertainty  inherent  to  the  estimates  of  PCBs  in  such 
equipment, the request asked for input on the quantities of PCB actively in use in di-electric 
equipment,  both  in  1990  and  in  2015,  as  well  as  the  quantities  of  PCBs  that  have  been 
destroyed between 1990 and 2015. Responses were received from 14 Member States, which 
indicated that in the majority of cases that <10% of stockpiles remained in 2015 compared to 
the  1990  estimates.  However,  a  small  number  of  Member  States  highlighted  that 
identification  and  removal  of  PCB  from  di-electric  equipment  was  still  ongoing,  with  the 
highest estimate of 49% of stocks still in-use for 2015 compared to the 1990 baseline. 

Recommendations COP-9 

COP-9 in its document UNEP/COP.9/6/Add.1 identifies a set of key recommendations for the 
further elimination and safe management of PCBs, which includes: 

  Urging  Parties  to  take  legal  and  administrative  measures  to  ensure  that,  by  2025, 
Parties  identify  and  remove  from  use,  equipment  containing  greater  than  0.005  per 
cent PCB and volumes greater than 0.05 litres. 

  Encouraging  Parties,  as  appropriate,  to  include  in  their  regulatory  frameworks 
provisions  to  ensure  the  environmentally  sound  management  of  PCB,  e.g.,  interim 
storage, avoiding cross-contamination, decontamination and elimination; 

  Urging  Parties  to  take  legal  and  administrative  measures  to  ensure  that,  as  soon  as 
possible but  no later than 2028, Parties make determined efforts designed to  lead to 
the  environmentally  sound  waste  management  of  liquids  containing  PCB  and 
equipment contaminated with PCB having a PCB content above 0.005 percent. 

  Reminding Parties, in accordance with subparagraph (f) of part II of Annex A to the 
Convention,  to  endeavour  to  identify  articles  containing  more  than  0.005  per  cent 
PCB in open applications such as cable sheaths, cured caulk and painted objects, and 
manage them in accordance with paragraph 1 of Article 6. 

  Encouraging Parties to raise awareness on PCB in open applications as well as other 
persistent  organic  pollutants  with  similar  open  applications  as  PCB,  such  as 
polychlorinated  naphthalenes  and  short-chain  chlorinated  paraffins,  and  build 
capacities to identify and manage them. 

 

Inviting  Parties  to  develop,  in  collaboration  with  PCB  experts,  guidance  on  best 
available  techniques  and  best  environmental  practices  (BAT/BEP)  for  PCB  in  open 
applications. 

119 

 
 
 
5.1.3.  POP-PBDEs (tetra-, penta-, hexa-, hepta- and decabromodiphenyl ether) 

Obligation: Article 3, paragraph 1(a)(i) and Annex A, Part IV and Part V of the Convention: 
prohibit and/or take legal or administrative measures necessary to eliminate the manufacture 
and  use  of  hexabromodiphenyl  ether,  heptabromodiphenyl  ether,  tetrabromodiphenyl  ether, 
pentabromodiphenyl ether and decabromodiphenyl ether.  

A  Party  may  allow  recycling  of  articles  that  contain  or  may  contain  hexabromodiphenyl 
ether,  heptabromodiphenyl  ether,  tetrabromodiphenyl  ether  and  pentabromodiphenyl  ether, 
and the use and final disposal of articles manufactured from recycled materials that contain or 
may contain hexabromodiphenyl ether, heptabromodiphenyl ether, tetrabromodiphenyl ether 
and pentabromodiphenyl ether, provided that: 

a)  The  recycling  and  final  disposal  is  carried  out  in  an  environmentally  sound  manner 
and  does  not  lead  to  recovery  of  tetrabromodiphenyl  ether,  pentabromo  diphenyl 
ether,  hexabromodiphenyl  ether  and  heptabromodiphenyl  ether  for  the  purpose  of 
their reuse; 

b)  The  Party 

to  prevent  exports  of  such  articles 
that  contain 
takes  steps 
levels/concentrations  of 
tetrabromodiphenyl  either,  pentabromodiphenyl  ether, 
hexabromodiphenyl  ether  and  heptabromodiphenyl  ether  exceeding  those  permitted 
for  the  sale,  use,  import  or  manufacture  of  those  articles  within  the  territory  of  the 
party; and 

c)  The Party has notified the Secretariat of its intention to make use of this exemption. 

Article 3, paragraph 6: take appropriate measures to ensure that any manufacture or use under 
a specific exemption in accordance with Annex A or a specific exemption or an acceptable 
purpose in  accordance with Annex B is  carried out  in  a manner that prevents  or minimizes 
human exposure and release into the environment. For exempted uses or acceptable purposes 
that  involve  intentional  release  into  the  environment  under  conditions  of  normal  use,  such 
release  shall  be  to  the  minimum  extent  necessary,  taking  into  account  any  applicable 
standards and guidelines. 

During  the  eigth  Conference  of  the  Parties  (COP8)  held  in  May  2017,  decabromodiphenyl 
ether  was  added  to  Annex  A  (SC8/10).  Under  Annex  A,  part  IX  of  the  Convention,  the 
manufacture and use of decabromodiphenyl ether shall be eliminated except for Parties that 
have notified of their intention to produce and/or use it in accordance with Article 4 (specific 
exemptions).  Annex  A,  part  IX  of  the  Convention  lists  the  following  specific  exemptions 
(time limited) for decabromodiphenyl ether: 

  Parties for use in vehicles specified in paragraph 2 of Part IX of Annex A (parts for 
legacy  vehicles,  defined  as  vehicles  that  have  ceased  mass  manufacture,  defined  on 
the specific categories listed in part IX [of Annex A?]of the Convention). Expires at 
end of life or 2036 which ever is sooner. 

  Aircraft for which approval has been applied for before December 2018 and has been 

received before December 2022 and spare parts for those aircraft. 

  Textile  products  that  require  anti-flammable  characteristics,  excluding  clothing  and 

toys. 

120 

 
 
 
  Additives  in  plastic  housing  and  parts  for  heating  home  appliances,  irons,  fans, 
immersion  heaters  that  contain  or  are  in  direct  contact  with  electrical  parts  or  are 
required to comply with fire retardancy standards, at concentrations lower than 10 per 
cent by weight of the part.  

  Polyurethane foam for building insulation.  

Note  under  Article  4(4)  of  the  Convention  unless  a  different  date  is  indicated,  all  specific 
exemptions  shall  expire  after  five  years  from  the  entry  into  force  unless  an  extension  is 
granted by the Conference of the Parties following a request from a Party.  

Recommendations COP-5, 7 and 8 

COP-5  in  its  decision  SC-5/5  encouraged  parties  and  other  relevant  stakeholders  to 
implement  the  recommendations  provided  in  the  decision  POPRC-6/2  on  the  elimination 
from  the  waste  stream  of  brominated  diphenyl  ethers  with  the  objective  to  achieve  the 
elimination as swiftly as possible. SC-5/5 also included further steps to help eliminate the use 
of PFOS under existing exemptions. The recommendations set out in SC-5/5 include: 

  Parties  and  other  relevant  stakeholders  to  implement  where  appropriate,  taking 
into account national circumstances, the recommendations set out in the annex to 
decision  POPRC-6/2  on  the  elimination  from  the  waste  stream  of  brominated 
diphenyl  ethers  that  are  listed  in  Annex  A  to  the  Convention305  and  on  risk 
reduction for perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl 
fluoride. 

  Parties  to  ensure  that  waste  materials  containing  brominated  diphenyl  ethers 
listed  in  Annex  A  are  not  exported  to  developing  countries  or  countries  with 
economies  in  transition,  consistent  with  the  provisions  of  the  Stockholm 
Convention, including its paragraph 1 (d) of Article 6, and relevant provisions of 
the Basel Convention306. 

At  COP-7  recommendations  were  made  subject  to  the  availability  of  resources,  to 
commission  a  technical  paper  on  POP-PBDEs  within  articles,  based  upon  the  terms  of 
reference to be prepared by the POPRC, to be completed in time for its consideration by the 
Committee at its eighth meeting.  

At COP-8 further review and steps were taken  to  assess progress  towards controlling POP-
PBDEs  within  wastes.  Within  the  information  document  COP8/22/Add.1  two  further  key 
recommendations were made: 

305  Failure to do so will inevitably result in wider human and environmental contamination and the dispersal of 
brominated  diphenyl  ethers  into  matrices  from  which  recovery  is  not  technically  or  economically  feasible 
and in the loss of the long-term credibility of recycling. Time is short because articles containing brominated 
diphenyl ethers are already present in many existing  waste streams as a result of the time frame of former 
production of these articles. Brominated diphenyl ethers should not be diluted since this  would not reduce 
the overall quantity in the environment. 

306  That is articles for which the flame retardant content was added for the purposes of flame retardancy rather 

than articles which contain some flame retardant as a consequence of contaminants in recyclate. 

121 

 
 
 
 
                                                           
 

In order to evaluate the progress made in elimination of PBDEs, Parties and observers 
should  provide  quantitative  information  on  articles  containing  BDEs,  including  in 
recycling and waste streams. 

  The guidance documents made available at the seventh meeting of the Conference of 
the  Parties  should  be  completed  in  consultation  with  the  Basel  Convention  so  that 
they  can  be  used  widely  to  develop  more  comprehensive  inventories  of  BDEs  and 
help  with  the  application  of  best  available  techniques  and  best  environmental 
practices for the recycling and waste disposal of articles containing BDEs.  

The  Stockholm  Convention  website  provides  a  guidance  document  for 
development of POP-PBDEs, including within articles and waste, last updated in 2017307. 

inventory 

Implementation so far: Manufacture, placing on the market and use of hexabromodiphenyl 
ether, heptabromodiphenyl ether, tetrabromodiphenyl ether and pentabromodiphenyl ether is 
prohibited  fully  by  the  POPs  Regulation.  Furthermore,  Commission  Regulation  (EU) 
2017/227  (establishing  a  new  entry  67  in  Annex  XVII  to  Regulation  (EC)  No  1907/2006 
(REACH)) on decabromodiphenyl ether states that the manufacture, placing on the market or 
use of decabromodiphenyl ether shall only be allowed for the manufacture of aircrafts until 2 
March 2027, for spare parts of aircrafts produced before the expiry of that period, and for the 
manufacture of spare parts for motor vehicles, agricultural and forestry vehicles or machinery 
produced  before  2  March  2019.  From  2  March  2019  the  use  of  decabromodiphenyl  ether 
shall be subject to a limit of 0,1% w/w for its use in manufacture of or placing on the market 
in another substance as a constiuent, mixture or article. 

In addition, Directive 2011/65/EU on the restriction of hazardous substances in electrical and 
electronic equipment  (EEE) (RoHS  Directive, see section  2.2.4) allows the use of all  POP-
PBDEs  in  EEE  put  on  the  Union  market  only  below  the  maximum  concentration  value  of 
0.1 weight-%  in  the  homogeneous  material  and  in  case  of  specific  exemptions  listed  in  the 
Directive’s Annex.  

Under the POPs Regulation, tetra, penta, hexa, hepta and decaBDE are listed in Annex I, part 
A, which prohibits the manufacturing, placing on the market and use of substances on their 
own, in mixtures or articles (unless set exemptions apply). However, as part of the listing of 
the  POP-PBDEs,  thresholds  are  applied  below  which  their  presence  is  assumed  as  an 
unintentional  trace  contamination.  For  the  POP-PBDEs  the  threshold  for  individual 
homologues  (e.g. tetraBDE)  present  in  substances  is  10 mg/kg  (0.001% by  weight)  and for 
the sum of tetra, penta, hexa, hepta and deca  present in mixtures and articles is 500 mg/kg. 
Additionally, by way of derogation for tetra, penta, hexa and hepta homologues, the limits set 
under the RoHS Directive apply, and articles in use before August 2010 are exempt. 

For  decaBDE,  additional  exemptions  also  apply  to  allow  continuity  between  the  POPs 
Regulation and the Stockholm Convention308. 

Analysis:  Legal  measures  on  manufacture,  placing  on  the  market  and  use  of  tetra,  penta, 
hexa, hepta and decabromodiphenyl ether are comprehensive and there is no need for further 
legislative measures at Union level. 

307http://chm.pops.int/Implementation/NIPs/Guidance/GuidancefortheinventoryofPBDEs/tabid/3171/Default.aspx 
308 See listing for decaBDE in Annex I part A of EU 2019/1021  

122 

 
 
                                                           
Border  and  market  surveillance  by  the  Member  States  is  a  necessity.  Cases  of  non-
compliance need to be reported to the Commission.  

In particular POP-PBDEs will continue to challenge the waste management sector due to the 
long  life-span  of  the  major  product  groups  (e.g.  vehicles,  electronics),  containing  them  and 
the existence of recycling schemes for these waste streams (cf. sections 3.2.3 and 3.2.4). This 
also recognises that the phase-out of c-decaBDE began much later than c-pentaBDE and c-
octaBDE. 

As  stated  in  sections  3.2.3  and  3.2.4,  the  major  remaining  PBDE  input  into  the  economic 
goods cycle is via the use in products and their further input into recycling, stockpiles and the 
waste stream. Commission Regulation (EU) No 1342/2014 updated Annexes IV and V of the 
POPs  Regulation  to  put  in  place  thresholds  for  PBDE  containing  wastes.  This  is  set  as  the 
sum of the congeners tetra-, penta-, hexa-, hepta and decaBDE which must not exceed 1000 
mg/kg. Any waste which exceeds the threshold in Annex IV must be subjected to a treatment 
that destroys or irreversibly transforms the POP substances it contains.  

The  application  of  thresholds  sets  clear  boundaries  on  how  PBDE  wastes  need  to  be 
managed,  however,  further  efforts  are  needed  at  Member  States  level  in  order  to  ensure  a 
reduction of PBDE input to recycling operations and with regard to exports and appropriate 
management and treatment of the waste stream. 

A strategy and methodology needs to be developed for the identification of articles in use, in 
the recycling, in stockpiles and wastes that contain POP-PBDEs. For these activities also the 
recommendations of the COP5 should be considered.  

At the international level, limit values for POP-PBDEs were discussed at COP14 of the Basel 
Convention in June 2019. The technical guidelines presented at COP14 quote three potential 
values of 50, 500, and 1000mg/kg for the sum of POP-PBDEs309, but agreement on the most 
appropriate  value  was  not  reached  during  the  meeting.  The  established  Union  limits  could 
provide valuable input to the international process.  

The  study  to  support  the  review  of  waste-related  issues  in  Annexes  IV  and  V  of  the  POPs 
Regulation  (Ramboll,  2019)  revealed  that  POP-PBDEs  (particularly  decaBDE)  are  still 
contained in some articles still in use and in material flows at the end of life in the Union.  

C-pentaBDE (tetraBDE and pentaBDE) uses 

A main material flow is cars and other transport vehicles produced from the 1970s to 2000 
(and some possibly up to 2004). They are partly used and sold within the Union and partly 
exported  to  other  regions.  There  is  no  database  on  producer  and  year  of  cars/transport 
vehicles containing PBDE and also no monitoring activity or scheme for this310. Only limited 
information  is  available  from  the  (former)  producers  of  cars.  Such  information  would  be  a 
good base in which to better understand the situation on use and reuse of these cars/transport 
vehicles and the export of vehicles containing POP-PBDEs.  

309  http://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW.14-7-Add.1-Rev.1.English.pdf 
310  Note the recent creation of the Substances of Concern In articles as such or in complex objects (products) 
database (the SCIP Database). This covers SVHCs under REACH.  While decaBDE is listed as an SVHC, 
the lower order homologues are not, and furthermore their earlier phase-out may create issues for gathering 
and submitting relevant data to the SCIP Database. 

123 

 
 
 
                                                           
Some Member States are doing screenings of end of life vehicles to generate necessary data, 
in  particular  studies  by  Ireland311,  Sweden312,  and  the  United  Kingdom313  have  assessed 
working concentrations of POP-PBDEs within plastics and foams from vehicles, suggesting 
significant declines in working concentrations for  c-pentaBDE homologues since the global 
ban in 2004. However, it would still be useful to have data from several other Member States 
to have a more comprehensive and representative overview.  

The ongoing discussion on the fate of listed POPs present in articles of everyday use and on 
the  associated  challenges  with  recycling  and  disposal  of  such  articles  is  linked  to  the  CiP 
programme as a forum where stakeholders can showcase their actions to understand, inform 
about and mange chemicals in their products throughout the life cycle. CiP information can 
also be a way to meet legal obligations with regards to POPs in products. 

Action 4: Commission to continue to collect  available data on presence of POP-PBDEs in 
end of life goods including vehicles, waste electrical and electronic equipment (WEEE), and 
waste  plastics  and  facilitate  exchange  of  information  among  the  Member  States.  (ongoing 
action)  

C-octaBDE (hexaBDE and heptaBDE) uses  

The  main  remaining  c-octaBDE  in  articles  in  use,  export  and  recycling  is  the  use  as  flame 
retardant in plastic in electrical and electronic equipment (EEE).   

PBDE/BFR-containing  plastic  (mainly)  from  WEEE  is  often  recycled  to  other  plastic 
materials by blending them with virgin polymer materials. Due to the mix of polymer types 
the  WEEE  plastic  is  typically  down-cycled  to  products  in  applications  with  less  material 
demanding properties. Screening of plastic products has revealed that even sensitive uses like 
children toys (Chen 2009) along with  household  goods (Chen 2010) and video tapes (Hirai 
2007)314 can be contaminated with PBDE and other BFRs.  

While  concentrations  of  POP-PBDEs  within  products  manufactured  in  the  Union  may  be 
expected  to  have  declined,  import  may  be  an  issue.  One  study  by  Whiting  et  al315  (2017) 
based on analysis of high street goods in the UK manufactured outside of the Union (based 
on product markings) (30 samples including 15 electrical items and 15 non-electrical items) 
indicated  concentrations  of  hexaBDE  from  6-2,700  mg/kg  and  of  heptaBDE  from  15  – 
21,000  mg/kg.  Homologues  of  c-octaBDE  (hexa  and  hepta)  were  detected  in  18  out  of  30 
samples.  Import  of  plastic  goods  that  contain  POP-PBDEs  as  a  result  of  recycling,  in  less 
expensive  electrical  goods  such  as  keyboards  and  IT  periphals  is  another  potential  supply 
route for goods reaching the Union market. Where such supply chains are complex and flow 

311  Ireland EPA (2015), ‘studies reported within the Ireland National Implementation Plan. 
312  Swedish Environmental Protection Agency, 2010, “The Use of Brominated Flame Retardants in Automotive 

and Construction Materials and the Treatment of Such Materials in the Waste Stream”. 

313  Defra (2016), ‘Annual report for Further update of the UK’s POPs multi-media emission inventory – Work 

Package 3: ‘Analysis of PBDEs from end of life vehicles’, ref CB0489 

314  Hirai,  Y.  Sakai,  S.-i.  (2007).  Brominated  Flame  Retardants  in  Recycled  Plastic  Products.  BFR2007:  4th 

International Symposium on Brominated Flame Retardants. 

315  Defra (2017), ‘Annual report for Further update of the UK’s POPs multi-media emission inventory – Work 

Package 3: ‘Analysis of PBDEs from non-EU plastics’, ref CB0489. 

124 

 
 
 
 
                                                           
of material globally is not well tracked, identification of PBDE contaminated material proves 
difficult. 

The  Stockholm  Convention  Secretariat  have  however  provided  detailed  guidance  for  the 
development  of  POP-PBDE  emission  inventories  (including  waste  aspects)316  as  well  as 
guidance  on  sampling,  analysis  and  screening  of  POPs  (including  POP-PBDEs)  in  articles 
and waste317.  

Information at Union level is variable across different Member States. UNEP comment that 
only  a  few  full  scale  e-waste  recycling  facilities  were  separating  PBDE  containing  plastic 
(UNEP 2011a,b)318. One facility in Switzerland had an automatic separation step for WEEE 
plastic  containing  BFRs  (halogens).  Additionally,  information  is  available  from  Sweden  on 
the  separation  of  BFR-containing  plastics  from  WEEE  plastics319.  Ramboll  (2019)  provide 
mass-flow  estimates  for  some  PBDEs  (in  particular  decaBDE  –  see  next  section)  but  also 
comment that materials likely to contain high PBDE concentrations can be readily separated 
in waste treatment plants by density separation. BSEF (2020) commented that 55% of plastics 
from  WEEE  entering  WEEE  processing  facilities  is  converted  to  regranulated  plastics  for 
recycling.  The  Ramboll  (2019)  report  states  that,  based  on  feedback  from  EERA, 
approximately 30 specialised recycling facilities exist across Europe.  

However,  for  WEEE  articles  recycled  outside  of  the  Union,  the  waste  management  may 
operate to lower standards. This represents a possible issue for imported plastic granulate (as 
a raw material) or articles that include recycled plastics manufactured outside of the Union. 

Action  5:  Commission  to  encourage  Member  States  to  make  use  of  the  UNEP  guidance 
documents on POP-PBDE emission inventories, and sampling, analysis and separation of 
POP-PBDEs  in  waste  as  part  of  national  level  planning  for  implementation  plans.  (new 
action) 

Action  6:  Commission  to  gather validated measurement methods to control the  export of 
waste  plastic  containing  PBDE  in  particular  electronic  waste  in  the  Member  States,  and 
depending  on  the  outcome  and  the  quality  of  information  take  further  actions.  (ongoing 
action) 

316  UNEP  (2017)  Guidance  for  the  inventory  of  polybrominated  diphenyl  ethers  (PBDEs)  listed  under  the 

Stockholm Convention on Persistent Organic Pollutants. 

317http://chm.pops.int/Implementation/NIPs/Guidance/GuidancefortheinventoryofPBDEs/tabid/3171/Default.aspx 
318  In  the  “Technical  Review  of  the  Implications  of  Recycling  Commercial  Pentabromodiphenyl  Ether  and 
Commercial  Octabromodiphenyl  Ether”  for  the  6th  POP  Reviewing  Committee  meeting  Geneva  October 
2010  (UNEP/POPs/POPRC.6/2  (a)  and  UNEP/POPs/POPRC.6/INF/6  (b)),  such  information  has  been 
compiled including information on facilities operated. 

319  Recycling of WEEE Plastics Containing Brominated Flame Retardants- a Swedish perspective”, Recycling 

Development AB and Vascaia, made for the Swedish EPA, 2010. 

125 

 
 
 
 
 
 
                                                           
5.1.4.  C-DecaBDE uses 

The  main  use  of  c-decaBDE  was  as  a  flame-retardant  in  within  articles;  in  particular  the 
dominant use of c-decaBDE was within plastics (circa-80%), particularly for electrical goods. 
However c-decaBDE has also been used within textiles and foams (circa-20%). The lifespan 
of all potential goods treated with c-decaBDE can be in excess of ten years. Noting that the 
phase-out of c-decaBDE began much later than c-pentaBDE and c-octaBDE320. Furthermore, 
c-decaBDE  was  used  more  extensively  than  c-pentaBDE  or  c-octaBDE.  The  Union  risk 
assessments  from  2001  and  2003  comment  that  total  use  of  all  commercial  PBDEs  in  the 
Union  at  that  time  amounted  to  11,000  tonnes  per  annum.  However,  use  of  c-decaBDE 
accounted for 75% of this quantity. Furthermore, Ramboll (2019) estimated that, as of 2015, 
1.2 million tonnes of plastics from waste electrical and electronic equipment were generated 
containing 630 tonnes of decaBDE. 

The extensive use of c-decaBDE  and potentially  significant  stockpile of in-use plastics and 
textiles yet to enter the waste stream represents a significant challenge for the waste handling 
sector.  Decabromodiphenyl  ether  has  been  added  to  Annex  IV  of  the  POPs  Regulation  to 
define the critical threshold (low POP content value), which is currently set at 1,000 mg/kg 
for waste.  

However,  one  key  point  of  interest  is  the  need  for  quick  and  easy  identification  of  POP 
brominated  flame-retardants  in  plastics,  foams  and  textiles,  including  decabromodiphenyl 
ether. A range of POP and non-POP BFRs have been used within plastics, foams and textiles, 
with  analysis  of  specific  species  both  costly  and  time  consuming  (requiring  full  laboratory 
analysis).  Therefore  it  is  a  challenge  for  the  waste  handling  industry  to  manage  wastes 
appropriately  in  order  to  comply  with  the  thresholds  in  Annex  IV  and  V  of  the  POPs 
Regulation. 

Section 3.2.12 highlighted the exploratory work around the use of handheld XRF equipment, 
used  to  identify  bromine  as  a  marker  for  where  a  BFR  has  been  used,  and  extrapolation 
against the critical thresholds for waste listed under Annex IV and V of the POPs Regulation. 
However, further analysis and work is needed to provide guidance on how techniques can be 
used for the correct management of waste and to avoid POPs re-entering commercial markets 
through  recycled  materials.  The  POPs  Regulation  recognised  this  fact  and  sets  in  place  a 
requirement for the Commission to review the Annex IV waste threshold within two years of 
entry  into  force,  with  the  aim  to  reduce  the  threshold  from  1000  mg/kg  to  500  mg/kg  if 
possible. 

Finally, one further consideration is  the type of  waste flow affected. Earnshaw et  al  (2013) 
commented that 75% of decaBDE was used within plastic applications, particularly electrical 
equipment and vehicles which have a defined waste stream under the WEEE and the end of 
life vehicles Directives. The remaining 25% of usage was  within textiles and foams (which 
includes  use  in  vehicles).  For  those  waste  streams  not  covered  by  WEEE  or  end-of-life 
vehicles requirements, it may be more challenging to identify decaBDE waste mixed in with 
general  municipal  waste  flows.  Note  however  that  usage  would  likely  be  related  to  bulky 
items such as sofas, armchairs, mattresses, and carpets. However, it is highly likely that there 

320  European phase-out for the use of c-pentaBDE and c-octaBDE began in the late 1990s / early 2000s leading 
up to a  ban in 2004. C-decaBDE  was expected to have  begun phase-out  from  the latter part of the 2000s, 
leading up the SVHC listing in 2012, but in some application phase-out may not have begun until after this 
date. 

Action 7: Commission to review how best to support screening and management 
techniques for POP-PBDEs and HBCDD within textiles and foam waste streams. (new 
action). 

126 

 
 
                                                           
will be a lower level of awareness of POP-PBDEs for waste operatives managing such waste, 
and application of screening techniques such as handheld XRF is unlikely. Further note that 
there may be similar issues for HBCDD which was also used in soft furnishing applications. 

5.1.5.  DDT 

Obligation:  Article  3,  paragraph  1(b)  and  Annex  B,  Part  II  of  the  Convention:  restrict  the 
manufacture and/or use of DDT, in accordance with the provisions of Annex B, Part II. The 
use of DDT as disease vector control is allowed as acceptable purpose. 

Implementation  so  far:  Manufacture,  placing  on  the  market  and  use  of  DDT  as  such,  in 
mixtures or in articles is totally prohibited by the POPs Regulation. No exemption is granted 
by the Regulation. 

On  the  basis  of  note  (iii)  of  Annex  B,  Part  I,  of  the  Stockholm  Convention,  the  POPs 
Regulation initially granted an exemption for Spain to continue the existing manufacture of 
dicofol  using  DDT  as  site-limited,  closed-system  intermediate  until  1  January  2014.  This 
notes that dicofol itself was subsequently listed as a POP under the Stockholm Convention. 
The exemption of use of DDT in dicofol manufacture was withdrawn from Regulation (EC) 
No 850/2004 in 2010. The Commission decided on the non-inclusion of dicofol in Annex I to 
Council  Directive  91/414/EEC  and  on  the  withdrawal  of  authorisations  for  plant  protection 
products  containing  that  substance  (Commission  Decision  2008/764/EC)321  in  2008. 
According  to  the  Commission  Decision,  all  existing  authorizations  for  dicofol  in  plant 
protection  products  had  to  be  withdrawn  before  30  March  2009.  National  registration  of 
dicofol was not possible after March 2009. However, feedback from the Spanish environment 
ministry  (MITECO)  confirmed  that  the  only  manufacturer  of  dicofol  in  Spain  ceased 
production in 2006. 

Analysis:  Legal  measures  are  considered  comprehensive.  There  is  no  need  for  further 
legislative measures at Union or Member State level. 

5.1.6.  Perfluorooctane  sulfonic  acid,  its  salts  and  perfluorooctane  sulfonyl  fluoride 

(PFOS) 

Obligation: Article 3, paragraph 1(b)  and Annex B, Part  III  of the Convention:  restrict the 
manufacture  and/or  use  of  perfluorooctane  sulfonic  acid,  its  salts  and  perfluorooctane 
sulfonyl  fluoride,  in  accordance  with  the  provisions  of  Annex  B,  Part  III.  For  registered 
Parties, numerous acceptable purposes and specific exemptions had initially been granted for 
the  manufacture  and/or  use.  By  decision  SC-4/17,  adopted  at  COP9,  the  vast  majority  of 
acceptable purposes and specific exemptions were deleted. 

Article 3, paragraph 6: take appropriate measures to ensure that any manufacture or use under 
a specific exemption in accordance with Annex A or a specific exemption or an acceptable 
purpose in  accordance with Annex B is  carried out  in  a manner that prevents  or minimizes 
human exposure and release into the environment. For exempted uses or acceptable purposes 
that  involve  intentional  release  into  the  environment  under  conditions  of  normal  use,  such 

321  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:262:0040:0041:EN:PDF  

127 

 
 
 
 
                                                           
release  shall  be  to  the  minimum  extent  necessary,  taking  into  account  any  applicable 
standards and guidelines. 

Recommendations COP-7 

At  COP-7  it  was  agreed  to  develop  terms  of  reference  for  a  technical  paper  on  the 
identification  and  assessment  of  alternatives  to  the  use  of  perfluorooctane  sulfonic  acid  in 
open applications, including the consideration of the following aspects of the substitution of 
perfluorooctane  sulfonic  acid,  taking  into  account  the  general  guidance  on  considerations 
related  to  alternatives  and  substitutes  for  listed  persistent  organic  pollutants  and  candidate 
chemicals: 

  Technical feasibility; 

  Health and environmental effects; 

  Cost-effectiveness; 

  Efficacy; 

  Availability; 

  Accessibility; 

Implementation  so  far:  Manufacture,  placing  on  the  market  and  use  of  perfluorooctane 
sulfonic acid, its salts and perfluorooctane sulfonyl fluoride as such, in mixtures or in articles 
is  severely  restricted  by  the  POPs  Regulation.  On  the  basis  of  acceptable  purposes  and 
specific and general exemptions granted by the Convention, the Regulation provides for the 
following exemptions: 

  placing on the market and use is allowed in concentrations of PFOS equal to or 
below 10 mg/kg (0,001 % by weight) when it occurs in substances or in mixtures;  
  concentrations of PFOS  in  semi-finished products  or articles, or parts thereof is 
allowed, if the concentration of PFOS is lower than 0,1 % by weight calculated 
with reference to the mass of structurally or micro-structurally distinct parts that 
contain PFOS or, for textiles or other coated materials, if the amount of PFOS is 
lower than 1 μg/m2 of the coated material; 

  use  of  articles  already  in  use  in  the  Union  before  25  August  2010  containing 

 

PFOS as a constituent of such articles is allowed; 
if  the  quantity  released  into  the  environment  is  minimised,  manufacture  and 
placing  on  the  market  is  allowed  for  the  following  specific  uses  provided  that 
Member  States  report  to  the  Commission  every  four  years  on  progress  made  to 
eliminate  PFOS:  mist  suppressants  for  non-decorative  hard  chromium  (VI) 
plating in closed loop systems (more detail in 3.2.7); 

Manufacturing  of  perfluorooctane  sulfonic  acid,  its  salts  and  perfluorooctane  sulfonyl 
fluoride was in recent years limited to only one Member State (Germany). According to the 
annual  reporting  information  submitted  by  Member  States  under  Regulation  (EC)  No 
850/2004  in  2013,  2014  and  2015,  PFOS  was  still  produced  in  Germany  in  quantities  of 
around  9  tonnes  per  annum.  This  was  primarily  used  for  hard  chromium  (VI)  plating    (cf. 
section 3.2.7).  

128 

 
 
 
 
Concerning  fire-fighting  foams  that  were  placed  on  the  market  before  27  December  2006 
continued use was allowed up until 27 June 2011. In this regard it is worthwhile making the 
distinction  between  public  fire  and  rescues  services  and  private  fire  services,  such  as  those 
used to protect airports. Public services attend to more ‘real’ incidents and would be expected 
to have a higher rate of replacement for stocks of foams,  wheareas private brigades tend to 
make use of foams for training exercises. Efforts have been made to gather and remove PFOS 
containing fire fighting foams across Europe, however it is likely that some stocks remain in 
the Union, and are still in the process of disposal (cf. section 3.2.7). 

There  is  an  onus  on  Member  State  Competent  Authorities  to  work  with  fire  services  to 
identify and remove such stockpiles, which should extend to those private fire services that 
may still retain older stockpiles. 

Annex  I,  Part  A  of  the  POPs  Regulation  also  provides  that  as  soon  as  new  information  on 
details of uses and safer alternative substances or technologies for the specific uses becomes 
available, the Commission shall review the derogations in the second subparagraph so that: 

 

the  uses  of  PFOS  will  be  phased  out  as  soon  as  the  use  of  safer  alternatives  is 
technically and economically feasible; 

  a derogation can only be continued for essential uses for which safer alternatives 
do not exist and where the efforts undertaken to find safer alternatives have been 
reported on; 
releases  of  PFOS  into  the  environment  have  been  minimised  by  applying  best 
available techniques. 

 

At COP-9, the Conference of Parties decided to amend the entry regarding PFOS in Annex B, 
with  the  removal  or  modification  of  several  acceptable  purposes  and  specific  exemptions. 
The POPs Regulation already took into account this amendment with the exception of the use 
for chromium plating in closed loop system. The modification under the Convention has been 
implemented  in  the  POPs  Regulation  through  Commission  Delegated  Regulation  (EU) 
2020/1203322. 

Analysis: The use of PFOS in the metal plating industry is the only remaining use of PFOS 
in the Union. Alternatives and substitutes have already been investigated for this use but there 
is a lack of practical implementation (cf. section 3.2.7). With a view to phase-out this use of 
PFOS,  support  of  practical  implementation  projects  to  help  mostly  concerned  SMEs  in 
phasing in alternative processes to PFOS might be desirable.  

The collection of information  for BAT/BEP  for  PFOS  use in  industrial processes under the 
Convention has just been initiated. It is desirable that Member States gather information and 
document BAT/BEP for the listed exemptions and forward the information to the Stockholm 
Convention Secretariat for consideration in the Stockholm Convention process.  

The  Stockholm  Convention  has  a  dedicated  process  for  collecting  information  on  PFOS 
alternatives,  with  a  first  report  developed  in  2010  for  the  POPs  Reviewing  Committee323. 

322  Commission Delegated Regulation (EU) 2020/1203 of 9 June 2020 amending Annex I to Regulation (EU) 
2019/1021 of the European Parliament and of the Council as regards the entry for perfluorooctane sulfonic 
acid and its derivatives (PFOS) (OJ L 270, 18.8.2020, p. 1). 

323  http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5Followupco
mmunications/PFOSalternativesguidanceInvitationforcomments/tabid/741/language/en-US/Default.aspx 

129 

 
 
 
                                                           
This has since been supplemented with the body of work looking at alternatives presented at 
the 10th POP Review Committee meeting and will continue to be updated in future POPRC 
meetings.  PFOS  is  present  in  broad  range  of  articles  at  relatively  low  concentrations. 
Measurement  of  concentration  of  PFOS  and  its  precursors  in  articles  at  low  levels  is  the 
major challenge of compliance and border controls. Additionally the POPs Regulation sets in 
place threshold values under Annexes IV and V regarding wastes that may be contaminated 
with  POPs.  Those wastes that  exceed the thresholds  in  Annexes  IV and  V, from  which the 
POP  content  cannot  be  separated,  must  be  disposed  of  or  recovered  (in  accordane  with  the 
Annexes)  in  such  a  way  as  to  ensure  that  the  POP  content  is  irreversibly  transformed  or 
destroyed.  Therefore  analytical  assessment  of  wastes  is  also  important  in  the  correct 
management of these materials. 

Under  the  Stockholm  Convention  a  small  intersessional  working  group  (SIWG)  which  is 
chaired  by  Canada  has  been  created  to  help  develop  technical  guidelines  for  POPs,  which 
includes review of low POP concentrations for PFOS324. 

The Commission has mandated the work of European Committee for Standardization (CEN) 
to  develop  a  standard  analytical  method  for  determination  of  PFOS  in  articles.  Technical 
specification  CEN/TS  15968  titled  'Determination  of  extractable  PFOS  in  coated  and 
impregnated solid articles, liquids and fire-fighting foams – Method for sampling, extraction 
and  analysis  by  LC-qMS  or  LC-tandem/MS'  was  adopted  by  the  CEN  in  2010.  The 
Commission understands that this assessment method has now been validated.  

No  exemptions  for  recycling  of  PFOS  containing  articles  have  been  granted.  Therefore 
recycling of PFOS containing materials above the limit of 50 mg/kg defined in Annex IV of 
the  POPs  Regulation  is  not  allowed.  Commission  contracted  a  study  (ESWI  2011)325  to 
gather  information  on  the  status  of  recycling  flows  possibly  including  PFOS  containing 
materials.  The  study  showed  that  recycling  activities  of  some  potentially  PFOS  containing 
materials are taking place but the concentration of PFOS is low. Probably the most relevant 
recycling activity in this respect is the recycling of synthetic carpets potentially contaminated 
with  PFOS  or  PFOS  precursors326.  Other  materials  potentially  contaminated  with  PFOS  or 
PFOS precursors are e.g. textiles, paper or aviation fluid.  

5.1.7.  Perfluorooctanoic acid, its salts and related-compounds (PFOA)327 

Obligation:  The  decision  adopted  at  COP9  of  the  Convention  (SC-9/12)  stipulates  that 
perfluorooctanoic acid, its salts and related-compounds are listed within Annex A, part I of 
the Convention. Under Article 3, paragraph 1(a) this prohibits the manufacture and/or use of 
PFOA, its salts and related compounds, unless an acceptable purpose or specific exemption is 
granted.  The  decision  does  not  identify  any  acceptable  purpose;  however,  a  wide  range  of 
specific exemptions are listed, largely covering only use. The decision states that production 

324  http://www.basel.int/Implementation/POPsWastes/Meetings/MeetingoftheSIWGonPOPs/tabid/4349/Default

.aspx 

325  ESWI (2011): Study on waste related issues of newly listed POPs and candidate POPs. Service request under 

the framework contract No ENV.G.4/FRA/2007/0066. Final report of 13 April 2011. 

326  See for example http://www.carpetrecyclinguk.com  
327 Note that at the time of writing (November 2020) the update of the convention text by the Secretariat of the 
Convention for additions at COP9 was still being prepared. The text presented here is based on the standard 
text of the Convention and decision documents from COP9. 

130 

 
 
 
                                                           
of  fire-fighting  foams  containing  PFOA,  its  salts  or  related-compounds  is  not  granted  a 
specific exemption. 

Under  the  COP9  decision  specific  exemptions  for  use  are  listed  for  the  following 
applications: 

  Photolithography or etch processes in semiconductor manufacturing.  

  Photographic coatings applied to films. 

  Textiles  for  oil  and  water  repellency  for  the  protection  of  workers  from  dangerous 

liquids that comprise risks to their health and safety.  

 

Invasive and implantable medical devices.  

  Fire-fighting  foam  for  liquid  fuel  vapour  suppression  and  liquid  fuel  fires  (Class  B 
fires)  in  installed  systems,  including  both  mobile  and  fixed  systems,  in  accordance 
with paragraph 2 of part X of this Annex.  

  Use  of  perfluorooctyl  iodide  for  the  production  of  perfluorooctyl  bromide  for  the 
purpose of producing pharmaceutical products,  in accordance with  the provisions of 
paragraph 3 of part X of this Annex.  

  Manufacture of polytetrafluoroethylene (PTFE)  and polyvinylidene fluoride (PVDF) 

for the production of:  

o  High-performance,  corrosion-resistant  gas  filter  membranes,  water  filter 

membranes and membranes for medical textiles  

o  Industrial waste heat exchanger equipment  

o  Industrial  sealants  capable  of  preventing 

leakage  of  volatile  organic 

compounds and PM2.5 particulates.   

  Manufacture  of  polyfluoroethylene  propylene  (FEP)  for  the  production  of  high-

voltage electrical wire and cables for power transmission.  

  Manufacture  of  fluoroelastomers  for  the  production  of  O-rings,  v-belts,  and  plastic 

accessories for car interiors.   

As  part  of  the  specific  exemptions,  the  COP9  decision  states  that,  by  the  end  of  2022,  if 
operators  have  capacity  to  do  so,  but  no  later  than  2025,  the  uses  of  PFOA,  its  salts  and 
related-compounds within fire-fighting foam must be restricted to sites where releases can be 
contained. 

Recommendations from COP-9 

At COP-9 the Secretariat invited Parties and Observers to provide data by December 2025 on 
the  production,  use,  efficacy  of  control  measures,  information  on  alternatives,  status  of 
control  and  monitoring,  and  any  national  or  regional  control  actions  taken.  The  Secretariat 
will use this information to compile a document for use by the POPs Review Committee in 
2026, to make further recommendations on the phase-out of PFOA and replacement by safer 
alternatives. 

131 

 
 
 
The  further  discussions  at  COP9  (detailed  in  the  meeting  report  –  UNEP/POPS/COP.9/30) 
highlighted  the  importance  of  substance  identity  for  PFOA-related  compounds.  The 
recommendations from the POPRC outline an approach and nomenclature to identify PFOA-
related  compounds.  However,  the  number  of  substances  included  within  the  scope  may  be 
substantial. 
Implementation so far: In 2017, PFOA its salts and PFOA-related substances328 were added 
to Annex XVII of the REACH Regulation (No 1907/2006)329. The entry on PFOA in Annex 
XVII has been deleted by Commission Regulation (EU) 2020/2096330 to ensure legal clarity 
after  PFOA  had  been  added  to  Annex  I  of  the  POPs  Regulation  through  Commission 
Delegated Regulation (EU) 2020/784331.  

The listing means that, as of 4 July 2020, PFOA, its salts and related compounds must not be 
manufactured, or placed on the market as substances on their own, and must also not be used 
in  the  production  of  another  substance,  mixture,  or  article.  In  addition,  PFOA,  its  salts  and 
related-compounds  are  subject  to  all  other  requirements  of  the  POPs  Regulation,  including 
those on waste. 

A number of exemptions are listed under Commission Delegated Regulation (EU) 2020/784. 
Analysis: To date PFOA has had a wide range of uses, primarily linked to its water and oil 
repellency  as  well  as  thermal  stability,  which  provide  a  technical  function  as  a  surfactant, 
levelling  agent,  or  water/oil/dirt  repellant.  It  has  also  been  used  as  a  processing  aid  in  the 
manufacture  of  fluoropolymers,  particularly  polytetrafluoroethylene  (PTFE).  However, 
mounting  concerns  over  C8  per/polyfluoroalkyl  acids  (PFAAs),  which  began  in  the  1990s 
with  PFOS,  meant  that  industry  began  to  transition  away  from  PFOA  as  early  as  the  mid 
2000s332.  The  US  EPA  stewardship  Group,  formed  in  2006,  by  the  eight  largest  global 
manufacturers  of  PFOA  aimed  to  phase-out  production  of  PFOA  by  2015333,  which  was 
shortly followed by the nomination to the Stockholm Convention, also in 2015. 

The REACH restriction for PFOA, its salts and related-compounds which entered into force 
in March 2019, with thresholds implemented from July 2020, further enforced the phase-out 
of PFOA, its salts and related-compounds from use in the Union.  

328  Any related substance (including its salts and polymers) having a linear or branched perfluoroheptyl group 
with  the  formula  C7F15-  directly  attached  to  another  carbon  atom,  as  one  of  the  structural  elements;  Any 
related substance (including its salts and polymers) having a linear or branched perfluorooctyl group with the 
formula C8F17- as one of the structural elements. 

329  Commission Regulation (EU) 2017/1000 amending Annex XVII to Regulation (EC) No 1907/2006 of the 
European Parliament and of the Council concerning REACH as regards perfluorooctanoic acid (PFOA), its 
salts and PFOA-related substances (see https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32017R1000) 

330  Commission Regulation (EU) 2020/2096 of 15 December 2020 (OJ L 425, 16.12.2020, p. 3). 
331  Commission Delegated Regulation (EU) 2020/784 of 8 April 2020 amending Annex I to Regulation (EU) 
2019/1021 of the European Parliament and of the Council as regards the listing of perfluorooctanoic acid 
(PFOA), its salts and PFOA-related compounds (OJ L 188 I, 15.6.2020, p. 1). 

332  Wang  et  al,  2014,  ‘Global  emission  inventories  for  C4-C14  perfluoroalkyl  carboxylic  acid  (PFCA) 
homologues  from  1951-2030,  Part  I:  production  and  emissions  from  quantifiable  sources’,  Environmental 
International Vol 70 pp 62-75 

333 The PFOA stewardship group reported that phase-out of production had been achieved in early 2016. See: 
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-
program (however, note that non-member companies may have continued to produce PFOA after this date). 

132 

 
 
                                                           
During  discussions  at  subsequent  POPRC  meetings  and  COP9  the  issue  of  remaining 
stockpiles was discussed, particularly related to fire-fighting foams. Where PFOS and PFOA 
were  both  used  in  firefighting  foams  (as  C8  PFAS  chemistry),  it  is  suggested  that  the 
transition  away  from  PFOS  likely  also  included  a  transition  away  from  C8  chemistry  more 
generally (including PFOA).  

The bigger issue,  given  the more  recent  phase-out  date of PFOA, is  management of PFOA 
within stockpiles and legacy waste more generally. PFOA has been used across a very wide 
range  of  articles  (such  as  textiles,  components  for  transport,  medical  devices,  construction, 
and semi-conductors), and therefore may present challenges both in terms of management of 
PFOA wastes in the waste cycle, but also releases to environment from final waste disposal 
sites (landfill). 

Furthermore,  while  the  Commission  has  mandated  the  work  of  European  Committee  for 
Standardization (CEN) to develop a standard analytical method for determination of PFOS in 
articles, no such standard is  currently in  place for PFOA or PFOA related-compounds.  The 
PFOS standard may form a good basis for the development of a subsequent PFOA standard. 

While  PFOA,  its  salts  and  related-compounds  were  added  to  the  POPs  Regulation  in  April 
2020,  work  to  define  a  low  POP  content  threshold  under  Annex  IV  is  ongoing,  with  the  
expectation  that  management  of  PFOA  within  waste  will  be  a  key  issue  for  the  POPs 
Regulation in the short to medium term (i.e. next five to ten years). 

5.2. 

Elimination  of  import  and  export  of  POPs  -  Article  3(2)  of  the  Stockholm 
Convention 

Obligation:  Article  3,  paragraph  1(a)(ii):  prohibit  and/or  take  legal  or  administrative 
measures  necessary  to  eliminate  the  import  and  export  of the  chemicals  listed  in  Annex  A. 
Article 3, paragraph 2 of the Convention: take measures regarding the import and export of 
chemicals in Annex A or Annex B. 

Implementation so far: Import is regarded as placing on the market in the Union and thus 
import of all Annex A and B chemicals is prohibited by the POPs Regulation except for the 
following exemptions: 

  A substance used for laboratory-scale research or as a reference standard; 
  A  substance  occurring  as  an  unintentional  trace  contaminant  in  substances, 

mixtures or articles; 

  A  substance  as  such  or  as  part  of  articles  for  the  purpose  of  environmentally 

sound disposal; 

  A substance as such or as part of articles for a use or purpose which is permitted 

by the POPs Regulation, e.g. PFOS for the exempted use. 

Export of POPs listed in Annex V to Regulation (EU) No 649/2012 is prohibited, except for 
chemicals  in  quantities  not  likely  to  affect  health  or  the  environment,  and  in  any  event  not 
more than 10 kg, provided that they are exported for the purpose of research or analysis.  

Analysis: The existing legal measures on import and export cover the obligations laid down 
in  the  Stockholm  Convention.  The  above  mentioned  regulations  are  directly  applicable 
legislation  in  all  Member  States.  To  enforce  the  legislation,  effective  border  control  by 

133 

 
 
 
 
Member States is a necessity. This may benefit from individual tariff codes for the listed POP 
chemicals. 

Action  8:  Commission  to  investigate  the  possibility  to  initiate  international  work  on 
development of individual tariff codes for POP substances334. (ongoing action) 

5.3. 

Prevention  of  the  manufacture  and  use  of  new  chemicals  exhibiting 
characteristics of POPs - Article 3(3) of the Stockholm Convention 

Obligation:  Article  3(3):  Take  measures  to  regulate  with  the  aim  of  preventing  the 
manufacture  and  use  of  new  chemicals  and  pesticides  which,  taking  into  consideration 
criteria in paragraph 1 of Annex D of the Stockholm Convention, exhibit the characteristics 
of persistent organic pollutants. 

Implementation  so  far:  Article  3(3)  of  the  POPs  Regulation  repeats  the  provision  of  the 
Stockholm Convention but the practical implementation is left to be done in the framework of 
the  existing  Union  regulatory  and  assessment  schemes  for  chemicals,  plant  protection 
products  and  biocides.  The  REACH  Regulation  (EC)  No  1907/2006  (cf.  section  2.2.3.1), 
Regulation  (EC)  No  1107/2009  (plant  protection  products)  (cf.  section  2.2.3.3)  and 
Regulation  (EU)  No  528/2012  (biocidal  products)  (cf.  section  2.2.3.4)  are  in  this  regard  of 
particular importance. 

Analysis: Manufacture and placing on the market of POP like substances can in principle be 
effectively  prevented  within  the  existing  regulatory  frameworks  for  chemicals  (cf.  section 
2.2.3). Although there are tonnage triggers for registration below which the data submitted to 
the authorities will not necessarily be sufficient for POP assessment in the framework of the 
REACH Regulation, it addresses specifically SVHCs with PBT criteria through its system of 
authorisation  that does  not  have any tonnage trigger. Furthermore, the European Chemicals 
Agency  has  a  right  to  request  further  information  from  companies  if  it  suspects  that  a 
substance might exhibit POP characteristics (cf. section 2.1.2). 
Regulation (EC) No 1107/2009335 concerning the placing of plant protection products on the 
market (PPP Regulation) prevents chemicals exhibiting POP characteristics from being used 
in plant protection products. This is achieved by the provisions according to which an active 
substance,  safener  or  synergist  shall  only  be  approved  for  use  in  plant  protection  products 
where it is not considered to be a POP or if it is not considered to be a PBT substance or a 
very persistent and very bioaccumalative substance (vPvB). In addition, a substance shall be 
approved as a candidate for substitution if it meets two of the PBT criteria. 

Regulation  (EU)  No  528/2012  on  biocidal  products  prevents  chemicals  exhibiting  POP 
characteristics  from  being  used  in  biocidal  products.  This  is  achieved  by  the  provisions 
according  to  which  an  active  substance  cannot  be,  in  principle,  approved  if  it  meets  the 
criteria  for  being  persistent,  bioacumulative  and  toxic  or  very  persistent  and  very 
bioacumulative  according  to  Annex  XIII  to  REACH  Regulation.  In  addition,  a  substance 
shall be approved as a candidate for substitution if it meets two of the PBT criteria. 

334  This action had already been part of the ECIP issued in 2007 and has not yet been achieved. It is hence taken 

over as an action into the current implementation plan. 

335  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:309:0001:0050:EN:PDF 

134 

 
 
 
                                                           
The  Chemicals  Strategy  for  Sustainability336  announces  that  the  Commission  will  work 
towards  adding  hazard  classess  for  PBT  and  vPvB  substances  in  the  CLP  Regulation.  This 
will help identifying and restricting, as appropriate, potential POP substances throughout all 
relevant legislation in a more effective and consistent manner. 

Proper enforcement of the obligation will require concerted action by the industry, rapporteur 
Member States, other Member States, the Commission and the European regulatory agencies 
involved in the risk assessment of chemicals. 

Action 9: Commission and Member States to ensure that the POP assessment is properly 
incorporated  in  the  assessment  of  chemicals  subject  to  different  legislative  provisions 
within the Union. (continuous action) 

5.4. 

Assessing  and  controlling  chemicals  in  use  -  Article  3(4)  of  the  Stockholm 
Convention 

Obligation:  Article  3(4):  Take  into  consideration  within  assessment  schemes  for  pesticides 
and chemicals in use, the criteria in paragraph 1 of Annex D when conducting assessments of 
pesticides and chemicals. 

Implementation so far: Article 3(3) of the POPs Regulation not only repeats but strengthens 
the  provision  of  the  Stockholm  Convention:  It  requires  the  Commission  and  the  Member 
States to take “appropriate control measures” on existing chemicals and pesticides exhibiting 
POP  characteristics.  As  in  the  case  of  new  chemicals  (see  section  2.2),  the  practical 
implementation  is  left  to  be  done  in  the  framework  of  the  existing  Union  regulatory  and 
assessment schemes for industrial chemicals, plant protection products and biocides. 

Analysis:  From  the  Stockholm  Convention’s  legal  implementation  point  of  view,  the 
legislative measures taken by the Union can be regarded as fully sufficient.  

The  distinction  of  new  and  existing  substances  is  not  anymore  regarded  as  fully  justified 
within  the  Union.  This  change  is  reflected  in  the  REACH  Regulation  and  will  be  reflected 
also in the regulatory frameworks set up for plant protection products and biocides when the 
extensive review programmes on the existing active substances have been accomplished. 

5.5. 

General exemptions 

Obligation:  Article  3(5)  of  the  Stockholm  Convention:  Not  to  apply  prohibitions  and 
restrictions  to  quantities  of  a  chemical  to  be  used  for  laboratory-scale  research  or  as  a 
reference standard. Notes (i)-(ii) of Annexes A and B: Quantities of a chemical occurring as 
unintentional  trace  contaminant  in  products  and  articles  or  occurring  as  constituents  of 
articles manufactured or already in use before or on the date of entry into force of the relevant 
obligation are exempted from the prohibitions / restrictions. 

Implementation  so  far:  Article  4(1)  and  (2)  of  the  POPs  Regulation  lay  down  the  general 
exemptions.  Member  States  are  obliged  to  notify  all  articles  containing  any  of  the  listed 

336  COM(2020) 667 final 

135 

 
 
 
 
 
                                                           
substances as constituents to the Commission, who in turn will notify the Secretariat in line 
with  note  (ii)  of  Annexes  A  and  B.  So  far  no  such  articles  have  been  identified  by  the 
Member States. 

The term of “unintentional trace contaminants” as mentioned in the Convention’s Annex A 
note (i) and Annex B note (i) is a challenge for the enforcement, particularly if a chemical is 
used in articles. Therefore other environmental and chemical legislation in the Union does not 
use  such  terms  but  they  rather  refer  to  concrete  maximum  concentration  values  (e.g.  the 
RoHS Directive). The aim of these fixed thresholds is to facilitate uniform enforcement and 
control and provides legal certainty to economic operators. Therefore, the POPs Regulation 
for the newly listed POPs with use in articles will contain fixed concentration values below 
which a substance is considered to be an "unintentional trace contaminant" (see sections 2.2.1 
and 3.2.12). 

Analysis: The legal  actions are sufficient and no further legal measures are needed. Border 
and market surveillance by the Member States is necessary and cases of non-compliance need 
to be reported to the Commission. 

5.6. 

Reduction  of  total  releases  from  unintentional  production  -  Article  5  of  the 
Stockholm Convention 

5.6.1.  Obligations and implementation 

Obligation:  Article  5:  To  reduce  the  total  releases  of  the  chemicals  listed  in  Annex  C 
(PCDDs, PCDFs, PCBs, HCB, PeCB, PAHs, hexachlorobutadiene and PCNs) with the goal 
of continuing their minimisation and, where feasible, achieving their elimination; To develop 
an  action  plan  to  identify,  characterise  and  address  the  releases  of  by-product  POPs;  To 
promote the application of available, feasible and practical measures to achieve a reasonable 
level of release reduction or source elimination and to promote the development and require 
the use of materials, products and processes to prevent the formation and release of chemicals 
listed in Annex C; To promote and require the use of BAT and BEP to prevent the release of 
chemicals listed in Annex C for new sources in main source categories; To promote the use 
of  BAT  and  BEP  for  existing  sources  from  the  main  source  categories  as  well  as  other 
categories. 

Implementation  so  far:  Article  6  of  the  POPs  Regulation  addresses  substances  for  which 
releases  should  be  reduced  and  minimised,  with  a  view  to  eliminate  them  if  feasible.  The 
substances  or  groups  of  substances  concerned  are  PCDDs/  Fs,  PCBs,  HCB,  PeCB,  HCBD, 
PCNs and PAHs, as listed in Annex III of the Regulation. Of these, all with the exemption of 
PAHs are listed in the Stockholm Convention and are therefore the main focus for the present 
implementation plan. 

According to Article 6 of the POPs Regulation,  Member States shall draw up and maintain 
release  inventories  for  the  substances  listed  in  Annex  III  into  air,  water  and  land  in 
accordance  with  their  obligations  under  the  Convention  and  the  Protocol.  Member  States 
were obliged to do so by 20 May 2006 for PCDDs, PCDFs, PCBs, and HCB, August 2012 
for  PeCB,  and  by  June  2021  for  HCBD  and  PCNs  which  were  included  in  the  POPs 
Regulation in 2019.  

Article  6  of  the  POPs  Regulation  further  stipulates  that  Member  States  shall  develop  an 
action plan on measures to identify, characterise and minimise the releases of unintentionally 

136 

 
 
 
produced  POPs.  The  action  plan  shall  include  measures  to  promote  the  development  and, 
where it deems appropriate, shall require the use of substitute or modified materials, products 
and processes to prevent the formation and release of the substances listed in Annex III. 

Member States  shall  furthermore,  when  considering proposals  to  construct  new facilities or 
significantly  to  modify  existing  facilities  using  processes  that  release  chemicals  listed  in 
Annex III of the Regulation, without prejudice to Directive 2010/75/EU (Industrial Emissions 
Directive),  give  priority  consideration  to  alternative  processes,  techniques  or  practices  that 
have  similar  usefulness  but  which  avoid  the  formation  and  release  of  substances  listed  in 
Annex III. 

Since  the  mid-1990s,  important  legislation  has  been  adopted  to  reduce  the  emissions  of 
PCDD/F, in particular in the areas of waste incineration and integrated pollution prevention 
and  control,  resulting  in  decreasing  levels  in  the  environment  and  in  the  human  population 
(see section 3.3.2). 

Inclusion of all Annex C substances (with the exception of PCNs) in the Water Framework 
Directive  has  further  contributed  to  the  reduction  of  emissions  of  these  substances  into 
aquatic  environment,  as  Member  States  have  an  obligation  to  ensure  that  concentrations  of 
these substances in the environment is below the environmental quality standard level.  

The implementation of the BAT conclusions adopted under the IED which BAT-AELs will 
be  another  step  to  further  reduce  releases  of  PCDD/F  and  other  unintentionally  produced 
POPs from industrial activities. Note that this now also includes BAT-AELs for dioxin-like 
PCBs (c.f. Table 12) 

The  Union  Strategy  for  Dioxins,  Furans  and  Polychlorinated  Biphenyls  adopted  in  2001 
(COM  (2001)  593)66  had  the  goal  to  assess  the  current  state  of  the  environment  and  the 
ecosystem,  to  reduce  exposure  from  dioxins  and  PCBs  to  humans  and  the  environment.  In 
October  2010  the  Commission  adopted  the  third  progress  report  on  the  Dioxin  strategy 
(COM (2010) 562 final)68 for the period 2007 to 2009. The report showed that over the last 
two decades 80% reduction of industrial emissions of PCDD/Fs and PCBs was achieved.  

The  generation  of  UPOPs  within  thermal  industrial  processes  typically  relate  to  the 
contamination  of  particulate  matter  within  the  waste  exhaust  system.  Abatement  measures 
designed to reduce the emission of PCDD/F releases into the atmosphere are likely to have 
synergistic  benefits  for  the  reduction  in  emissions  of  the  unintentionally  produced  PeCB, 
HCB, PAH and PCB. This reduction can occur through removal of particulates that acts as a 
seeding  surface  for  UPOPs,  or  through  removal  of  the  contaminated  particulates  as  air 
pollution control residues. On this basis it can be assumed that the above mentioned reduction 
of PCDD/F already had a similar effect for these other UPOPs. 

5.6.2.  Analysis of implementation 

Analysis: In section 3.3 of Part I, it is described that in the Union the release from POPs due 
to unintentional manufacture remains one of the most important issues to be tackled. Several 
actions  are  thus  dedicated  to  the  development  of  corresponding  measures  with  the  goal  to 
reach a further reduction of POP emissions.  

As the unintentional  manufacture  of POPs  has  historically been  largely related to  industrial 
processes  such  as  manufacture  of  iron  and  steel  (sinter  plants,  electric  arc  furnaces),  the 
manufacture of non-ferrous metals, the incineration of waste etc, the legislation dealing with 

137 

 
 
 
industrial  emissions  is  the  main  instrument  to  tackle  releases  of  unintentionally  produced 
POPs. The IPPC Directive has been replaced by the Industrial Emissions Directive (IED) that 
came into effect in January 2013. Further improvement of the situation is expected with the 
IED, because the BAT-AELs as listed in the BAT conclusions are to be used by permitting 
authorities when issuing permits for industrial installations.  

As the IED has a much wider scope than just reduction of POP emissions, it is important that 
POP-related expertise is present in the discussions about the BAT and BAT-AELs during the 
BREF review and update process. This should make sure that the prevention of the formation 
of POPs as well as the control of POP releases is taken into consideration adequately, with a 
view  to  developing  BAT  conclusions  (including  BAT-AELs  where  possible)  concerning 
emissions of unintentionally produced POPs. 

Action 10: Commission and Member States to ensure that BAT conclusions under the IED 
and related implementation measures consider the reduction of emissions of unintentionally 
produced POPs, including their potential transfer to other media and their presence in waste. 
(ongoing action) 

For air pollution control residues (fly ashes) and articles other than food and feed no PCDD/F 
regulation exists and the only relevant limit is the low POPs content of 15 ng TEQ/g as low 
POPs content. This value is high and there is a considerable debate on this provisional Basel 
Convention low POPs limit. For fly ashes in Japan e.g. a limit of 3 ng TEQ/g exists and in the 
Waste Incineration BREF fly ash values from German incinerators below 0.5 ng TEQ/g are 
mentioned. 

Action 11: To assess levels of PCDD/PCDFs in critical solid residues (fly ashes) and articles 
and  take  action  to  possibly  develop  BAT  and  maximum  concentrations  in  this  respect. 
(ongoing action) 

The European Commission have contracted an ongoing study to review the Annex IV and V 
threshold values  under the POPs  Regulation. This  will include dioxins and furans, with  the 
results  potentially  addressing  Action  12  above.  The  study  is  due  to  be  completed  in  July 
2021. 

In  addition  to  emissions  from  the  large  industrial  installations  also  small  scale  incinerators 
and diffuse sources are contributing to the release of PCDDs/PCDFs and other UPOPs. One 
activity which can contribute to reduction of UPOPs in this sector is the minimum eco-design 
requirements for solid fuel small combustion installations. Even though preparatory work is 
underway  concerning  this  action  it  is  being  renewed  here  as  the  inclusion  of  POP-related 
aspects (especially the generation of unintentionally produced POPs) should be a main focus 
of the still to be developed implementing measure (cf. section 3.3.3). 

Overall,  the  emissions  of  UPOPs  to  air  across  Europe  have  declined  significantly  over  the 
past 25 years, largely due to the measures outlined above. Data from the EMEP Webdab for 
reported emissions  in  each Member State indicate that emissions of PCBs, PCDDs/PCDFs, 
and HCB between 1990 and 2015, declined 74%, 75%, and 95% respectively.  

138 

 
 
 
The  relative  contribution  of  different  source  categories  to  the  oberved  total  emissions  of 
UPOPs in Europe has changed notably for some pollutants over the past 25 years. While the 
total  quantity  of  emissions  has  declined,  the  balance  between  regulated  point  sources  and 
non-regulated  domestic  or  diffuse  sources  has  shifted.  In  the  case  of  PCDDs/PCDFs,  the 
proportion attributed to industry has declined, with a corresponding increase in contribution 
from residential combusion. PCB emissions from industrial sources have also declined with 
the introduction of more efficient combustion and abatement processes, while the emissions 
from  electrical  equipment  (e.g.  dielectric  fluid,  leaks  from  transformers  and  capacitors  and 
wastes) have declines a lot more slowly, leading to a greater overall relative proportion from 
these sources.  

Action  12:  Commission to  table an implementing measure to  set  out  minimum  eco-design 
requirements for solid fuel small combustion installations. (ongoing action) 

As regards emissions of dioxins and PCBs from raw or treated sewage sludge that is used as 
fertilising  product,  the  Commission  is  carrying  out  a  study  with  a  view  to  adopt  further 
measures that aim at reducing such emissions, as appropriate. The study will be finalised in 
2021  and  any  measures  may  be  proposed  thereafter.  Moreover,  limits  might  be  set  for 
PCDD/F and non-dioxin like PCBs from other input materials for fertilisers such as struvite, 
biochar, incineration ashes. 

Action 13: Commission to finalise the study on contaminants in fertilising products and to 
propose/finalise measures that aim at further controlling unintentional emissions from such 
sources, as appropriate. (new action) 

5.6.3.  Pentachlorobenzene (PeCB) 

PeCB was listed in the Stockholm Convention Annexes A and C without exemptions in 2009. 
In the Union PeCB is not intentionally produced it is only addressed in the section of UPOPs.  

According  to  the  results  of  the  E-PRTR  (2007-2017  data)  PeCB  remains  unintentionally 
produced in the Union due to releases to air, largely from the manufacture and processing of 
metals,  and  to  water,  largely  from  urban  waste  water  treatment  plants,  with  lesser 
contributions from chemical manufacture  plants and oil and gas refineries. Emissions from 
domestic  sources  are  not  covered  by  the  scope  of  the  E-PRTR  Annex  I  activities  under 
Regulation  (EC) No 166/2006, although PeCB is expected to be emitted from the domestic 
use  of  coal  and  open  burning  of  wastes,  particularly  the  plastic  content.  In  such  cases,  an 
integrated  view  is  required  looking  at  all  emissions  of  halogenated  compounds  and  other 
pollutants to understand the individual situation. It would be beneficial if companies in this 
sector  or  Member  State  Competent  Authorities  could  assesses  what  BAT  measures  for 
reduction of PeCB emissions from this source sector could be used.  

The  review  of  E-PRTR  data  also  highlights  that  some  facilities  report  releases  of  PeCB 
significantly above the reporting threshold (1kg) and others do not at all. Based on the data 
reviewed  it  might  be  possible  that  there  is  under  reporting/non-reporting  from  a  number  of 
similar facilities within the metal manufacture sector, where releases of PeCB and potentially 

139 

 
 
 
 
 
also  HCB  might  be  expected337  to  be  considerably  above  1  kg/y.  One  reason  for  these 
inconsistencies  and  missing  data  could  possibly  be  the  lack  of  measurements  of  PeCB  and 
HCB in IED facilities as there are no legal requirements for PeCB and HCB measurements. 
Another  possible  reason  for  the  lack  of  reporting  may  stem  from  a  lack  of  awareness 
regarding sources of UPOPs with operators, which includes allowing operators to understand 
what a realistic set of emissions might look like for their facility.  

Manufacture  of  chlorinated  organics  and  their  deposits  from  historic  manufacture  were 
described  in  a  recent  POP  Reviewing  Committee  Report  (UNEP  2010c)338  as  probably  the 
largest  global  source  of  PeCB.  Therefore  it  seems  necessary  to  increase  understanding  of 
PeCB emissions among the chemical industries and improve the E-PRTR database of PeCB 
releases.  

Up to now measures to reduce unintentionally produced POPs largely focused on PCDDs/Fs. 
While the reduction of formation of PCDDs/Fs from thermal sources (primary measure) will 
at the same time have synergistic benefits to reduce PeCB (and other new POPs) secondary 
measures  like  adsorption  technologies  might  have  to  be  adjusted  to  also  address  the  more 
volatile PeCB.  

Action  14:  The  Commission  to  work  with  Member  States  to  examine  how  the 
characterisation of PeCB releases can be improved, and to identify whether BAT/BEP could 
be appropriately updated to further decrease PeCB releases. (ongoing action) 

5.7. 

Identification and environmentally sound management of stockpiles and wastes 

5.7.1.  Obligations and implementation 

Obligations:  Article  5  of  the  Stockholm  Convention:  To  develop  appropriate  strategies  for 
identifying  stockpiles,  products  and  articles  containing,  consisting  of  or  contaminated  with 
chemicals  listed  in  Annexes  A,  B  or  C;  manage  stockpiles  in  a  safe,  efficient  and 
environmentally  sound  manner;  implement  measures  to  reduce  or  eliminate  releases  from 
stockpiles  and  wastes  containing  chemicals  listed  in  Annexes  A,  B  or  C  in  a  manner  that 
protects  human health and the environment; take appropriate measures to  ensure that waste 
products  and  articles  containing  chemicals  listed  in  Annexes  A,  B  or  C  are  handled  in  an 
environmentally friendly manner; dispose of waste products and articles containing chemicals 
listed  in  Annexes  A,  B  or  C  in  a  way  that  destroys  the  POPs  content,  taking  into 
consideration  the  Technical  guidelines  for  the  environmentally  sound  management  of  POP 
wastes developed under the Basel Convention.  

Implementation so far: Directive 2008/98/EC (waste framework directive) sets a number of 
provisions  that ensure wastes including stockpiles are handled in  an  environmentally sound 
manner  (see  Annex  I).  Amongst  others,  this  includes  waste  prevention  promotion, 

337   Furthermore  this  two  facilities  reporting  on  elevated  PeCB  air  emissions  have  not  reported  on  HCB 
emissions.  Since  the  ratio  of  PeCB  to  HCB  in  such  thermal  sources  are  normally  between  0.2  and  2,  the 
HCB  from  these  two  facilities  can  also  be  estimated  in  the  order of  several  10’s  kg/year  and  should  have 
been reported to the E-PRTR.  

338  UNEP  (2010)  “Additional  consideration  of  new  persistent  organic  pollutants:  pentachlorobenzene” 
Stockholm  Convention  document  from  6th  POP  Reviewing  Committee  meeting  (UNEP/POPS/ 
POPRC.6/INF/8) 

140 

 
 
 
                                                           
classification  rules  for  hazardous  waste,  the  obligation  to  collect  waste  and  to  package  and 
label  it  appropriately,  to  elaborate  waste  management  plans,  to  permit  waste  disposal  and 
recovery installations and the prohibition to dispose of waste in an uncontrolled manner. 

Article 5 of the POPs Regulation requires stockpiles to be managed as waste. The holder of 
stockpiles  greater  than  50  kg,  consisting  of  or  containing  any  POP  and  the  use  of  which  is 
permitted shall provide the competent authority with information concerning the nature and 
size thereof. The stockpile shall be managed in a safe,  efficient  and environmentally sound 
manner. Member States must monitor the use and management of notified stockpiles. 

Article  7  of  the  POPs  Regulation  sets  that  producers  and  holders  of  waste  are  obliged  to 
undertake all reasonable efforts to avoid contamination of waste with POP substances. Waste 
consisting of, containing or contaminated by POPs shall be disposed of without undue delay. 
Waste  with  POPs  content  higher  than  the  lower  POP  limits  set  in  the  Regulation  must 
generally  be  disposed  or  recovered  in  such  a  way  that  the  POP  content  is  destroyed  or 
irreversibly transformed. The lower POP limit values are specified in Annex IV to the POPs 
Regulation, which is regularly updated to set limit values for new or revise  limit values for 
existing  POPs.  Those  wastes,  which  are  managed  in  an  environmentally  preferable  way 
instead  of  being  destroyed  or  irreversibly  transformed  have  to  meet  the  upper  POP 
concentration limits set in Annex V to the Regulation339. 

Additionally,  the  POPs  Regulation  exceeds  its  predecessor  Regulation  (EC)  850/2004  as  it 
includes  further  additional requirements  for traceability of wastes containing POPs  (even if 
below the Annexes IV and V critical thresholds). The POPs Regulation places obligations on 
Member States to take the necessary measures to ensure control and traceability of POPs in 
accordance  with  Article  17  of  Directive  2008/98/EC  (on  the  control  of  hazardous  waste 
within  the  waste  framework  directive),  including  records  for  quantities  of  waste,  its  nature 
and origin and the final destination of the waste.  

5.7.2.  Analysis of implementation 

Analysis:  The  existing  legal  framework  basically  ensures  the  environmentally  sound 
management of stockpiles and waste consisting  of contaminated or containing POPs.  Some 
actions should be envisaged as follow-up or complementation of the tasks to be addressed by 
the Basel Convention (see following section). 
With  regard  to  obsolete  pesticides  the  Commission  Study  (BiPRO  2005)340  estimated  that 
there are stocks containing 5,370 t in the Union, mainly in the new Member States joined in 
2004. Information about Romania and Bulgaria is not available.  

In addition the first community implementation plan (2007) estimated 500,000 t of deposited 
HCH  waste  which  at  that  time  were  not  POPs  waste.  With  inclusion  of  alpha-,  beta-  and 
gamma-HCH  these  deposited  wastes  can  largely  be  considered  the  POPs  waste  since  the 

339  The  upper  concentration  limits  are  not  valid  for  permanent  underground  landfilling.  Regulation  (EC) 
172/2007  amending  Regulation  (EC)  850/2004:  “These  limits  exclusively  apply  to  a  landfill  site  for 
hazardous  waste  and  do  not  apply  to  permanent  underground  storage  facilities  for  hazardous  wastes, 
including salt mines.” 

340  BiPRO (2005): Study to facilitate the implementation of certain waste related provisions of the Regulation 
on  Persistent  Organic  Pollutants  (POPs).  ENV.A.2/ETU/2004/0044.  European  Commission,  DG 
Environment, Brussels 2005.  

141 

 
 
 
                                                           
other isomer contribute only a minor share of HCH waste isomers (IHPA 2006 a,b, Vijgen et 
al.  2011).  An  updated  assessment  revealed  that  deposited  HCH  wastes  within  the  Union 
might  amount  up  to  1.8  to  3  million  tonnes  considering  a  lindane  manufacture  volume  of 
300,000 t (Vijgen et al. 2011). 

The  identification  and  management  of  sites  contaminated  by  HCH  waste  represents  a 
challenge within the Union. Seventeen Member States have identified contaminated land as 
an  issue  within  existing  national  implementation  plans,  with  further  action  needed  to  help 
address this issue. While the issue should be primarily dealt with on a Member State level, 
with the costs borne by the "polluter-pays" principles as laid down in the Waste Framework 
Directive,  the  exchange  of  information  at  European  level  would  be  beneficial  to  help 
collaboration and learning in management of such issues. 

Beyond the issue of contaminated land, the Union's funds are eligible for the disposal of the 
stockpiled obsolete pesticides. 

Other  new  POPs  in  products  in  use,  in  the  waste  flow  and  in  disposal  schemes  are  POP-
PBDEs  and  PFOS.  Since  they  are  mostly  included  in  articles  (see  Section  3.2)  but  also  in 
matrices like sewage sludge the assessment of their disposal is more complex. 

Action 15: The Commission to review Annexes IV and V and to propose amendments, as 
appropriate, to ensure environmentally sound management of waste consisting of or 
contaminated by POPs. (continuous action) 

5.7.3.  Disposal and destruction of POP-PBDE containing materials 

The  “Technical  Review  of  the  Implications  of  Recycling  Commercial  Pentabromodiphenyl 
Ether  and  Commercial  Octabromodiphenyl  Ether”  (UNEP/POPs/POPRC.6/2  and  related 
Annexes  UNEP/POPs/POPRC.6/INF/6)  from  the  POP  Reviewing  Committee  (UNEP 
2010a,b)341  emphasized  that  most  recovery  and  destruction  technologies  where  PBDE 
containing materials are treated have not been assessed for their appropriateness (destruction 
efficiency and releases). 

The  Basel  Convention  further  established  guidelines  for  the  destruction  and/or  irreversible 
transformation  of  wastes  containg  brominated  flame  retardants  (including  POP-PBDEs) 
(UNEP/CHW.12/5/Add.6/Rev.1).  

revised  Basel  Convention 

The 
2017 
technical 
(UNEP/CHW.13/6/Add.1/Rev.1) go further,  indicating that possible suitable approaches for 
destruction / irreversible transformation include: 
  Advanced solid waste incineration (ASWI)342; 

guidelines 

published 

in 

341  UNEP (2010) “Technical Review of the Implications of Recycling Commercial Pentabromodiphenyl Ether 
and Commercial Octabromodiphenyl Ether” from 6th POP Reviewing Committee meeting Geneva October 
2010 ((a) UNEP/POPs/POPRC.6/2 and related Annex report (b) UNEP/POPs/POPRC.6/INF/6). 

342  UNEP/CHW.13/6/Add.1/Rev.1 states: There are many types of municipal waste incinerators not all of which 
are  appropriate  to  destroy  POP  PBDEs.  ASWI  are  designed  to  safely  treat  contaminants  present  within 

142 

 
 
 
 
                                                           
 
  Cement  kiln  co-incineration  (noting  that  cement  kilns  operate  at  high  temperatures 

(c.1450oC); 

  Gas phase chemical reduction (GPCR)343; 

  Hazardous waste incineration; and  
  Thermal and metallurgic production of metals (again at high temperatures ≥850oC). 

While the Basel Convention technical guidelines may in part be superceded the findings of 
the Stockholm Convention COP-5 recommendations, the remaining key recommendations 
from COP-5 include:  

  To  generate  and  collect  information  on  releases  of  brominated  diphenyl  ethers  and 
unintentionally  produced  brominated  organic  compounds  such  as  polybrominated 
dibenzodioxins and polybrominated dibenzofurans (PBDD/PBDF) in emissions to air and 
in the solid residues from thermal processes used in treating materials contaminated with 
brominated diphenyl ethers. 

  To  undertake  further  assessment  and  produce  best  available  technique  and  best 
environmental  practice  guidance.  These  tasks  should  be  undertaken  by  the  Stockholm 
Convention’s expert bodies and include consideration of polybrominated diphenyl ethers 
and  PBDD/PBDF  releases  from  smelters  and  other  thermal  recovery  technologies, 
including secondary metal industries, cement kilns and feedstock recycling technologies. 

  To collect information relevant to the establishment of best available techniques and best 
environmental  practices  for  treatment  and  disposal  techniques  for  materials  containing 
brominated diphenyl ethers. 

As described in section 3.2, the largest part of PBDE containing materials has been disposed 
of via landfill. Depending on the quality of the landfills and the leachate controls POPs could 
be released from such deposits and contaminated the environment (Weber et al. 2011)344.  

The COP-5 also discourage the landfilling of PBDE containing waste and recommends in this 
respect:  

  Reducing  releases  of  polybrominated  diphenyl  ethers  from  landfills  by  avoiding  the 
landfilling of waste containing them. Significant reductions can be made by restricting the 
landfill disposal of waste streams with high concentrations of brominated diphenyl ethers. 
A  “proper  management  to  isolate  the  landfill  contents”  permanently  from  the 
environment  cannot  be  achieved.  Therefore,  maximum  concentration  limits  for  (above-
ground) landfills for hazardous waste pursuant to Annex V of the POP Regulation should 
be set. 

municipal waste involving maintaining a minimum temperature of 850oC and residence time of not less than 
2 seconds in the combustion chamber. 

343  UNEP/CHW.13/6/Add.1/Rev.1  states:  GPCR  involves  thermochemical  reduction  of  organic  compounds, 

using temperatures not less than 850 Celsius and low-pressure environments. 

344   Weber, R., Watson, A., Forter, M., Oliaei, F. (2011): Persistent Organic Pollutants and Landfills - A Review 

of Past Experiences and Future Challenges. Waste Management & Research 29 (1) 107-121.  

143 

 
 
 
                                                                                                                                                                                     
  Assessing  further  the  long-term  chemistry  of  polybrominated  diphenyl  ethers  in  landfill 
sites and the fate and risk of polybrominated diphenyl ether release from landfills into the 
environment. 

  Providing guidance for MS on how to focus efforts on products/materials with the highest 
concentrations of POP-PBDEs and PFOS. The guidance could also include techniques for 
identification and separation of materials and products with high POPs concentrations.  

The Basel  Convention technical  guidelines outline that thermal metallurgic production may 
be  a  viable  option  for  destruction.    However,  note  that  whilst  metals  are  recovered  for 
recycling, the polymer to which the PBDE had been added is not recovered. Instead it is used 
for the recovery of energy. The presence, and recovery, of the metal in these cases is due to 
the  mixing  processes,  usually  shredding  or  compacting,  used  in  disassembly  rather  than  to 
any  specific  use  of  PBDE  in  metal  components.  This  process  is  slightly  more  ambiguous 
when  considering  material  and  energy  recovery  in  smelters  used  for  tens  of  thousands  of 
tonnes of printed wire boards (PWB) which contain precious metals. PWBs may also contain 
pentaBDE in the resin, as BFR containing plastic is often added to the process. 

Options  for  energy  recovery  of  plastics  containing  PBDE  (or  just  the  recovery  of  metals 
incidentally mixed with BDE-containing plastics) include: 

a)  Electric arc furnaces for iron scrap recycling (entering e.g. with car scrap),  

b)  Secondary aluminium (entering e.g. with electronic waste parts),  

c)  Antimony recovery from PBDE/BFR plastics containing antimony,  

d)  Energy recovery from PBDE/BFR containing high calorific waste in cement kilns, 

e)  Energy  recovery  and,  in  theory  at  least,  bromine  recovery  from  PBDE/BFR 

containing materials in incinerators. 

As highlighted by the POP Reviewing Committee report these facilities with the exemption 
of BAT incinerator  need further  assessment  for  specific issues  relating to the processing  of 
PBDE  containing  materials.  In  particular,  the  POP  Reviewing  Committee  report  further 
highlights  that  in  these  applications  PBDD/PBDF  and  Polyhalogenated  dibenzo‐p‐dioxins/ 
Polyhalogenated  dibenzofurans  (PXDD/PXDFF)  are  likely  to  be  formed  and  should  be 
considered for the assessment of these facilities (UNEP 2011a,b)345. 

Action 16: The Commission and Member States should as part of the regular review 
process of BREFs evaluate how PBDE containing materials are dealt with within IED 
activities and identify whether BAT/BEP could be included / updated to prevent, and 
where that is not possible to minimise emissions of brominated and brominated-chlorinated 
dioxins. (ongoing action) 

345  In  the  “Technical  Review  of  the  Implications  of  Recycling  Commercial  Pentabromodiphenyl  Ether  and 
Commercial  Octabromodiphenyl  Ether”  for  the  6th  POP  Reviewing  Committee  meeting  Geneva  October 
2010  (UNEP/POPs/POPRC.6/2  (a)  and  UNEP/POPs/POPRC.6/INF/6  (b)),  such  information  has  been 
compiled including information on facilities operated. 

144 

 
 
 
 
                                                           
5.7.4.  Disposal and destruction of PFOS, PFOA and related PFAS-compounds   

Disposal of PFOS and PFOA containing materials 

In  respect  to  end  of  life  management,  recommendations  were  made  at  COP-5  for  PFOS, 
which are likely to be relevant for both PFOS and PFOA:  

  No  landfilling  of  these  wastes  should  be  permitted,  unless  leachate  containing 

PFOS and PFOA is properly treated.  

  Resulting  sludge,  adsorbents  and  wastes  containing  PFOS  and  PFOA  should  be 

destroyed and not deposited. 

In  the  past  longer  chain  PFAS  compounds  (≥C8)  including  PFOS  and  PFOA  have  been 
widely  used  as  water,  oil  and  stain  repellents  in  textile  applications,  including  use  in  soft 
furnishings (e.g. carpets and furniture) with these articles deposited into landfill at end of life. 
Considering  that  PFAS  compounds  generally  have  a  high  solubility  poses  concerns  for 
landfill leachate, particularly in older landfills or landfills with poor capture systems. Weber 
et al (2011) highlighted the potential release to ground and ground water for PFAS chemicals 
such as PFOS from landfills. Therefore there is no justification to deposit PFOS and PFOA 
containing materials considering the burden such practice would bring to future generations.  

Additionally, longer chain PFAS compounds including PFOS and PFOA have been used as 
surfactants within certain types of fire-fighting foams. The Risk Management Evaluation for 
PFOA  (UNEP/POPS/POPRC.13/3)  highlighted  concerns  around  the  use  of  PFOA  within 
such  mixtures  given  that  the  application  of  fire-fighting  foam  is  widespread  and  dispersive 
with high potential for loss to environment. 

The  listing  of  PFOA  within  the  Stockholm  Convention  annexes  at  COP-9  includes 
exemptions  for  fire-fighting  foams  placed  on  the  market  before  4  July  2020;  and  further 
allows the continued use of PFOA-based fire-fighting foams for training purposes, provided 
that emissions to the environment are minimised and effluents collected are safely disposed 
of. 

Kemi (2016)346 comment that, for longer chain PFAS such as PFOS and PFOA, destruction 
via  incineration  would  require  temperatures  at  or  above  1,100oC.  Note  that  Kemi  go  on  to 
state that, for shorter chain compounds, the temperature may need to be even higher with C4 
PFAS compounds requiring 1,450oC. 

Basel 

Convention 

2017 
The 
(UNEP/CHW.13/6/Add.1/Rev.1) 
suitable 
destruction/irreversible transformation of PFOS within wastes, which is likely also relevant to 
other PFAS compounds, including PFOA: 

published 
details 

technical 
provide 

guidelines 

further 

some 

on 

in 

  Cement  kiln  co-incineration  (noting 

temperatures (c.1450oC); 

that  cement  kilns  operate  at  high 

346  Kemi, 2016, ‘Strategy for reducing the use of highly fluorinated substances, PFAS. ISSN 0284-1185. Article 

number: 361 210. 

145 

 
 
 
                                                           
  Gas phase chemical reduction (GPCR); and 

  Hazardous waste incineration. 

PFOS and PFOA containing materials like textiles (such as carpets or other soft furnishings), 
coated paper, and treated articles such as plastics end up to a considerable share in municipal 
waste incinerators (operated at ≤850ºC). Further sewage sludge containing PFAS may end up 
partly  in  sewage  sludge  incinerators  often  operated  at  lower  temperature  compared  to 
municipal  waste  incinerators.  Full  scale  tests  with  assessment  of  destruction  efficiency  and 
degradation  products  have  not  been  published  for  municipal  waste  incinerators  and  sewage 
sludge incinerators.  

Furthermore,  data  on  stockpiles  of  mixtures  and  articles  containing  PFOS  and  PFOA, 
particularly items like fire-fighting foams and treated textiles, is very limited. This poses its 
own  challenges  for  management  of  stockpiles  and  wastes  at  Member  State  level.  It  is 
advisable that Member States share information among themselves and with the Stockholm 
Convention  Secretariat  on  their  experiences  with  PFOS  and  PFOA  destruction  projects 
(including data on material flows and lifecycle) and appropriate destruction technologies.  

PFHxS  has  been  nominated  to  the  Stockholm  Convention  as  a  third  PFAS  substance,  and 
perfluorobutane  sulfonate  (PFBS)  (a  fourth  PFAS)  has  been  identified  as  a  SVHC  under 
REACH. There is  therefore  wider analysis needed more generally on PFAS  substances and 
what  kind  of  controls  may  be  needed.  In  2019  the  European  Commission  commenced  two 
studies to assess the uses and risks of PFAS in fire-fighting foams and textiles respectively, 
with both studies expected to complete before the end of 2020. 

Action  17:  The  Commission  to  develop  an  action  plan  for  PFAS  (including  PFOS, 
PFOA, PFHxS) as part of the wider framework for a chemicals strategy. (ongoing action) 

Action  18:  The  Commission  and  Member  States  to  develop  approaches  to  quantify 
remaining stockpiles of fire-fighting foams that contain C8 PFAS compounds (including 
PFOS  and  PFOA).  This  should  be  used  to  help  support  the  action  plan  identified  in 
Action 17. (new action) 

5.7.5.  Disposal and destruction of POPs Pesticides 

Data reported by Member States has shown that there are still a number of existing stockpiles 
of POP pesticide and POP-containing wastes. A study by the International HCH and Pestides 
Association  (IHPA)  in  2008  suggested  that  for  the  then  ‘EU-25’,  approximately  30,000-
32,000  tonnes  of  obsolete  pesticide  stockpiles  existed347.  Based  on  the  Article  12  reported 

347  http://www.ihpa.info/how-to-be-involved/how-big-is-the-problem/ 

146 

 
 
 
 
 
                                                           
data for both the second synthesis report and draft third synthesis report (spanning the periods 
2007-2009, and 2010-2012 respectively) significant work has been completed to reduce these 
quanities. This has included the export of waste stockpiles across political boundaries within 
Europe  for  destruction  by  incineration.  The  Article  12  reports  for  the  period  2010-2012  do 
however suggest  that significant  levels of stockpiles remain, particularly in the Central  and 
Eastern European Member States with programmes of management and final destruction in 
place  to  handle  remaining  stockpiles.  This  work  is  partly  hindered  by  the  difficulties  in 
identifying  those  waste  stockpiles  that  may  be  contaminated  with  POPs  pesticides.  The 
inclusion  of  a  number  of  POPs  pesticides  in  the  POP  Regulation  since  2009,  particularly 
lindane  and  alpha  and  beta  HCH,  leads  to  the  necessity  of  assessment  and  possibly 
remediation  of  HCH  waste  deposits.  This  recognises  that  for  every  tonne  of  lindane 
manufactured  up  to  nine  tonnes  of  waste  contaminated  with  alpha  and  beta  HCH  was 
generated.  The  identification  of  contaminated  land  sites  and  sites  of  former  manufacture  is 
partly  covered  by  those  Member  States  with  contaminated  land  registries,  with  some  such 
deposits  having  been  cleaned  or  secured  in  the  past.  The  management  of  POPs  pesticide 
stockpiles and any contaminated land issues are primarily for the action at the Member States 
level. 

5.7.6.  Destruction of PCB and PCB containing materials 

Basel 

Convention 

2017 
The 
suitable 
(UNEP/CHW.13/6/Add.1/Rev.1) 
destruction/irreversible transformation of PCBs and PCB containing materials within wastes, 
which include: 

published 
details 

technical 
provide 

guidelines 

further 

some 

for 

in 

  Alkali metal reduction348; 
  Base catalysed decomposition (BCD)349; 
  Catalytic hydrodechlorination (CHD)350; 

  Cement  kiln  co-incineration  (noting 

temperatures (c.1450oC); 

  Gas phase chemical reduction (GPCR); 

  Hazardous waste incineration; 
  Plasma arc351; 

that  cement  kilns  operate  at  high 

348  UNEP/CHW.13/6/Add.1/Rev.1  states:  Alkali  metals  react  with  chlorine  in  halogenated  wastes  to  produce 

chlorine salts. Typically the process operates at standard atmospheric pressure and 60-180oC. 

349  UNEP/CHW.13/6/Add.1/Rev.1 states: The BCD process involves treatment of  wastes in the presence of a 
reagent  mixture  consisting  of  a  hydrogen-donor  oil,  an  alkali  metal  hydroxide  and  a  proprietary  catalyst. 
When  the  mixture  is  heated  to  above  300  °C,  the  reagent  produces  highly  reactive  atomic  hydrogen.  The 
atomic hydrogen reacts with the waste to remove constituents that confer toxicity to the compounds. 

350  UNEP/CHW.13/6/Add.1/Rev.1  states:  CHD  involves  the  treatment  of  wastes  with  hydrogen  gas  and  a 
palladium on carbon (Pd/C) catalyst dispersed in paraffin oil. Hydrogen reacts with chlorine in halogenated 
waste to produce hydrogen chloride (HCl) and non-halogenated waste. In the case of PCBs, biphenyl is the 
main  product.  The  process  operates  at  atmospheric  pressure  and  at  temperatures  of  between  180°C  and 
260°C 

147 

 
 
 
                                                           
  Plasma melting decomposition method (PMD)352; 
  Supercritical water oxidation (SCWO) and subcritical water oxidation353. 

Several Member States are importing PCB and other POPs containing wastes for destruction. 
It has been revealed that the activity of a major importer of PCB waste to Germany (ENVIO) 
led to the contamination of workers and resulted in the contamination of storage sites and the 
area where the PCB transformers were treated. It is advisable that Member States share their 
experience and lessons learned from such cases.  

PCB  destruction  of  open  applications:  As  mentioned  above,  PCBs  have  been  used  in  anti-
corrosion paints (e.g. bridges and other constructions, electric poles, large water pipes) in the 
1950s to the early 1970s. Some of this equipment is now coming to the end of life stage and 
will  need to  be treated. The large metal  parts are normally recycled in  electric arc furnaces 
(EAF) and possibly other secondary metal processing plants. Since the combustion processes 
in  these  batch  type  operations  can  be  considered  incomplete,  most  probably  a  considerable 
share  of  these  PCBs  are  evaporated  and  not  destroyed.  This  is  supported  by  the  relatively 
high emissions of PCB reported from EAF. Furthermore the conditions in such facilities are 
favourable  to  form  PCDF  with  associated  increase  of  toxicity.  Currently  there  is  no 
assessment of how much PCB painted scrap materials are entering the end of life and enter 
secondary  metal  treatment.  Also  no  dedicated  tests  have  been  published  on  releases 
associated  with  such  practice.  However  it  is  known  from  measurements  in  EAF  that 
considerable  PCB  loads  are  emitted  which  only  can  be  explained  by  PCB  input  by  treated 
material and cannot be explained by unintentionally formation of PCB in this processes354.  

Another open application are sealants containing PCB in buildings from the 1960s and 1970s. 
A  share  of  these  buildings  is  renovated  in  the  frame  of  insulation  measures  while  another 
share is torn down.  

It is advisable that Member States share their findings on the PCB contaminated construction 
materials and paints and share their experiences in handling such waste.  

351  UNEP/CHW.13/6/Add.1/Rev.1 states: The waste, as a liquid or gas, is injected directly into the plasma and 
is rapidly (<1 ms) heated up to about 3,100°C and pyrolysed for about 20 ms in the water-cooled reaction 
chamber  (flight  tube).  The  high  temperature  causes  compounds  to  dissociate  into  their  elemental  ions  and 
atoms. 

352  UNEP/CHW.13/6/Add.1/Rev.1  states:  The  plasma  melting  decomposition  method  (PMD)  is  a  thermal 
destruction  method  for  solid  waste  containing  or  contaminated  with  PCBs.  Solid  waste  containing  or 
contaminated  with  PCBs  is  canned  directly  into  containers,  such  as  drums  or  pails,  without  shredding  or 
disassembling. In a plasma furnace, a plasma torch generates high temperature plasma gas (air) so that the 
furnace  temperature  is  maintained  to  melt  the  waste  together  with  the  container  itself.  All  the  organic 
substances, including PCBs, are decomposed into CO2, H2O and HCl under the high temperature conditions 
of the plasma furnace, and inorganic materials, including metals, are oxidised to become molten slag. The 
plasma furnace temperatures exceed 1,400˚C. 

353  UNEP/CHW.13/6/Add.1/Rev.1  states:  SCWO  and  subcritical  water  oxidation  treat  wastes  in  an  enclosed 
system using an oxidant (such as oxygen, hydrogen peroxide, nitrite, nitrate, etc.) in water at temperatures 
and  pressures  above  the  critical  point  of  water  (374°C  and  218  atmospheres)  and  below  subcritical 
conditions (370°C and 262 atmospheres). Under these conditions, organic materials become highly soluble 
in water and are oxidised to produce carbon dioxide, water and inorganic acids or salts. 

354  The  PCB  pattern  from  EAF  have  often  a  congener  finger  print  of  industrial  PCBs  demonstrating  that  the 

main PCB release stem from the input material and are not unintentionally formed.  

148 

 
 
 
                                                                                                                                                                                     
5.8. 

Identification  of  contaminated  sites  (Annex  A,  B  and  C  Chemicals)  and  if 
addressed then remediation in an environmentally sound manner 

Obligations: Article 6.1 (e) of the Stockholm Convention emphasize that parties “Endeavour 
to  develop  appropriate  strategies  for  identifying  sites  contaminated  by  chemicals  listed  in 
Annex  A,  B  or  C;  if  remediation  of  those  sites  is  undertaken  it  shall  be  performed  in  an 
environmentally sound manner”.  

Implementation so far: As regards the identification and remediation of sites contaminated 
by  chemicals  in  Annexes  A,  B  or  C,  the  Commission  has  adopted  in  September  2006  a 
Thematic  Strategy  on  soil  protection.  Since  its  implementation,  numerous  soil  awareness 
raising tools and networks have been  established.  This  includes the European Network for 
Soil  Awareness  (ENSA)  and  setup  of  the  European  Soil  Data  Centre  (ESDAC),  with  soil 
issues increasingly becoming the focus of research projects across Europe.   

The  proposal  for  a  framework  Directive  on  the  protection  of  soil  was  withdrawn  in  May 
2014,  following  sustained  opposition  by  a  minority  of  Member  States.  However,  soil  is  an 
evolving  area  of  policy  focus  at  a  national  level  across  Europe.  Member  States,  such  as 
Sweden,  Germany  and  Denmark,  are  also  developing  legislation  and  technical  approaches 
specific for POPs, such as PFOS. Collaboration is taking place, both between Member States 
and supporting organisations, such as the Common Forum on Contaminated Land in Europe 
(CF)  and  Network  for  Industrially  Co-ordinated  Sustainable  Land  Manangement  in  Europe 
(NICOLE), with the aim of working towards harmonised and efficient working practices and 
management approaches 

The  Water  Framework  Directive  includes  many  POPs  and  hence  imposes  monitoring 
obligations on Member States regarding their presence in ground water and surface waters. In 
this  respect  it  provides  a  mechanism  to  identify  contaminated  sites  associated  with  water 
bodies. 

In 2013, PFOS and its derivatives were included in the Directive on Environmental Quality 
Standards (Directive 2013/39/EU amending Directive 2008/105/EC). The date set for Union-
wide compliance with the EQS is 22 December 2027, with Member States required to submit 
a supplementary monitoring programme and preliminary programme of measures to achieve 
compliance by 22 December 2018.   

The  POPs  Regulation  further  puts  greater  onus  on  contaminated  sites,  specifically 
encouraging  Member  States  to  include  any  data  that  has  been  developed  within  national 
reports and national implementation plans, which are publically made available. 

Analysis:  As  described  above  (3.4),  several  POPs  (e.g.  PCB,  HCH,  PCDD/PCDF,  PAH, 
PFOS) have resulted in a wide range of POPs contaminated sites. Due to the relative mobility 
of  POPs  these  sites  are  a  threat  for  the  wider  environment  and  by  contamination  of  related 
river  systems  and  the  fish  or  flood  plains  and  related  grazing  cattle  also  impact  human 
nutrition.  Furthermore  the  more  water  soluble  POPs  (PFOS  and  HCBD)  also  contaminate 
related ground and surface waters and can impact drinking water.  

For the Union, the historical contamination of soil with HCH and at former manufacture sites 
and  stores  of  HCH  are  probably  one  of  the  main  problems  linked  to  POP  compounds. 
Identification  and  quantification  of  the  extent  of  this  problem  to  develop  appropriate  risk 
management should be regarded as a priority action for the Member States. 

149 

 
 
 
Recent  studies  have  identified  the  widespread  presence  of  PFOS  (and  other  PFAS) 
contamination  within  water  resources  across  Europe.  Investigations  into  the  extent  of  this 
problem and potential sources, including waste water effluents and sewage sludges applied to 
agricultural land, also warrants further analysis. 

A recent study into the current status of lindane contamination across Europe has found that 
many  Member  States  are  yet  to  commence  investigation  and  remediation  of  contaminated 
sites, leading to  ‘hot-spots’ of lindane and HCH waste persisting in  these countries355. This 
delay  is  likely  to  worsen  the  diffuse  contamination  associated  with  such  sites,  as 
contamination is mobilised and migrates through groundwater and surface waters. The need 
for further investigation and clean up of such sites is therefore of high importance. 

Action 19: The Commission and the Member States should develop a strategy for 
identifying sites contaminated by POPs and for their environmentally sound remediation. 
(ongoing action) 

6. 

IMPLEMENTATION OF THE OBLIGATIONS ON SUPPORTING ACTIVITIES 

6.1. 

Information exchange 

Obligation:  Article  9  of  the  Stockholm  Convention:  To  facilitate  or  undertake  information 
exchange relevant to the reduction or elimination of the manufacture, use and release of POPs 
and  alternatives  to  POPs  including  information  relating  to  their  risks  as  well  as  their 
economic and social costs. Each Party to the Convention are required to designate a national 
focal  point for the exchange of information as specified under Article 9 of the Convention. 
This  information  exchange,  either  directly  or  through  the  Secretariat,  can  also  be  used  to 
develop  alternatives  to  POPs.  Where  Parties  exchange  information  on  health  and  safety  of 
humans  and  the  environment  it  must  not  be  treated  as  confidential.  Parties  that  exchange 
other information must protect any confidential information as mutually agreed. 

COP-5 recommendations: 

  To  exchange  information  on  and  experiences  of  successful  environmentally 
sound  handling,  management  and  disposal  of  articles  and  wastes  containing 
brominated diphenyl ethers. 

  Especially developed countries, are encouraged to exchange their experiences and 
success  stories  with  other  countries.  Results  should  be  reported  to  the 
Secretariat/COP which should result in valuable information for developing and 
transition countries and support implementation in these countries. 

Implementation  so  far:  The  Commission  and  the  European  Chemicals  Agency  are 
disseminating  information  on  these  activities  mainly  through  the  websites  hosted  by  the 
Directorate-General  Environment  and  ECHA  respectively.  Additionally,  different  publicly 

355  European  Union  (2016)  “Lindane  (persistent  organic  pollutant)  in  the  EU”,  Report  for  the  European 

Parliament, Policy Department C: Citizen’s Rights and Constitutional Affairs. 

150 

 
 
 
 
                                                           
accessible databases such as Eur-Lex, statistic databases of Eurostat, the E-PRTR, the Union 
pesticide database, OpenFoodTox and databases of Union institutions on specific topics, for 
example  EFSA  has  a  key  role  in  the  dissemination  of  information  related  to  pesticides  and 
food contamination.  

Analysis: Obligations derived from the implementation of the POPs Regulation are changing 
as  new  substances  are  further  added  to  the  annexes  of  the  Regulation.  Note  also  the  POPs 
Regulation, which continues to build upon the existing approaches, but with significant new 
elements  altering  the  roles  of  key  bodies  (such  as  ECHA),  and  with  greater  onus  on  waste 
(including  traceability  of  materials),  and  monitoring  data  (reported  to  IPCheM).  The 
stakeholders  and  key  regulatory  bodies  concerned  by  these  changes  need  to  be  proactively 
informed and supported in  the implementation  of the corresponding obligations. This  could 
inter alia take place via workshops, projects in cooperation with associations and federations 
(industry and NGOs) as well as common dissemination strategies such as websites and paper 
documentation. 

The vast majority of Member States have information exchange mechanisms in place, and a 
number  of  these  provide  details  of  these  mechanisms  in  their  NIPs.  In  many  cases, 
informatione  exchange  is  facilitated  through  the  Member  States’  National  Competent 
Authority.  

Action 20: Commission and Member States should facilitate the exchange of information 
and experiences on elimination of PCBs (e.g. through a workshop). This should be used to 
further explore the progress made on the elimination of PCBs within di-electric equipment, 
obstacles  faced,  and  what  learning  lessons  could  be  implemented  by  Member  States. 
(ongoing action) 

Action 21: Commission and Member States to  ensure that all players (including industry) 
are  fully  informed  about  the  obligations  under  the  Stockholm  Convention.  (continuous 
action) 

Action  22:  Commission  and  Member  States  to  exchange  their  experiences  and  success 
stories with other countries. (continuous action) 

Action 23: Commission to facilitate the identification of  both chemical and non-chemical  
options  which  can  act  as  alternatives  to  POPs  and  to  disseminate  their  risk  assessment 
reports more widely. (continuous action) 

151 

 
 
 
 
 
 
6.2. 

Public information, awareness and education 

Obligations:  Article  10  of  the  Stockholm  Convention:  Promote  and  facilitate  awareness  of 
POPs,  among  policy  and  decision  makers,  and,  along  with  industry  and  professional  users, 
provide and facilitate up-to-date information to the public as well as develop education and 
training  programmes.  To  give  consideration  to  the  development  of  mechanisms,  including 
pollutant release and transfer registers, for the collection and dissemination of information on 
the release and disposal of chemicals listed in Annexes A, B and C. To consult with national 
stakeholders when developing and implementing the national implementation plan. 

Implementation  so  far:  Access  to  environmental  information  and  consultation  with 
stakeholders  are  an  integral  part  of  the  Union  environment  policy.  In  general,  a  lot  of 
emphasis  is  put  on  dissemination  of  information  to  citizens,  industry  and  other  interested 
parties  on  the  Union’s  environment  policy  and  activities.  The  main  tool  for  public 
information  is  the  Europa-website,  a  specific  website  dedicated  to  POPs  and  different 
European  databases  (see  section  2.6).  Additionally,  under  the  POPs  Regulation,  the  ECHA 
website now hosts pages on POPs, including the new selection process for candidate POPs. 

Alongside the Commission and ECHA, EFSA have a key role in the assessment of pesticide 
residues  in  food  and  communication  to  the  general  public  (via  databases  such  as 
OpenFoodTox).  Additionally,  the  Union  makes  use  of  rapid  alert  systems  (RASFF  and 
RAPEX)  to  share  information  on  POPs  in  food  and  feed  and  consumer  products  between 
Member State authorities as means of early warning and intervention. 

More recent ECHA have also begun work on the SCIP database for SVHCs (which includes 
POPs) in articles and compex objects, which is intended to help better inform those working 
in the waste sector of where POPs (among other SVHC) may be found. 

As consultations with stakeholders are an integral part of the Union's environment policy in 
order  to  provide  opportunities  for  input  from  representatives  of  authorities,  civil  society  or 
individual  citizens,  this  present  Union  Implementation  Plan  has  been  subjected  to  an  open 
consultation (see Preface).  

Analysis: As the Member States’ NIPs highlight a range of specific issues that can vary from 
State  to  State,  the  role  of  disseminating  information  to  the  public,  awareness  raising  and 
education  on  POPs  best  remain  at  the  domain  of  the  Member  States.  The  Commission  has 
concentrated  on  information  on  Union  legislation  and  other  activities  with  a  broader  pan-
European scope.  

As  most  Member  States  have  developed  their  NIPs  and  report  information  under  the 
requirements of Article 12, it is now possible to evaluate the need for and the added value of 
such concerted action in the field of POPs. 

The vast majority of Member States have adopted measures to raise public awareness, some 
as  part  of  wider  strategies  or  frameworks  for  wider  community  action.  For  example,  most 
countires provide the public with information, accessible through the websites of government 
departments,  ministries or agencies, and many  report the provision of leaflets,  brochures or 
newsletters to provide the public with information.  

However, the feedback from the public consultation on the draft UIP in the autumn of 2019 
highlighted a concern from both the general public and experts regarding communication on 
POPs.  The  respondents  highlighted  a  lack  of  visibility  of  what  activities  were  ongoing  at 

152 

 
 
 
Member State level, and further a lack of communication on POPs and what the key concerns 
are.  In  particular  the  general  public  stakeholder  group  highlighted  concerns  over  obsolete 
pesticide stockpiles and risks related to POPs in food. 

Based  on  the  above  paragraphs  it  is  possible  that,  while  Member  State  authroities  are 
developing and making such information publically available, the public themselves may be 
unaware that it exists or of where to find such information. This further prompts the need for 
further  review  of  the  methodology  of  communication  and  what  actions  may  be  needed  as 
coordinated information campaigns at pan-European level. 

Action  24:  The  Commission  and  Member  States  to  evaluate  the  need  for  and  the  added 
value of a concerted action - coordinated information campaigns at European Union level - 
in  the  field  of  POPs  taking  into  consideration  the  obligation  of  Member  States  to 
disseminate  environmental  information  on  POPs  pursuant  to  Directive  2003/4/EC53. 
(continuous action) 

6.3. 

Research, development and monitoring 

Obligations: Article 11 of the Stockholm Convention: To encourage research, development, 
and monitoring of POPs on their sources, releases and transport to the environment, presence, 
levels,  trends  and  effects  in  humans  and  the  environment,  socio-economic  and  cultural 
impacts,  release  reduction  and/or  elimination  and  harmonised  methodologies  for  making 
inventories  and  analytical  techniques  for  measuring  releases.  In  taking  this  action,  Parties 
should  also  support  and  further  develop  international  programmes  aimed  at  research,  data 
collection  and  monitoring,  support  efforts  to  strengthen  national  scientific  and  technical 
research  capabilities,  take  into  account  the  concerns  and  needs  of  developing  countries  to 
improve their capability  to  participate, undertake research towards  alleviating the  effects  of 
POPs  and  make  the  results  of  this  available  to  the  public  and  encourage  and/or  undertake 
cooperation with regard to storage and maintenance of this generated information. 

Implementation so far: Research and development are essential for the support of policies 
such as inter alia consumer protection or the protection of the environment. The Framework 
Programmes (FP) are the main instrument for funding research and development in Europe. 
POP related research was funded in FP 5 (1998-2002), FP 6 (2002-2006), FP 7 (2007-2013) 
and Horizon 2020 (2014-2020). Details on projects  funded under  FP5 are  given in  the first 
Union Implementation Plan prepared in 2007.  The Horizon 2020 programme has an overall 
budget of about €80 billion euros (see section 2.5). Details on projects funded under Horizon 
2020 are given in the section 7.  

The  Joint  Research  Centre  –  the  Commission's  scientific  body  –  has  performed  several 
monitoring  activities  of  POP  substances  in  the  environment  andexposure  assessments  to 
POPs  and  contributed  to  the  development  of  a  Toolkit  for  the  indentification  and 
quantification  of  releases  of  dioxins,  furans  and  other  unintentionally  produced  POPs 
particularly by determination of emission factors for non-standard emission sources.  

The  European  Food  Safety  Authority  (EFSA)  has  a  key  role  to  play  in  the  monitoring  of 
different pesticide residues in food for the European Union. 

153 

 
 
 
 
Furthermore, the Joint Research Centre has been instrumental in the creation of the IPCheM 
platform  for  monitoring  data,  which  acts  as  a  central  repository  for  such  information.  The 
recast  of  the  POPs  Regulation  specifically  identifies  IPCheM  as  the  preferred  repository  of 
monitoring  data  going  forward  and  includes  an  Article  under  the  Regulation  for  Member 
States and ECHA to agree common formats and software for the reporting of monitoring data 
into IPCheM. 

Under  the  Water  Framework  Directive    and  Environmental  Quality  Standard  Directive, 
Member States are obliged to monitor substances placed on the priority list (many of which 
have POP characteristics), if they are discharged into the river basin or sub-basin. In addition, 
Member  States  have  to  monitor  also  other  pollutants  if  they  are  discharged  in  significant 
quantities in the river basin or sub-basin.  

Analysis: As regards the research and development, support will mainly come from Horizon 
2020  Societal  Challenge  1  “Health,  Demographic  Change  and  Wellbeing”,  Societal 
Challenge  2  “Food  Security,  Sustainable  Agriculture  and  Forestry,  Marine,  Maritime  and 
Inland  Water  Research  and  the  Bioeconomy”  and  Societal  Challenge  5  “Climate  Action, 
Environment, Resource Efficiency and Raw Materials” since some POP  substances are still 
used due to lack of alternatives. 

There  are  a  range  of  inconsistencies  in  E-PRTR  data  e.g.  for  PeCB,  HCB  and  HCBD  (see 
section  3.3.1).  A  research  into  characterisation  of  sources  of  these  substances  might  be 
desirable to improve the situation. 

As  stated  in  section  5.6,  prevention  of  the  unintentional  formation  of  POPs  through  the 
development  of  processes  and  technologies  that  avoid  their  formation  should  mainly  be 
addressed  in  the  area  of  industrial  manufacture  but  also  cover  domestic  sources  such  as 
diffuse  incineration  sources.  There  is  still  need  for  additional  research  and  technological 
development. 

Though  the  coordination  of  research  efforts  already  marks  a  good  way  towards  the 
minimisation of effort duplication (see section 2.5.2), this action should be continued in the 
future. Especially the aspect of coordination and exchange at international level should be set 
more  in  focus.  Ensuring  the  communication  between  policy  makers  and  scientific  research 
communities is  a key aspect  to  maintaining a healthy  flow of  new data  needed to  underpin 
logical policy making in the field of science for POPs. This includes identification of priority 
data  needs  in  advance  to  help  guide  scientific  research  communities  to  where  existing  data 
gaps  exist,  and  likewise  to  ensure  publicly  funded  research  does  not  duplicate  academic 
research efforts.  In this respect exchanges between research and development aid should be 
supported and further developed.  

As  regards  the  monitoring,  despite  the  fact  that  Member  States'  authorities,  research 
organisations and Union bodies are making significant efforts to monitor numerous chemicals 
in  various  matrices  (water,  air,  biota,  soil,  human  milk,  etc.)  as  a  consequence  of  Union 
legislation, national and international initiatives and scientific curiosity, there is a knowledge 
gap  on  the  chemical  burden.  This  occurs  because  the  chemical  data  generated  by  the 
monitoring activities are not being collected, managed and assessed in a coherent manner and 
accessible manner. To address this gap, an information platform for chemical monitoring data 
should be established at the European scale which would ensure a coordinated and integrated 
approach to collecting, storing, accessing and assessing of data. 

154 

 
 
 
Action 25: The Commission should ensure that the current EU Framework Programme for 
Research and Innovation Horizon 2020 (and Horizon Europe, which covers 2021-2027) will 
encourage research and innovation activities for the above identified challenges (alternatives 
(both  chemical  and  non-chemical),  characterisation  of  sources,  review  of  industrial 
processes  to  avoid  unintentional  formation,  data  management,  testing,  and  health  impacts) 
and promote  a coordinated approach between Member States  as  well  as  with  international 
counterparts  inter  alia  long-term  health  impacts  of  exposure  to  POPs  at  environmentally 
relevant concentrations or development of affordable alternatives to POP substances still in 
use. (continuous action) 

Action 26: The Commission and the Member States should ensure better co-ordination and 
communication  between  scientific  research  communities  and  relevant  national,  Union  and 
international bodies to, amongst others, communicate priority data needs for management of 
POPs issues. (ongoing action) 

7. 

IMPLEMENTATION OF OTHER COMMITMENTS 

7.1. 

Technical assistance 

Obligations: Article 12 of the Stockholm Convention: To cooperate, in response to requests 
to provide timely and appropriate technical assistance to developing Parties and Parties with 
economies  in  transition,  especially  least  developed  countries  and  small  island  developing 
states, to assist them, to develop and strengthen their capacity to implement their obligations 
under  the  Stockholm  Convention.  Article  12.3  places  an  obligation  on  developed  country 
Parties to provide such assistance and also mandates the establishment of regional and sub-
regional centres for capacity-building and transfer of technology. 

Furthermore  the  POPs  Regulation  gives  ECHA  a  more  central  role  in  the  development  of 
technical information. This includes technical assistance upon request of the Commission and 
others.  EFSA  also  provides  technical  assistance  through  its  role  in  the  risk  assessment  of 
POPs in food. 

COP-5 recommendations: 

  To  encourage  developed  countries  to  promote  the  transfer  to  developing  countries  of 

screening and separation techniques. 

  The transfer of knowledge and technology, including capacity-building to identify PFOS 
in articles and applications and monitor PFOS in the environment, should be promoted to 
support full participation in global efforts to reduce PFOS risks. 

  To  encourage  developed  countries  to  promote  the  transfer  to  developing  countries  of 

screening and separation techniques (for PBDE containing materials). 

Implementation  so  far:  Union  technical  assistance  responds  to  requests  and  is  financed 
through  its  aid  programmes  which  are  described  in  sections  2.4.2  and  2.4.3.  The  main 
instrument  for  assessing  developing  countries  and  partner  organisations  was  until  2013  the 

155 

 
 
 
 
Thematic  Programme  for  Environment  and  Sustainable  Management  of  Natural  Resources 
(ENRTP) within the EuropeAid.  

ENRTP  has  been  replaced  by  the  thematic  programme  on  Global  Public  Goods  and 
Challenges  (GPGC),  which  covers  the  period  2014-2020.  The  initial  programming  for  the 
period  2014-2017  of  the  GPGC  Environment  and  Climate  envelope  included  substantial 
support of the Special Programme on Chemicals and Waste, which aims at strenghthening the 
instutional  capacity  in  chemicals  management  of  developing  countries  and  countries  with 
economies in transition.  

The  2018  Action  Programme  for  Environment  and  Climate  Change  under  the  GPGC  has 
been published356, specifying a Union contribution of €74 million.  

In  addition,  financial  support  was  provided  to  the  Secretariat  of  the  Basel,  Rotterdam  and 
Stockholm  Conventions  through  the  GPGC.  Those  resources  were  used  to  implement  the 
programme  of  work  as  agreed  by  the  Conference  of  the  Parties,  which  also  included  the 
provision of technical assistance. 

Analysis:.  As  of  2014,  the  GPGC  replaced  the  ENRTP  and  addressed  chemicals 
management,  including  the  implementation  of  the  Stockholm  Convention,  under  the 
Environment and Climate envelope and in the envelope sub-delegated to DG ENV. The latter 
was used to support projects carried out by the Secretariat of the BRS Conventions that inter 
alia provided targeted technical assistance developing countries and countries with economies 
in transition. 

inclusive  green  and  circular  economy  and 

Under Component 3 of the GPGC 2018-2020 thematic programme, ‘Transformation towards 
an 
into  account  environmental 
sustainability,  climate  change  and  disaster  risk  reduction’,  one  of  the  expected  results  is 
“enabling policy and institutional frameworks supporting the transition  to  a green  economy 
and  combating  pollution,  including  through  the  sound  management  of  chemicals  and  waste 
are developed in partner countries”.  

taking 

Action  27:  The  European  Union  should  develop  mechanisms  for  better  coordination 
between the bilateral  aid programmes of  the Commission  and those of the Member States 
with regards to POPs. (continuous action) 

7.2. 

Financial Assistance 

Obligations: Article 13: All parties undertake to provide financial support and incentives in 
respect of those national activities that are intended to achieve the objective of the Stockholm 
Convention  in  accordance  with  their  national  plans,  priorities  and  programmes.  Developed 
country  Parties  are  required  to  provide  new  and  additional  financial  resources  through  the 
financial  mechanism  to  enable  developing  country  Parties  and  Parties  with  economies  in 
transition  to  meet  the  agreed  full  incremental  costs  of  implementing  measures  which  fulfil 
their obligations under the Stockholm Convention. 

356 https://www.gtai.de/resource/blob/41602/9d46a5e0cc98b52a24ea3ed6a6d1a781/pro201810185000-data.pdf 

156 

 
 
 
 
                                                           
Implementation so far: Basically, it is for the Member States rather than the Union to fund 
domestic implementation in accordance with Article 13.1. Nevertheless, the Union provides 
significant amount of funding within the Union, in neighbouring countries and in developing 
countries,  by  different  funding  instruments  in  order  to  contribute  to  the  implementation, 
updating  and  development  of  Union  (environmental)  policy  (see  section  2.4.1),  including 
through relevant international instruments. 

Regarding sound management of chemicals and waste, including the Stockholm Convention, 
the  European  Commission  provides  funding  to  developing  and  neighbouring  countries 
directly and also contributes to multilateral and international programmes, such as the Special 
Programme to support institutional strengthening at the national level for implementation of 
the  Basel,  Rotterdam  and  Stockholm  Conventions,  the  Minamata  Convention  and  the 
Strategic  Approach  to  International  Chemicals  Management  (SAICM)  and  the  Voluntary 
Trust Funds of the Basel, Rotterdam and Stockholm Conventions (see section 2.4.3).  

Analysis:  The  Union  provides  funding  through  numerous  programmes  and  instruments. 
However, there is no fund exclusively for the implementation of the Stockholm Convention. 
Indeed a specific fund to support partner countries to implement the Convention would not be 
in line with agreed international best practice in aid effectiveness since developing countries 
are in the best position to set their own priorities. Nevertheless the Union does recognise that 
for  structural  reasons,  notably  the  absence  of  future  generations  in  decision-making, 
environment tends to get neglected when countries decide on the use of aid allocated to them.  

It  is  for  this  reason  that  the  Union  has  earmarked  since  2007  a  part  of  its  development 
cooperation  budget  for  environment  through  thematic  programmes:  the  Environment  and 
Natural  Rersources  Thematic  Programme  in  2007-2013,  and  the  current  2014-2020  Multi-
annual  Financial  Framework  the  Global  Public  Goods  and  Challenges  (GPGC)  Thematic 
Programme  includes  environment  as  one  of  its  priority  areas.  The  overall  budget  for  the 
Environment  and  Climate  Change  programme  under  the  GPGC  is  €2  billion  for  the  2014-
2020 period. The Commission has looked for opportunites to increase requests for aid related 
to sound chemicals and wastes management, not least by being the largest donor to the Quick 
Start  Programme of the  Strategic Approach to  International  Chemicals  Management, which 
works to raise political awareness and action on sound chemicals management in developing 
countries.  

The  Union  has  played  a  leading  role  in  the  definition  and  negotiation  of  the  Integrated 
approach  to  financing  sound  management  of  chemicals  and  waste  adopted  through  UNEA 
resolution  1/5  on  chemicals  and  waste.  That  resolution  launches  the  Special  Programme  to 
support  institutional  strengthening  at  the  national  level  for  implementation  of  the  Basel, 
Rotterdam  and  Stockholm  Conventions,  the  Minamata  Convention  and  the  Strategic 
Approach  to  International  Chemicals  Management  (SAICM)  that  will  complement  the 
support  for  the  Stockholm  Convention  provided  through  the  Global  Environment  Facility 
(GEF).  

Furthermore,  the  Union  and  individual  Member  States  also  provide  input  to  the  Stockholm 
Convention Trust Fund. The total mandatory contribution of Member States and the Union in 
2019  represented  42%  of  the  total  mandatory  financial  contribution  of  Parties  to  the 
Convention (total contributions in 2019 were $4 million USD with contributions for Member 
States  and  the  Union  of  $1.7  million  USD).  In  addition,  important  amounts  are  regularly 
contributed by the Union and its Member States to the voluntary trust fund. 

157 

 
 
To increase awareness and demonstrate the support provided by Union financial instruments 
that are relevant for POP-related action, specific information could be provided on the POP 
specific Commission website. 

Action 28: The Commission should consider the scope for funding POPs related assistance 
under  the  new  Neighbourhood,  Development  and  International  Cooperation  Instrument 
(NDICI) when drawing up the Annual Action Plans (AAP) and in the cooperation with non-
EU countries. (ongoing action) 

7.3. 

Reporting 

Obligations:  Article  15  to  the  Stockholm  Convention:  To  report  to  the  Conference  of  the 
Parties  on  the  measures  the  Party  has  taken  to  implement  the  provisions  of  the  Stockholm 
Convention  and  on  the  effectiveness  of  such  measures  in  meeting  the  objectives  of  the 
Stockholm  Convention.  Reporting  shall  include  data  on  the  total  quantity  of  manufacture, 
import  and  export  of the  chemicals  listed  in  Annexes  A  and  B  and  a  list  of  countries  from 
which it has imported and exported substances.  

Implementation so far: The POPs Regulation includes provisions under Article 9 to develop 
national implementation plans covering the major issues relating Annexes A, B and C of the 
Stockholm Convention (as well as Annexes I, II and III of the regulation which largely mirror 
the  Convention)  which  are  reported  to  Secretariat  of  the  Convention,  the  European 
Commission and ECHA. Similarly, under Article 9 of the POPs Regulation, the Commission 
supported by ECHA are to maintain a Union Implementation Plan (this document) which is 
reported to the Convention. 

Formerly  under  Regulation  (EC)  850/2004  Article  12  stipulated  that  Member  States  were 
required to gather, collate and report information annually to the Commission on quantities of 
Annex A and B substances placed on the market (including enforcement activities), as well as 
triannually on Annex C emission inventories. The reporting under Article 12 has been further 
used to develop triannual synthesis reports on POPs at the Union level. To date four triennial 
synthesis reports (2004-2006, 2007-2009, 2010-2012 and 2013-2015357) have been published 
based  on  data  submitted  by  the  Member  States  under  Article  12  of  Regulation  (EC)  No 
850/2004, further supplemented by other existing data to provide a state of the union set of 
information on progress towards the objectives of the Convention. These reports are available 
website: 
on 
http://ec.europa.eu/environment/chemicals/international_conventions/index_en.htm  

Commission 

European 

the 

Under the POPs Regulation, Article 13 states that the information covering Annexes A and B 
substances,  quantities  placed  on  the  market,  enforcement,  and  release  inventories  will  be 
managed at national level and made publicly available on a periodic basis. All raw data will 
be provided to ECHA, with formats for reporting of such data to be agreed between ECHA 
and the Member State Competent Authorities pursuant to Article 17. 

357  

Draft report currently being prepared by the Commission  

158 

 
 
 
 
                                                           
Analysis: Reporting from Member States to the Commission is a prerequisite for the Union 
to be able to identify further measures for the implementation of the Stockholm Convention 
and  also  for  submitting  adequate  reports  to  the  Stockholm  Convention.  However,  several 
Member States have not yet met their reporting obligations and the Commission may launch 
infringement procedures in this respect to address the issue.   

Following-up on national reporting under the POPs Regulation and on the still to be delivered 
NIPs  under  the  Stockholm  Convention,  the  Commission  should  assess  which  specific 
exemptions and acceptable purposes are still needed respectively fix a timeline until when a 
complete  phase-out  is  possible.  There  are  hints  that  for  example  the  main  remaining 
acceptable purposes for PFOS are the use in metal plating industry and in aviation fluids (cf. 
section  3.2.7).  For  all  other  registered  applications  PFOS  seems  to  have  been  phased-out. 
However, this would have to be verified with data and information reported by the Member 
States. 

Action 29: The Commission should consider launching infringement procedures against the 
Member States in case of non-compliance with reporting obligations. (ongoing action) 

Action 30: Commission and Member States to regularly verify the need for the use of any 
specific exemption for Annex A and Annex B substances. (ongoing action) 

7.4. 

Effectiveness evaluation 

Obligations:  Article  16  of  the  Stockholm  Convention:  Conference  of  the  Parties  to 
periodically evaluate the effectiveness of the Stockholm Convention, starting four years after 
entry  into  force.  The  evaluation  will  be  conducted  on  the  basis  of  available  scientific, 
environmental, technical and economic information.  

Implementation  so  far:  Article  10  of  the  POPs  Regulation  stipulates  that  the  Commission 
and  the  Member  States  shall  establish,  in  close  cooperation,  appropriate  programmes  and 
mechanisms,  consistent  with  the  state  of  the  art,  for  the  regular  provision  of  comparable 
monitoring data on the presence of dioxins, furans and PCBs as identified in Annex III in the 
environment. 

Harmonised monitoring  at  Union-level  exists for emissions of all by-product  POPs  through 
the  E-PRTR.  There  is  also  harmonised  monitoring  in  the  area  of  feed  and  food  where  it  is 
recommended that a number of defined food and feed samples are analysed yearly. Common 
methods for sampling and analysis ensure comparability of the results that will be compiled 
by the Commission in a database with the aim of having a clear picture of the time trends in 
background presence of these substances in feed and food. 

Under  the  Water  Framework  Directive,  Member  States  are  obliged  to  monitor  substances 
placed on the priority list (many of which have POP characteristics), if they are discharged 
into  the  river  basin  or  sub-basin.  In  addition,  Member  States  have  to  monitor  also  other 
pollutants if they are discharged in significant quantities in the river basin or sub-basin.  

159 

 
 
 
 
 
In order to  check the feasibility of a Union  coordinated approach to  Human Biomonitoring 
(HBM),  a  research  project  on  the  development  of  a  coherent  approach  to  human 
biomonitoring  in  Europe  was  granted  leading  to  the  concept  of  biomonitoring  as  a  policy 
making tool.  

HBM  is  a  viable  tool  to  evaluate  the  effectiveness  of  policies  because  it  allows  good 
assessment  of  temporal  trends  in  total  human  exposure  to  environmental  pollutants.  In 
December 2009, the Union project for a Consortium to Perform Human Biomonitoring on a 
European Scale (COPHES) was created as a pan European effort involving scientists from all 
28  Member  States.  A  feasibility  study  called  DEMOCOPHES  was  launched  in  September 
2010  and  concluded  in  November  2012  with  finance  from  Life  plus.  The  study  measured 
biomarkers for mercury, cadmium, phthalates, bisphenol A and environmental tobacco smoke 
in human hair and urine from around 120 mother-child pairs in the 17 participating countries, 
in total almost 4000 samples, across 17 Member States. This is the first time that information 
has been derived on the distribution of chemicals in 17 Member States which are comparable 
between the countries and with international data.  
More recently, the HBM4EU358 project (launched in 2017 under Horizon2020)  – involving 
all  the  Member  States,  the  EEA,  ECHA,  EFSA  and  the  Commission  –  aims  to  address 
concerns around a priority set of substances (many of which are POPs) to help guide policy 
making. The HBM4EU project is a five year study due to be completed at the end of 2021. 

Analysis:  The  Union  and  the  Member  States  will  continue  to  play  an  active  role  in  the 
international  work  regarding  the  effectiveness  evaluation  and  will  continue  to  generate 
exposure  data.  An  information  platform  for  chemical  monitoring  data  has  been  established 
(IPCheM), to improve accessibility of the data and coherence in collection, management and 
assessment  (see  section  5.3).  The  platform  will  improve  effectiveness  evaluation  of  the 
implementation  of  the  POPs  Regulation  and  of  the  Stockholm  Convention  in  the  Union  by 
facilitating access to the monitoring data and by improving comparability of the data.  

7.5. 

Addition of Future Chemicals to the Stockholm Convention 

Obligations:  The  Stockholm  Convention  does  not  lay  down  any  particular  obligation 
concerning addition of chemicals to it but allows any Party to propose an amendment of the 
Stockholm Convention by listing of further substances in it. 

Implementation  so  far:  The  Commission  has  initiated  the  inclusion  of  several  of  the  new 
POPs and supported the proposals submitted by other parties. The Commission has an active 
role in supporting the position of the Member States through review of nominated substances 
at Union level prior to submission to the Stockholm Convention secretariat.   

Analysis:  The  Union  and  the  Member  States  have  put  throughout  the  negotiations  on  the 
Stockholm  Convention  much  emphasis  on  the  widening  of  the  initial  list  of  12  POP 
substances to additional POP substances warranting global action. The proper functioning of 
the POPRC is of crucial importance in this regard. It is evident that the Commission and the 
Member States need to actively participate in and support the POPRC in its work in order to 
ensure timely and thorough evaluation of the submitted proposals. 

358  

https://www.hbm4eu.eu/about-hbm4eu/ 

160 

 
 
 
                                                           
Through the implementation of the Union legislation,  in  particular the REACH Regulation, 
the Plant Protection Products Regulation, the Biocides Regulation and the Water Framework 
Directive, the Union is in the possession of a huge amount of valuable chemicals data. This 
data  should  be  used  to  identify  and  assess  any  further  candidates  for  the  inclusion  into  the 
Stockholm Convention. 

The  recast  of  the  POPs  Regulation  in  2019  more  closely  aligns  the  POPs  Regulation  with 
REACH, including a more central role for ECHA to support in the identification of candidate 
POPs.  This  includes  alignment  to  REACH  processes  and  use  of  eight-week  public 
consultation  rounds  allowing  input  from  the  Member  States,  industry,  NGOs  and  other 
interested parties in the nomination of POPs to the Stockholm Convention. 

Action 31: Commission and Member States to continue work on identification of potential 
POP  substances  warranting  international  action.  Commission  to  initiate  formal  proposals 
by  the  Union,  when  appropriate.  Commission  and  the  Member  States  to  increase  and 
strengthen Union wide and international cooperation and information exchange concerning 
identification  of  potential  POP  substances  and  on  concentrations  of  POP-candidate 
substances  especially  in  remote  regions  and  on  the  extent  of  trans-boundary  dispersion. 
(continuous action) 

161 

 
 
 
 
8. 

EU RESEARCH PROJECTS SINCE 2007 WITH REFERENCES TO POP ISSUES  

Table 13   Research Projects with references to POPs funded under Horizon 2020  

No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

1 

NADiRA, Nurturing Africa 
Digital Revolution for 
Agriculture, EU 
Contribution €1.9M 

H2020-EU.2.1.6.3. 
Start date: 2017-11-01 
End date: 2020-04-30 

2 

RECOPHARMA, Removal 
and Recovery of 
Pharmaceutical Persistent 
Pollutants from Wastewater 
by Selective Reagentless 
Process, EU Contribution 
€900,000 

H2020-EU.1.3.3. 
Start date: 2018-01-01 
End date: 2021-12-31 

NADiRA aims to incorporate Copernicus, other Earth Observation products and in-situ IoT devices 
into mAgriTM, an existing value chain orchestration platform connecting, in smallholder contract 
farming, producers with banks, insurers, input providers and agro-industries to control risks and 
improve the productivity, security, and welfare of tens of thousands of African farmers. 
By industrializing EO products , NADiRA reduces mAgriTM’s operating costs, while increasing the 
timeliness, granularity and reach of its following services: (1) Agricultural investment risk mapping, 
to reduce finance institutions cash-out and increase availability of input credit to smallholders, (2) 
More robust, affordable agricultural insurance contracts, to reduce persistent climate risk, (3) 
Improved smallholder tactical management of crop nutrient deficiencies and post-harvest losses to 
increase productivity, harvest quality and income. 
NADiRA demonstrates, on a large market scale, the economic and commercial viability of the 
combination of EO, IoT and mobile technology and its leverage on the new business model 
implemented by MANOBI, Swiss Re, credit and insurance institutions and agro-industries to 
improve smallholder productivity. Four pilots run in parallel in Senegal and Nigeria targets (i) 
different crop types and production systems (irrigated rice, rainfed peanuts, maize and sorghum) in 
(ii) 10 crop campaigns (4 irrigated, 3 rainfed) and (iii) various production environments and 
management practices. This demonstration sustains the development of a business plan with financial 
objectives and an associated roadmap to capture 30% of the addressable market in Africa.  
The outreach actions benefits from the communications channels of the NADiRA partners, active in 
Africa (MANOBI, Swiss Re, ICRISAT, local banks and farmers associations), in Europe 
(SPACEBEL, University of Liège, Viveris and EUGENIUS association) and Asia (ICRISAT). A 
Copernicus Relay will be established in West Africa. 
Pharmaceutical drugs, characterized by their environmental persistence (e.g. cytostatic drugs [CDs]) 
have been detected in water bodies (drinking water, groundwater, surface water, and effluent 
wastewater) at concentrations up to μg/L level. Actual methods for the removal and degradation of 
CDs, including electrochemical, photochemical, and biological methods have been developed. 
However, these methods are expensive and sometimes inefficient for CDs complete removal from 
the treated water. Including the exploitation of previous results from EU funded projects, the goal of 
project RECOPHARMA is to design, develop, validate and demonstrate a novel process by 

162 

https://cordis.europa.eu/
project/rcn/212436_en.
html  

https://cordis.europa.eu/
project/rcn/212474_en.
html   

 
 
 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

sequential integration the potentials offered by Molecular Imprinted Polymers (MIPs), Reagentless 
Thermosorption (RTS),  Nanocomposites Functional Materials, Advanced Oxidation Processes, for 
an effective treatment aiming the recovery of target recalcitrant CDs and degradation of 
corresponding transformation products or metabolites, working in a continuous operation mode. The 
suggested approach offers versatile, fast, highly efficient, and low-cost treatment for wastewaters. 

RECOPHARMA brings together academic research centres and the private sector, with a long-term 
goal of designing and developing advanced water treatment technologies in the interest of the society 
and integrate them for demonstration following a circular economy approach. Through the scheduled 
secondments, the involved staff will perform the required R&I to demonstrate the technical and 
economic feasibility of the developed process, including the technical formation of specialists as a 
fundamental activity to project success. The secondments will also enhance the exchange of 
knowledge, best practices, know-how, innovations, experience, mutual cooperation and culture of 
work between different organizations, regions and countries through the partners’ well-established 
reputation as transfer hubs. 
MULTIEPIGEN seeks to solve does ancestral exposure to various stressors transmit to offspring via 
epigenetic mechanisms. Thus far animal models have indicated that exposure to certain stressors can 
lead to phenotypic changes not only in the predisposed individuals, but also in the future generations, 
such that individuals can acquire phenotypes caused by exposures of their ancestors. Such effects do 
not involve new DNA mutations, but are transmitted to offspring via epigenetic mechanisms such as 
the transfer of non-coding RNA molecules in the semen. In humans, intergenerational transmission 
has been examined extremely little because a priori designed population-based studies across several 
generations are lacking. To close this gap MULTIEPIGEN will expand the well-characterized 
Cardiovascular Risk in Young Finns Study (YFS) to the parents and offspring of the original YFS 
participants. During the ERC funding period, we will perform field studies involving N~9000 
individuals across 3 generations and test 3 key ancestral exposures with very high plausibility 
causing intergenerational effects on obesity-related phenotypes, cognitive function and psychological 
well-being. The studied exposures are 1) tobacco smoke, 2) persistent organic pollutants, and 3) 
accumulation of psychosocial adversities. We will collect serum, blood and semen samples for 
epigenetic marker analysis to provide understanding of the mechanisms of intergenerational 
transmission in humans. Specifically, we will seek proof for the hypothesis that paternal stressors can 
lead to phenotypic changes in the offspring via non-coding RNA molecules in the semen. 
Multigenerational epidemiologic data showing robust links between ancestral exposures and 
offspring phenotypes that operate with biologically plausible epigenetic mechanism would provide a 
conceptual change in the developmental biology in humans and have substantial ramifications on 
public health. 
EU Member States are currently working towards the realisation of environmental goals specified in 

163 

https://cordis.europa.eu/
project/rcn/212173_en.
html  

https://cordis.europa.eu/

3 

MULTIEPIGEN, Ancestral 
environmental exposures 
and offspring health – a 
multigenerational 
epidemiologic cohort study 
across 3 generations, EU 
Contribution €2.5M 

H2020-EU.1.1. 
Start date: 2017-11-01 
End date: 2022-10-31 

4 

FreshwaterMPs, The 

H2020-EU.1.3.2. 

 
 
  
No. 

Acronym, Project Title, 
EU contribution 
environmental fate and 
effects of microplastics in 
freshwater ecosystems, EU 
Contribution €1.6M 

Programme, 
Duration time 
Start date: 2015-04-01 
End date: 2017-03-31 

5 

MAT4TREAT, Enhancing 
water quality by developing 
novel materials for organic 
pollutant removal in tertiary 
water treatments, EU 
Contribution €630,000 

H2020-EU.1.3.3. 
Start date: 2015-01-01 
End date: 2018-12-31 

Short description and main objectives  

the Water Framework Directive (WFD), which aims to protect both human and ecosystem health. 
Microplastic particles (MPs) are emerging pollutants of increasing concern and are formed primarily 
when plastic waste degrades in the environment. The impacts of MPs on freshwater biota are not 
known, however, they may present a potentially persistent and ecotoxicological pollution problem. 
Accordingly, the goal of this project is to assess the environmental risk of MPs in freshwater 
habitats. To achieve this, a detailed investigation of MP environmental persistence will be carried 
out. This will provide environmental fate summaries for different polymer classes and enable the 
modelling of their degradation processes. This will be combined with laboratory studies to assess 
relevant sub-lethal endpoints such as reproduction, fitness, inflammation, and oxidative stress. As 
MPs are known to accumulate co-occurring organic pollutants, the toxicity of virgin MPs will be 
compared to MPs conditioned with relevant freshwater pollutants. This work will build towards a 
sophisticated state-of-the-art mesocosm study that will evaluate both MP fate and impacts in model 
ecosystems. The establishment of a novel framework for the environmental risk assessment of MPs 
will inform our ability to achieve conservation objectives taking into account MPs as emerging 
pollutants. The merit of this is that protection goals may be better accommodated in policy and 
management through the generation of so far unavailable data on MP persistence and environmental 
toxicity. Taken together, the project will generate so far unavailable data sets to assess for the first 
time the environmental impacts of freshwater MPs. Thus, the outcomes will highly relevant for 
academia, politics, stakeholders and society. 
The MAT4TREAT project consists in a consortium of 8 Universities, 5 of them  European (UNITO, 
AAU, POLITO, UPV and UOI), and the other three from outside the EU (UNLP, McGill, SU), as 
well as two non academic institutions (ACEA and LQT). These groups are committed to work in the 
development of novel materials to be used in innovative integrated water tertiary treatments (to 
remove, for instance, Emerging Pollutants). This ambitious goal will be achieved by world leading 
research groups in the following fields: (i) graphene-based and other carbon-related materials, (ii) 
polymeric materials, (iii) oxidic ceramic materials, and (iv) hybrid inorganic-polymeric materials.        
The new materials will be used as adsorbents, as photocatalysts and as active layers for the 
fabrication of membranes, and thus tested for the pollutant removal from model aqueous solutions as 
well as from real water samples. Furthermore, approaches combining different materials and 
pollutant abatement technologies will be proposed and a demonstrative lab-bench apparatus for the 
integrated treatment of wastewaters will be built-up with the support of two European non academic 
institutions, which will directly participate to the project. Chemometric approach will be followed to 
optimize both materials manufacture and experimental conditions for analytical purposes. Life Cycle 
Assessment of new materials and proposed technologies will be performed in order to evaluate their 
economic and environmental sustainability. 

More information 

project/rcn/195924_en.
html  

https://cordis.europa.eu/
project/rcn/194348_en.
html  

6 

ECO-INK, ECO-
INNOVATIVE WATER-

H2020-EU.2.1.5. 
Start date: 2017-01-01 

The ECO-INK project proposes a green, innovative and comprehensive solution to the great 
limitations of the digital printing technology within the ceramics decoration sector. The main 

https://cordis.europa.eu/
project/rcn/207085_en.

164 

 
 
No. 

Acronym, Project Title, 
EU contribution 
BASED INKS FOR THE 
CERAMIC SECTORS, EU 
Contribution €50,000 

Programme, 
Duration time 
End date: 2017-05-31 

7 

NanoScreen, Disruptive 
portable device for pre-
screening of Persistent 
Organic Pollutants –POPs- 
in food products and water, 
EU Contribution €1.2M 

H2020-EU.3.2.4. 
Start date: 2017-06-01 
End date: 2019-05-01 

More information 

html  

https://cordis.europa.eu/
project/rcn/210851_en.
html  

Short description and main objectives  

objectives of the project are to explore new market opportunities and boost the competitiveness of 
METCO srl business, while addressing EU/global challenges on Climate Change and following the 
indications of the “Stockholm Convention on persistent organic pollutants” & the ""Stimulating 
technologies for sustainable development: an environmental technologies action plan for the 
European Union"": ECO-INK will promote environmentally-friendly activities as well as guarantee 
the safe elimination of substances, harmful to human health and the environment, as well as the 
reductions in their manufacture and use, through the substitution of current solvent based ink with 
water based inks (WSI) for ceramic tile manufacture. for METCO itself, with the introduction of 
WSI in their manufacture chain, there will be a saving of about 240-360t of solvent each year, 
corresponding to save about 0,5-1M€ if the solvent substituted is naphtha and approximately 728–
1,093t of CO2 emissions per year. Considering the global market the expected figure is very 
impressive, since it’ll be possible to save 620,000t CO2 emission per year. METCO srl foresees a 2-
years investment (about 1.8M€) to complete the optimization of WSI and to setup the whole 
technological package. METCO then envisages a full manufacture and commercialization of 450-
1.350-2.700t ECOINK ecoformulations 
per Years 3-4-5. This is expected to result in a +487% ROI by 2019 and in a METCO srl growth with 
+45 human resources by 2021. 
Persistent organic pollutants (POPs) are organic compounds produced by human action resistant to 
environmental degradation and whose bioaccumulative capacity and toxicity can cause harmful 
health effects e.g. cancer. Hence, they have become global threats for human and environment. The 
most extended analytic methods used nowadays for detecting POPs are gas chromatography and/or 
mass spectroscopy to separate and identify them. These methods are expensive -€1,000/sample-, 
time-consuming -24h-, require a laborious sample preparation and a well-equipped laboratory. 
Consequently, there is a great demand to increase the number of water and food quality tests if 
available for a lower price and shorter time. 

SAFTRA PHOTONICS will bring to market NanoScreen - a portable nano-optical sensing chip for 
pre-screening purpose that detects food or water contamination by POPs. We will offer a rapid 
method (10 minutes) to detect the most important POPs (ppb) present in food products and water, 
carrying out an in-situ analysis for less than 100€ per sample. By putting NanoScreen solution into 
the the European, Japanese and USA market, in 2023 we expect to sale 55,000 chips with revenue of 
€4,800,000 (27% Y/Y growth) and ROI 3.25. This ensures sustainability of 37 new full time job 
positions at company. 

The project resubmission (13.61) reflects couple of great achievements of 2016: FS has elaborated in 
detail the NanoScreen business plan, the company has signed two investment agreements, three 
business partners and two distribution partners. Moreover, we have identified another two major 

165 

 
 
 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

replication opportunities of future joint ventures that can form a new business-industrial ecosystem 
for online nano-screening. The vision is to reach a unique one-box-system tailored for specific 
applications, e.g. security, agriculture and sport. 

The Phase 2 funding will help us to close the gap from design validation to industrial manufacture 
and significantly shorten the market entry period. 
The ever-increasing environmental input of toxic chemicals is rapidly deteriorating the health of our 
ecosystems and, above all, jeopardizing human health. Overcoming the challenge of water pollution 
requires novel water treatment technologies that are sustainable, robust and energy efficient. 
ELECTRON4WATER proposes a pioneering, chemical-free water purification technology: a three-
dimensional (3D) nanoelectrochemical system equipped with low-cost reduced graphene oxide 
(RGO)-based electrodes. Existing research on graphene-based electrodes has been focused on 
supercapacitor applications and synthesis of defect-free, superconductive graphene. I will, on the 
contrary, use the defective structure of RGO to induce the manufacture of reactive oxygen species 
and enhance electrocatalytic degradation of pollutants. I will investigate for the first time the 
electrolysis reactions at 3D electrochemically polarized RGO-coated material, which offers high 
catalytic activity and high surface area available for electrolysis. This breakthrough approach in 
electrochemical reactor design is expected to greatly enhance the current efficiency and achieve 
complete removal of persistent contaminants and pathogens from water without using any chemicals, 
just by applying the current. Also, high capacitance of RGO-based material can enable further energy 
savings and allow using intermittent energy sources such as photovoltaic panels. These features 
make 3D nanoelectrochemical systems particularly interesting for distributed, small-scale 
applications. This project will aim at: i) designing the optimum RGO-based material for specific 
treatment goals, ii) mechanistic understanding of (electro)catalysis and (electro)sorption of persistent 
pollutants at RGO and electrochemically polarized RGO, iii) understanding the role of inorganic and 
organic matrix and recognizing potential process limitations, and iv) developing tailored, adaptable 
solutions for the treatment of contaminated water. 
From SAFTRA PHOTONICS we will bring to the market: NanoScreen, a portable sensing device 
that will detect in-situ contamination in any food matrix and water with most deleterious Persistent 
Organic Pollutants -POPs- at a cost-effective price and in a reduced time-span, with a simpler 
procedure when comparing to current methodologies, allowing multiplexing. 
Persistent Organic Pollutants are transported across international boundaries far from their sources, 
even to regions where they have never been used or produced. 
These POP pose a threat to the environment and to human health all over the globe. A total of 152 
countries have participated in the Stockholm Convention, the international event in which strategies 
for controlling POPs. In the EU there is a strong legal framework that must be followed in order to 
reduce POPs burden, which includes analysis and detection. Article 11 of the resulting document of 

166 

https://cordis.europa.eu/
project/rcn/206054_en.
html  

https://cordis.europa.eu/
project/rcn/199497_en.
html  

8 

9 

ELECTRON4WATER, 
Three-dimensional 
nanoelectrochemical 
systems based on low-cost 
reduced graphene oxide: the 
next generation of water 
treatment systems, EU 
Contribution €1.5M 

H2020-EU.1.1.  
Start date: 2017-05-01 
End date: 2022-04-30 

NANOSCREEN, 
Disruptive portable device 
for pre-screening of 
Persistent Organic 
Pollutants –POPs- in food 
products and water, EU 
Contribution €50,000 

H2020-EU.2.3.1. 
Start date: 2015-12-01 
End date: 2016-04-30 

 
 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

the Stockholm Convention encourages the generation of new technologies for POPs monitoring and 
elimination. 
The most extended analytic methods used nowadays for detecting POPs are gas chromatography 
and/or mass spectroscopy (GC-MS) to separate and identify them. These methods are expensive -
€1,000/sample-, time-consuming -24h-, require a laborious sample preparation and a well-equipped 
laboratory. 
The functioning of the Nanoscreen device is a revolutionary technique that makes much easier and 
functional the way of detecting and analysing POPs in food and water. We have mainly three 
advantages that make NanoScreen a fruitful innovation: Easy process for sample collection that can 
be done by non-specialists; Quick method, in which only 10 minutes are needed; Competitive price 
per analysis of 100€. 
Nanoscreen presents a ROI in 2022 of 2.45 and it is expected to reach its payback in July 2020 (two 
years and one month after the beginning of its commercialization). 

167 

 
 
 
 
 
 
Table 14   Research Projects with references to POPs funded under FP7  

No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

1 

2 

3 

Impact of global change on 
the remobilization and 
Bioaccumulation of organic 
Pollutants in Polar aquatic 
food webs 

FP7-People 
Start date: 2015-05-01 
End date: 2018-04-30 

Optimising the use of 
lichens as biomonitors of 
atmospheric PAHs 

FP7-People 
Start date: 2014-04-01 
End date: 2016-03-31 

Impact of polyaromatic 
hydrocarbons on arbuscular 
mycorrhizal fungi and 
biochemical and molecular 
mechanisms involved in 

FP7-People 
Start date: 2014-04-01 
End date: 2016-03-31 

Global warming is affecting the Polar Areas, with some of the most rapid changes associated with 
warming in polar terrestrial, freshwater and marine ecosystems, associated with changes in sea ice 
dynamics, nutrient loadings and perturbation of sinks of persistent organic pollutants (POPs). In 
addition to the direct influence that increasing temperatures will have on the polar ecosystems, 
perturbations of the carbon cycle driven by a warming climate will affect the biogeochemical cycle 
of POPs, and thus their transport, fate and effects along the polar aquatic food webs.  
However, these effects are still far from being well understood. Biogeochemical cycles of POPs and 
C in aquatic ecosystems may be linked in various ways such as for example water-air exchange and 
soil-air exchange processes or metabolic processes such as respiration although there are still 
important gaps in the literature.  
In terms of the understanding of the impacts, the BioPollAr project aims to understand how POPs are 
coupled with the C-cycle in polar aquatic ecosystems and how climate change will affect the fate and 
bioavailability of POPs and their effects through the food webs. 
Polycyclic aromatic hydrocarbons (PAHs) have received increased attention in recent decades in air 
pollution studies due to their carcinogenicity and mutagenicity. Directive 2004/107/EC recommends 
the use of other monitoring methods (aside from passive samplers), notably biomonitors (living 
organisms), to complement data and to assess spatial deposition of PAHs.  
Biomonitoring methods have been developed during the last decades for this purpose. Within 
biomonitors, lichens are the most used organisms to monitor atmospheric deposition of several air 
pollutants. However, one of the main drawbacks of using lichens to monitor atmospheric PAHs has 
been reported as the impossibility to translate PAH values in lichens into the atmospheric 
equivalents, in order to use this information for regulatory purposes.  
It is also missing an understanding of the mechanisms through which lichens intercept and 
accumulate PAHs, which means it is difficult to assess a critical level for PAHs in lichens – lowest 
level that will affect lichen structures and functions, which will be valuable when identifying areas 
with high ecological/environmental risk. POPLAIR aims to fulfill these gaps of knowledge and to 
study the feasibility of introducing lichens in the market as a well-known tool to be applied in 
environmental monitoring assessments 
Polyaromatic hydrocarbons (PAHs) are frequently associated to polluted soils. PAHs are harmful for 
human health (carcinogenic and/or mutagenic) and can disrupt the ecosystem functioning. To clean-
up the PAHs-polluted soils, phytoremediation assisted by arbuscular mycorrhizal fungi (AMF) 
represent an innovative approach, cost-effective and environmental friendly.  
The present project aims to determine the impact of PAHs on AMF having different life history 

http://cordis.europa.eu/
project/rcn/186554_en.
html 

http://cordis.europa.eu/
project/rcn/187821_en.
html 

http://cordis.europa.eu/
project/rcn/187767_en.
html 

168 

 
 
 
No. 

Acronym, Project Title, 
EU contribution 
plant protection and 
pollutant dissipation 

Programme, 
Duration time 

4 

5 

6 

Pollutants accumulation 
and effects in relation to 
trophic niches of the high-
arctic ivory gull 

FP7-People 
Start date: 2014-05-01 
End date: 2016-04-30 

Next-Generation 
Electrochemical 
Technology for the 
Treatment of Hospital 
Wastewater: 
Electrogenerated Sulfate 
Radicals for Complete 
Destruction of Persistent 
Pollutants 

FP7-People 
Start date: 2014-11-17 
End date: 2016-11-16 

Sustainable use of Biochar 
in Mediterranean 
Agriculture 

FP7-People 
Start date: 2013-03-01 
End date: 2016-02-29 

Short description and main objectives  

More information 

strategies, i.e. adapted to grow either under stable (K-strategists) or disturbed (r-strategists) 
environments. We postulate that PAHs may differently affect AMF r/K-strategists which in turn may 
(1) protect the plant from PAHs toxicity in a different way and (2) differently participate in the 
dissipation of PAHs. 
Seabirds living in the Arctic coastal sytems, such as the ivory gull (Pagophila eburnea), are 
particularly vulnerable to contaminants from long range transport because they bioaccumulate toxic 
compounds throughout their life and are top predators displaying high levels of contamination 
(through biomagnification).  
This project aims at (1) comparing temporal variations of persistent organic pollutants (POPs) and 
trace element levels (TEs) in the ivory gull population of Svalbard to evaluate the effect of climate 
change on contaminant loads in this species, (2) assess spatial variations of POPs and TEs along 
gulls circumpolar distribution (Svalbard, Canada, Greenland and Russia), (3) investigating the 
relation between contaminant concentrations and trophic habits of gulls, and (4) evaluating the effect 
of contaminants on wild gull metabolism at the cellular and organism levels.  
Hospital wastewater effluents have been identified as the primary sources of DNA-damaging 
compounds, and are considered as the major source of antibiotic resistance in the environment. There 
is no established technology for the treatment of hospital wastewater. Biological treatment is 
incapable of degrading more persistent contaminants, e.g., organohalogens, cytostatics, and 
antibacterial agents.  
This project proposes a next-generation technology for the treatment of contaminated hospital 
wastewater, based on the electrochemical generation of sulfate and hydroxyl radicals. Highly 
oxidizing sulfate and hydroxyl radicals are formed by applying current to an anode at atmospheric 
temperature and pressure. Excellent preliminary results achieved show an outstanding capacity of the 
electrochemically generated sulfate radicals in removing persistent organic contaminants at up to 80 
times higher rates than with hydroxyl radicals alone. Sulfate radicals react mainly through electron 
transfer and hence are less subject to scavenging by the background matrix, which allows their 
accumulation in the solution and drastically enhances the oxidation efficiency. 
The application of biochar (charcoal or biomass-derived black carbon (BC)) to soil is proposed as a 
novel approach to establish a significant long-term sink for atmospheric carbon dioxide in terrestrial 
ecosystems. Additionally the fertilizing properties of biochar were re-discovered and are nowadays 
divulged and encouraged within the concept of using biochars produced under controlled combustion 
conditions as soil amendment. On the other hand, Polycyclic Aromatic Hydrocarbons (PAHs), 
persistent organic pollutants formed during biochar production due to incomplete combustion 
process (pyrolysis step), will enter the environment when the biochar is applied as soil conditioner. 
However, an accurate assessment of the impact of biochar addition on the release of PAHs is still 
missing and will constitute the other main objective of this proposal. 

http://cordis.europa.eu/
project/rcn/187663_en.
html 

http://cordis.europa.eu/
project/rcn/185866_en.
html 

http://cordis.europa.eu/
project/rcn/108342_en.
html 

169 

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

7 

Global contaminated land 
management 

FP7-People 
Start date: 2011-12-01 
End date: 2015-11-30 

Complex hazardous contamination of soil and water are obstructing sustainable re-development of 
previously industrialized urban land in Europe as well as in China.  

The main objective of this program is to strengthen the quality of research by developing 
international collaborations and advance the decision making on complex issues in contaminated 
land management Specifically, in this collaboration UNIVE will involve its expertise on multicriteria 
decision analysis, decision support systems and risk assessment. UmU will bring understanding of 
mobilization processes for persistent organic and inorganic pollutants in soil and ground water. 
CRAES will offer its expertise on ecology, risk assessment and management of contaminated site 
and BNU on environment risk assessment and characteristic of soil pollution. 

http://cordis.europa.eu/
project/rcn/101419_en.
html 

8 

9 

ACROPOLIS, Aggregate 
and cumulative risk of 
pesticides: an on-line 
integrated strategy, EU 
Contribution €3M 

FP7-KBBE 
Start date: 2010-06-01 
End date: 2013-05-31 

ARCRISK, Arctic Health 
Risks: Impacts on health in 
the Arctic and Europe 
owing to climate-induced 
changes in contaminant 
cycling, EU Contribution 
€3.5M 

FP7-ENVIRONMENT 
Start date: 2009-06-01 
End date: 2013-12-31 

This will be done by the organization of several exchange activities in the fields of contaminated soil 
characterization, environmental risk assessment and decision making processes. These exchange 
activities aim to increase quality and mutual benefit of the transfer of knowledge between the 
involved researchers from EU and China. 
Improvement of cumulative exposure assessment and cumulative hazard assessment methodology; 
Development of new models for aggregated exposure assessment addressing different routes of 
exposure; 
Setting up of new toxicological testing for identifying possible synergistic effects and development 
of a strategy for refinement of cumulative assessment groups; 
Integration of cumulative and aggregate risk models integrated in a web-based tool, including 
accessible data for all stakeholders; 
Improvement of the understanding of cumulative risk assessment methodology of different 
stakeholders. 
Exploration and use of selected climate change and chemical usage scenarios, the changing routes 
and mechanisms by which persistent chemical pollutants and air pollutants are delivered to the Arctic 
and the possible role of global climate change. 
Study of the deposition and accumulation of air pollutants and persistent chemical pollutants on 
snow/ice and on ice-free surfaces, their fate and transfer to aquatic food chains with melt-water 
runoff. 
Exploration of the transfer of pollutants from the abiotic Arctic environment into the base of food 
chains and to higher trophic level organisms (e.g., fish, marine mammals, reindeer) consumed by 
humans. 
Comparison of the role of climate change on the transport, fate and food web transfer of pollutants in 
the Arctic to the situation in relevant selected areas with exposed local populations in the EU; 
Identify and quantify the current main health outcomes in relation to exposure to ‘legacy’ 

170 

http://acropolis-eu.com/  

http://www.arcrisk.eu/  

 
 
 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

contaminants in selected populations in the Arctic and exposed local populations in the EU. 

10 

11 

12 

13 

BASIS, PAH Anaerobic 
Biodegradation Assessment 
by Stable Isotope 
Technologies, EU 
Contribution €170,000 

BAYEX, Atmospheric 
Exchange of Persistent 
Chemicals in Bothnian Bay, 
Northern Baltic Sea, EU 
Contribution €240,000 

BRIDGE, Bridging mecha-
nisms into risk assessment: 
An integrated European 
research network targeting 
contaminants in milk, EU 
Contribution €3.48M 

BROWSE, Exposure 
models to assess the risks to 
operators, workers, 
residents and bystanders 
from exposure to plant 
protection products (PPPs), 
EU Contribution €2M 

FP7-PEOPLE 
Start date: 2011-05-01 
End date: 2013-04-30 

The main goals of this proposed project are to assess in situ biodegradation of PAHs under anaerobic 
environments in marine and fresh water systems, to describe microbial activities and to identify 
microbial key players 

FP7-PEOPLE 
Start date: 2011-04-15  
End date: 2013-04-14 

Atmospheric deposition and air-sea exchange of persistent chemicals in Bothnian Bay are 
investigated with goals of understanding current atmospheric loadings and how future loadings will 
respond to changes in ice cover and air concentrations 

FP7-KBBE 
Duration: 36 months 

Risk assessment data for exposure to contaminants in milk, particularly during the vulnerable stages 
of foetal and infant development; characterisation of the endocrine disruptive effects of chemical and 
microbiological toxins in milk and produce novel tools to improve consumer safety and prevent 
disease. 

FP7-ENVIRONMENT 
Start date: 2011-01-01 
End date: 2013-12-31 

Review, improve and extend the models currently used in the risk assessment of plant protection 
products (PPPs) to evaluate the exposure of operators, workers, residents and bystanders. 
Use the new and improved exposure models to contribute to the implementation of Regulation (EC) 
1107/2009 on authorisation of PPPs, replacing Directive 91/414/EC and the implementation of the 
Thematic Strategy on the Sustainable Use of Pesticides. 
Involve all relevant stakeholders and end-users and take full account of relevant gender issues in 
developing the exposure models and policy tools. 

14 

CADASTER, Case studies 

FP7-ENVIRONMENT  The project provides a practical guidance to integrated risk assessment by carrying out a full hazard 

171 

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b7057
87f:3ad5:58e8706f&RC
N=98660 
- no project website  
http://eu.project.umu.se/
projectweb/4a851ad5f0
ec5/Baltic%20region.ht
ml 
http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b701ef
ac:1e64:56f2a86f&RC
N=96896 
- no project website  

http://www.ncp-
bio.net/media/document
s/successstories/bridge.
pdf  
- no project website  

http://cordis.europa.eu/f
etch?CALLER=FP7_E
NV_PROJ_EN&ACTI
ON=D&DOC=56&CA
T=PROJ&QUERY=01
29fe7c8e02:8b2f:41abc
192&RCN=97105  
- no project website  
http://www.cadaster.eu/  

 
 
No. 

Acronym, Project Title, 
EU contribution 
on the development and 
application of in silico 
techniques for 
environmental hazard and 
risk assessment, EU 
Contribution €2.69M 

15 

CARBPOL, Investigating 
the role of the carbon cycle 
on the environmental fate 
of semivolatile organic 
pollutants, EU Contribution 
€170,000 

Programme, 
Duration time 
Start date: 2009-01-01 
End date: 2012-12-31 

Short description and main objectives  

More information 

and risk assessment for chemicals belonging to four compound classes. 
Collection of data and models; development and validation of QSAR models; integration of QSARs 
within hazard and risk assessment; outreach via development of website, newsletters/workshop(s) 
and standalone tools for dissemination of project results. 

FP7-PEOPLE 
Start date: 2008-04-01 
End date: 2010-03-31 

Semivolatile organic compounds (SOCs) are a heterogeneous class of chemicals including many 
ubiquitous toxic pollutants such as the notorious persistent organic pollutants (POPs). The main 
hypothesis behind the present project is that the C cycle controls the global environmental cycling of 
SOCs. 

16 

CLEAR, Climate Change, 
Environmental 
Contaminants and 
Reproductive Health, EU 
Contribution €2.37M 

FP7-ENVIRONMENT 
Start date: 2009-05-01 
End date: 2013-04-30 

18 

CONFFIDENCE, 
Contaminants in food and 
feed: inexpensive detection 
for control of exposure, EU 
Contribution €5.8M 

FP7-KBBE 
Start date: 2008-05-01 
End date: 2012-04-30 

Identification and description of mechanisms by which climate change affect the exposure of Arctic 
and other human populations to contaminants through change in chemical use and emissions, 
delivery to the ecosystems as well as processing within the physical environment and human food 
chain; 
Expansion of the existing knowledge database on human contaminant exposure in the Arctic and 
selected European countries by measurements of biopersistent and non-persistent compounds in 
serum samples, namely polybrominated diphenylethers, perfluorinated surfactants, phthalates and 
metals; 
Increase knowledge on links between parental blood levels of environmental contaminants and 
reproductive health outcomes in terms of functional and biological measures of fertility and child 
development; 
Investigation of mechanisms related to effects of contaminants on reproductive health; 
Integration of data on relative climate induced changes in contaminant mobility and distribution, 
external and internal exposure of humans and links between contaminant exposure and health 
surveys into a risk assessment and risk evaluation. 
Provide long-term solutions to the monitoring of POPs, perfluorinated compounds, pesticides, 
veterinary pharmaceuticals (coccidiostats, antibiotics), heavy metals and biotoxins (alkaloids, marine 
toxins, mycotoxins) in high-risk products such as fish and fish feed; 
Assurance of quality and safety in the European food supply from farm to fork by the development 
of new simplified detection methods for chemical contaminants with effective features; development 
of  new  detection  tools  for  key  and  emerging  risks  as  recognised  by  the  European  Food  Safety 
Agency (EFSA); improvement of consumer exposure assessments to achieve a better understanding 
of contaminant levels in food and feed; contribution to the validation of risk-benefit and predictive 

172 

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b706c0
2a:6e26:55bf2629&RC
N=87358 
- no project website 

http://www.inuendo.dk/
clear/  

http://www.conffidence
.eu/  

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

19 

20 

21 

CONTAMED, 
Contaminant mixtures and 
human reproductive health 
– novel strategies for health 
impact and risk assessment 
of endocrine disrupters, EU 
Contribution €3.5M 

FP7-ENVIRONMENT 
Start date: 2008-05-01 
End date: 2011-12-31 

COPHES, Consortium to 
Perform Human 
Biomonitoring on a 
European Scale, EU 
Contribution €4M 

FP7-ENVIRONMENT 
Start date: 2009-12-01 
End date: 2012-11-30 

CYTOTHREAT, Fate and 
effects of cytostatic 
pharmaceuticals in the 
environment and 
identification of biomarkers 
for an improved risk 
assessment on 
environmental exposure, 
EU Contribution €2.58M 

FP7-ENVIRONMENT 
Start date: 2011-01-01 
End date: 2014-12-31 

hazard  behaviour  models  in  accordance  with  the  strategic  agenda  of  the  European  Technology 
Platform (ETP) Food for Life; extensive dissemination and training of new detection methods to all 
relevant  stakeholders,  including  industrial  and  governmental  end-users  and  students,  to  advance 
technology exploitation. 
The project will explore the hypothesis that combined exposure to endocrine disrupting chemicals 
(EDC) in foetal life may lead to adverse delayed impacts on human reproductive health. 
Preparation of the ground for epidemiological studies able to capture cumulative EDC exposure by 
developing and evaluating biomarkers for total effective internal EDC load; 
Substantiation of observations from human studies in extended developmental toxicity rat studies by 
investigating the possible role of mixtures of oestrogens, anti-androgens and other classes of EDC in 
producing long-lasting delayed adverse reproductive effects at environmentally relevant levels; 
Bringing together human epidemiology and predictive toxicological risk assessment by comparing 
internal EDC exposures in humans with those resulting from controlled exposures producing clear 
effects in laboratory animal experiments; 
Searching for previously unrecognised EDCs in human tissues. 
The project will develop a coherent approach to human biomonitoring (HBM) in Europe, using 
existing and planned HBM projects and programmes of work and capabilities. It will investigate 
what is needed to advance and improve comparability of HBM data across Europe. 
Definition of priorities for biomonitoring of chemical exposures and effects in the general European 
population; improvement of comparability of HBM data in Europe by developing strategies to 
harmonise recruitment, sampling, quality control, data exchange, data analysis, and reporting 
strategies; guarantee of high scientific standards and use of up-to-date scientific technology and 
approaches in human biomarker development and integration of HBM into health impact assessment; 
provision of a communication strategy and common ethical standards, development of a programme 
for capacity building and of a concept for sustainable organisation and structure of an EU HBM 
network. 

Assess the risks of pharmaceuticals released in the environment, focusing on cytostatic drugs 
because of genotoxic properties which may cause unexpected long term effects. Their release in the 
environment may lead to systemic ecological effects and increased cancer incidence, reduced fertility 
and malformations in the offspring in humans. 
Special emphasis is put on the combined effects of environmentally relevant mixtures; combination 
of state-of-the art analytical chemistry, in vivo and in vitro systems, and ‘OMICS’ technologies is 
applied. Comparisons with the hazardous effects of other groups of pharmaceuticals will provide 
knowledge on the magnitude of the problem; it will generate new knowledge on environmental and 
health risks of cytostatics and provide objective arguments for recommendations and regulations.  

http://www.contamed.e
u/  

http://www.eu-
hbm.info/  

http://www.nib.si/eng/i
ndex.php/aktualno/proje
ct/287-national-
institute-of-biology-nib-
is-coordinating-7-
framework-programme-
project-which-has-33-
million-eur-budget-
.html 
- no project website yet 

173 

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

22 

23 

DEER, Developmental 
Effects of Environment on 
Reproduction, EU 
Contribution €3.5M 

FP7-ENVIRONMENT 
Start date: 2008-05-01 
End date: 2012-04-30 

This research project will improve the understanding of the role of environmental factors in the 
development and establishment of human reproductive health. 
Investigation of connections between normal and abnormal foetal and perinatal reproductive 
development and subsequent maturation of reproductive function at puberty and in adulthood; study 
of systemic gene-environment interactions underlying reproductive disorders taking into account 
genetic susceptibility, multiple exposures (mixtures of environmental chemicals and natural 
products) and their timing (perinatal, peripubertal, adult); investigation of connections between 
perinatal reproductive development and obesity/metabolic disorders in later life. 

DEHALORES, Breathing 
chlorinated compounds: 
unravelling the biochem-
istry underpinning 
(de)halorespiration, an 
exciting bacterial metabo-
lism with significant 
bioremediation potential, 
EU Contribution €1.15M  

FP7-IDEAS 
Start date: 2008-09-01 
End date: 2013-08-31 

Seeks to unlock the full potential of bacterial metabolism for bioremediation of persistent 
organohalides, such as polychlorinated biphenyls (PCBs) and tetrachloroethene. However, the 
regulation, mechanism and structure of the reductive dehalogenase (the enzyme responsible for 
delivering electrons to the halogenated substrates) are poorly understood. This ambitious proposal 
seeks to study representatives of the distinct reductive dehalogenase classes as well as key elements 
of the associated regulatory systems. 

24 

DENAMIC, Developmental 
neurotoxicity assessment of 
mixtures in children, EU 
Contribution €6.99M 

FP7-ENVIRONMENT 
Start date: 2012-01-01 
End date: 2015-12-31 

25 

ENFIRO, Life Cycle 
Assessment of 
Environment-Compatible 
Flame Retardants: 
Prototypical Case Study, 
EU Contribution €3.16M 

FP7-ENVIRONMENT 
Start date: 2009-09-01 
End date: 2012-08-31 

Exposure to low doses of environmental biologically active contaminants during human development 
can alter gene expression and have deleterious effects on cognitive development in childhood. 
project is focused on reducing such effects of environmental contamination on learning and 
developmental disorders in children. It aims to study and evaluate environment-health relationships 
in children. 
Develop tools and methods for neurotoxic effects of mixtures of environmental pollutants at low 
levels, possibly resulting in (subclinical) effects on learning (cognitive skills) and developmental 
disorders in children; study mechanisms of disease development and the role of individual 
susceptibility; improve assessment of exposures and effects, focus on combined exposures to 
environmental agents that can interact to enhance adverse effects and reduction of health inequalities 
of children through Europe; dissemination will ensure the project results to arrive at policymakers' 
desks, and will also illustrate the subject for a scientific audience and the public. The very large 
network of the consortium ensures dissemination to European industries, and every other interested 
stakeholder. 
The project offers a prototypical case study on substitution options for specific brominated flame 
retardants (BFRs). It delivers a comprehensive dataset on viability of manufacture and application, 
environmental safety, and a life cycle assessment of the alternative flame retardants (FRs). 
Collection of information on the availability of alternative FRs, their characteristics in relation to fire 
safety regulations, environmental behaviour, possible toxic effects, economic aspects, compatibility 
with polymer manufacture and impact on the function and reliability of end products; selection of 

174 

http://www.eu-
deer.net/index.htm  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b2397c
56:cc2a:18356864&RC
N=87942  
- no project website yet  

http://ec.europa.eu/rese
arch/environment/pdf/f
p7_catalogue.pdf  
- no project website yet  

http://www.enfiro.eu/  

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

substitution options for specific BFRs for further study in a small number of case studies; technical 
assessment studies on application requirements regarding manufacture properties and application 
functions; technical assessment on five alternative FR/product combinations: printed circuit boards, 
electronic components, injection-moulded products, textile back coatings and intumesent paints; 
determination of toxicological effects and environmental behaviour, performance of risk assessment 
based on all environmental and human hazard information and performance of life-cycle assessment 
(LCA) and a life cycle costing (LCC) analysis of the alternative FRs studied. 
The project will focus on exposure response relationships in environment and health in pregnancy 
and early childhood based and supported of the wealth of data generated by past or ongoing studies 
funded by the EU and national programmes. 
Inventories of birth cohorts, including health and exposure data, biological samples, environmental 
exposure response functions, expertise, and access; assurance of quality and interoperability and 
validation of exposure, health and exposure-response data; extraction and rigorous evaluation of 
quality of the data, including developing protocols; data access, databases and analysis, including 
setting-up of protocols for data access, database building and analyses, and exposure-response 
analyses; conduction of specific analyses on exposure and health data to obtain exposure-response 
functions and specific meta/pooled analyses to obtain exposure-response functions; 
recommendations for data collection in the future to improve environment health linkages and 
information for data collection (exposure, health etc), for possible analyses (laboratory and 
statistical) and for exchange of knowledge between (older and newer) cohorts; dissemination of 
information through the project website, virtual network, workshop(s), easy accessible info and a 
database with exposure-response functions. 
The project will aim at the development and application of a new generation of biomarkers to study 
the role of environmental agents in human disease. 
Discovery and validation of novel biomarkers predictive of increased risks of chronic diseases, in 
which the environment may play an important role (breast cancer, NHL, allergy, neurological and 
immune diseases, thyroid disruption); exploration of the association of such risk biomarkers with 
environmental exposures, including high-priority pollutants (carcinogens and immunotoxicants) and 
emerging exposures (such as phthalates and brominated flame retardants), many of which are also 
endocrine disrupters; discovery and validation of biomarkers of exposure to the above and other 
high-priority environmental exposures (e.g., water disinfection by-products). 

http://www.enrieco.org/  

http://www.envirogeno
markers.net/  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b7126
2d3:c74c:56e3be5f&R

26 

ENRIECO, Environmental 
Health Risks in European 
Birth Cohorts, EU 
Contribution €0.91M 

FP7-ENVIRONMENT 
Start date: 2009-03-01 
End date: 2011-02-28 

ENVIROGENOMARKER
S, Genomic Biomakers of 
Environmental Health, EU 
Contribution €3.5M 

FP7-ENVIRONMENT 
Start date: 2009-03-01 
End date: 2013-02-28 

27 

28 

EXPLOIT-CSIA, 
Exploiting the potential use 
of compound specific 
isotope analysis (CSIA) in 
marine environment, EU 
Contribution €240,000 

FP7-PEOPLE 
Start date: 2010-09-01 
End date: 2012-08-31 

To explore, develop and exploit the potential use of Compound Specific Isotope Analysis (CSIA) to 
PAHs and POPs compound groups in marine environments in order to unambiguously allocate and 
distinguish their contaminant sources, track their contamination pathways ( environmental forensics), 
identify and quantify transformation reactions, chemical or biological remediation processes as well 
as degradation mechanisms 

175 

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

29 

FACET, Flavourings, 
Additives and food Contact 
materials Exposure Task, 
EU Contribution €5.88M 

FP7-KBBE 
Start date: 2008-09-01 
End date: 2012-08-31 

The project will estimate exposure to flavours, additives and food contact materials across Europe 
and the creation of a food chemical exposure surveillance system.  
Recording the occurrence levels of targeted chemicals in representative regions of the EU food 
supply. This will include a major survey of food packaging usage in countries representative of the 
regional groupings of FACET; creation of a database of targeted food chemical concentrations in 
foods, working closely with the food and packaging sectors, and the regulatory authorities; 
establishment of a migration modelling framework for complex packaging materials into foods under 
real conditions of use to deliver realistic concentration estimates for consumer exposure modelling; 
construction of a tiered food intake database aimed at foods, which are relevant to the target food 
chemicals; development of a personal computer-based, publicly available software programme, 
taking in to account the variation of national food consumption data, which will draw on limited 
data, build on known laws governing food intake and in particular build on small national surveys 
and local knowledge to model regional intake of target foods; building of new databases, populate 
them with the data generated by the project and to estimate exposure assessment using a probabilistic 
model. 

30 

31 

FOODSEG, Safe food for 
Europe – Coordination of 
research activities and 
dissemination of research 
results of EU funded 
research on food safety, EU 
Contribution €1M 

FP7-KBBE 
Start date: 2011-05-01 
End date: 2014-04-30 

The project will disseminate state-of-the-art research results in food safety and quality topics through 
a series of symposia, expert working group meetings, an online platform with best practise examples 
and coordination of cooperation and a plan for the preparation of future activities. 

HEROIC, Health and 
environmental risks: 
organisation, integration 
and cross-fertilisation of 
scientific knowledge, EU 
Contribution €0.98M 

FP7-ENVIRONMENT 
Start date: 2011-10-01 
End date: 2014-09-30 

Due to the lack of mutual understanding between experts of individual disciplines, data from 
toxicological and ecotoxicological studies is not readily accessible by risk assessors across 
disciplines. However, the need for risk assessment (RA) will continue to along with budget 
restrictions and political and public pressure to reduce the number of animal tests.  
More cost effective, predictive and rapid tests for high quality sustainable RA are needed including a 
better exploitation of existing data. Better risk communication to regain consumer/public trust and to 
give unambiguous guidance for improved risk management. Divergence often arises on risk policies 
and measures, sometimes due to different RA approaches. 
The project will establish and co-ordinate a global network of European and international experts and 
stakeholders from different disciplines to establish stronger interfaces between human and 
environmental RA, between RA and risk management, between the various agencies and countries 
within the EU and between agencies and industry. 

176 

More information 

CN=96372 
- no project website yet  

http://www.ucd.ie/facet/  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b6fc6a
a8:2f48:57083f56&RC
N=98810  
- no project website yet  

http://ec.europa.eu/rese
arch/environment/pdf/f
p7_catalogue.pdf  
- no project website yet 

 
 
32 

33 

34 

No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

INTERNAL EXPOSURE, 
Internal exposure in tissue 
equilibrium sampling to 
bridge the missing link 
between bioavailability and 
bioaccumulation, EU 
Contribution €180,000 

MARPAH, Marine micro-
algae as global reservoir of 
polycyclic aromatic 
hydrocarbon degraders, EU 
Contribution €330,000  

FP7-PEOPLE 
Start date: 2008-04-15 
End date: 2011-10-14 

The overall goal of this application is to improve the understanding of the link between 
concentrations of organic contaminants in the marine environment and the contaminant levels in the 
tissues of higher organisms where adverse effects are occurring, analysing internal exposure, 
bioaccumulation and bioavailability of organic contaminants. Investigation in the missing link 
between external concentrations of POPs and their levels at target sites in organisms where adverse 
effects occur. 

FP7-PEOPLE 
Start date: 2008-10-20 
End date: 2011-10-19 

To manage and mitigate the impacts of PAH pollution in the marine environment, it is necessary that 
we understand the mechanisms involved in their biodegradation. 

OBELIX, Obesogenic 
Endocrine disrupting 
chemicals: Linking prenatal 
exposure to the 
development of obesity 
later in life, EU 
Contribution €3M 

FP7-KBBE 
Start date: 2009-05-01 
End date: 2013-04-30 

35 

OPENTOX, An open 
source predictive 
toxicology framework, EU 
Contribution €2.97M 

FP7-HEALTH 
Start date: 2009-07-01 
End date: 2014-06-30 

It will investigate if prenatal exposure to endocrine disrupting compounds in food plays a role in the 
development of obesity and related disorders later in life.  
Assessment of prenatal exposure in humans to major classes of ECDs in food identified as potential 
inducers of obesity and related disorders later in life, sing mother-child cohorts from various 
European regions with different food contaminant exposure patterns; 
Relating markers for early life exposure to EDCs with effect biomarkers, novel biomarkers and 
health outcome data, which are related to risk for obesity and related disorders later in life; 
Performing hazard characterization of in utero exposure to representatives of major classes of EDCs 
in food with respect to the development of obesity later in life, using dose-response analysis in a 
rodent (mouse) model;  
Determination of mechanisms of action of obesogenic EDCs using analysis of effect biomarkers, 
gene expression and epigenetic analysis. Mouse models, in vitro models and analysis in peripheral 
mononuclear cells of biological samples from the cohorts, will be used as complementary tools; 
Performing risk assessment of prenatal exposure to besogenic EDCs in food, by integrating maternal 
exposure through food, contaminant exposure and health effect data in children, and hazard 
characterization and mechanistic information in animal and in in-vitro studies. 
The project will create a unified access framework to toxicological data, quantitative models and 
supporting information and it will provide tools for the integration of data from various sources. 
Development of a framework providing a unified access to toxicity data, (Q)SAR models, procedures 
supporting validation and additional information that helps with the interpretation of (Q)SAR 
predictions; 

177 

http://www.itm.su.se/pa
ge.php?pid=492  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b236ed
ee:17bb:77108fab&RC
N=88345 
- no project website yet  

http://www.theobelixpr
oject.org/  

http://www.opentox.org
/  

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

36 

OUTREACH, Overlooked 
Unresolved Toxic Organic 
Pollutants: Resolution, 
Identification, 
Measurement and Toxicity, 
EU Contribution €2M 

FP7-IDEAS 
Start date: 2009-07-01 
End date: 2014-06-30 

37 

PERFOOD, Perflourinated 
organic in our diet, EU 
Contribution €3M 

FP7-KBBE 
Start date: 2009-08-01 
End date: 2012-07-31 

Provision of accessibility at three levels: (i) A simple and intuitive interface for toxicological experts 
that provides unified access to (Q)SAR predictions, toxicological data, (Q)SAR models and 
supporting information; (ii) An expert interface for the streamlined development and validation of 
new (Q)SAR models; (iii) An application programming interface for the development, integration 
and validation of new (Q)SAR algorithms; 
Development as an open source project to optimise the dissemination and impact, to allow the 
inspection and review of algorithms and to attract external contributors; 
Close collaboration with related projects (e.g., OECD QSAR toolbox) and relevant authorities to 
agree on common standards and to avoid duplicated and redundant work. 

Identification, measurement and study of the effects of unresolved and unidentified, complex 
mixtures (UCMs) of organic chemicals 

The project focuses on the development of robust and reliable analytical tools, including reference 
materials for the determination of PFCs in food items. The aim is to qualify and quantify PFCs in our 
diet, understand how PFCs are transferred from the environment into dietary items, and quantify the 
possible contribution of food/beverage contact materials and food and water processing to the overall 
PFC levels in our diet. 
Assessment of the origin of PFCs in our diet and the contribution of the diet to the total human 
exposure to PFCs; development of robust and reliable analytical tools for the determination of PFCs, 
and using of these to (i) qualify and quantify PFCs in our diet; (ii) understand how PFCs are 
transferred from the environment into dietary items, and (iii) quantify the possible contribution of 
food/beverage contact materials and food and water processing to the overall PFC levels in our diet; 
evaluation of the possible routes, including their relative importance, of human exposure to PFCs via 
our diet; assessment of the role of the technosphere in the contamination of our food; identification 
of ways to reduce the PFC contamination of dietary articles. 

38 

PHARMAS, Ecological and 
human health risk 
assessments of antibiotics 
and anti-cancer drugs found 
in the environment, EU 
Contribution €2.8M 

FP7-ENVIRONMENT 
Start date: 2011-01-01 
End date: 2013-12-31 

Assess the risks to wild animals and humans posed by environmental exposure to pharmaceuticals.  
This project will concentrate on two classes of human pharmaceuticals, namely antibiotics and anti-
cancer drugs, considering uncertainty to obtain accurate data on both exposure concentrations and 
effects levels.  

178 

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=13&CAT=PRO
J&QUERY=0130b2290
de1:7015:28acdc28&R
CN=91068 
- no project website yet  

http://www.perfood.eu/  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=7&CAT=PROJ
&QUERY=012d5027c1
d5:b8ab:4d39d878&RC
N=97551  

 
 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

39 

QSAFFE, Quality and 
safety of feeds and food for 
Europe, EU Contribution 
€2.99M   

FP7-KBBE 
Start date: 2011-03-01 
End date: 2014-08-31 

40 

REEF, Reproductive effects 
of environmental chemicals 
in females, EU 
Contribution €2.92M 

FP7-ENVIRONMENT 
Start date: 2008-05-01 
End date: 2011-04-30 

41 

SYSTEQ, The 
development, validation 
and implementation of 
human systemic Toxic 
Equivalencies (TEQs) as 
biomarkers for dioxin-like 
compounds, EU 
Contribution €2.7M 

FP7-ENVIRONMENT 
Start date: 2009-02-01 
End date: 2013-01-31 

42 

TATOO, Tagging Tool 

FP7-ICT 

The project will deliver better, faster and economically viable means of ensuring the quality and 
safety of animal feeds in Europe. Provide an integrated approach to the reduction and management of 
chemical and microbiological contamination in animal feeds, better ways of preventing 
contamination and fraud, identifying and assessing new risks and providing scientific evidence of the 
risks of transfer of microbiological and chemical contaminants from feed to food.  
Development of new strategies for quality and safety assurance in the feed chain using existing 
testing methods and emerging technologies; development and improvement of systems of traceability 
and authenticity monitoring of the major feed materials used in Europe; identify the emerging risks 
(chemical and microbiological) from new sources of animal feed materials that may arise from 
changes to the formulation/composition of animal feeds and due to economic factors; undertake 
optimization and application of pharmaco-kinetic models focussing on a number of carefully selected 
transfer problems such as dioxins and PCBs, melamine and related compounds, Salmonella spp. and 
Listeria monocytogenes based on existing data and data generated in the studies performed within 
the project. 
The project will use a pattern of gestational development similar to humans, exposed long-term to a 
broad range of environmental chemicals (ECs) at low/environmental concentrations. This will 
provide a real-life model for human exposure. 
Examination of the effects of sewage sludge exposure during specific periods of foetal ovarian 
development in the sheep; examination of the effects of environmental concentrations of bis(2-
ethylhexyl)phthalate (DEHP) and polychlorinated biphenyls (PCBs) on female reproductive 
development in the sheep and mouse; investigation of the transgenerational effects of DEHP and 
PCB exposure on F2 sheep and mouse ovaries; examination of the effects of DEHP and PCBs on 
cultured human and sheep foetal ovaries; integration of human and animal models.  
TEQs are developed as biomarkers for exposure and risk of dioxin-like compounds, since chlorinated 
dioxins and biphenyls (PCBs) commonly occur in the human food chain and can still be detected at 
levels that might cause long term health effects.  
Establishment of possible differences between ‘uptake’ and ‘systemic’ TEFs; study of novel 
quantifiable biomarkers in in-vitro experiments; exploration of the possibility to use effects in 
peripheral lymphocytes as novel biomarkers; study of differences in TEFs between humans and 
experimental animal species in in-vitro experiments; testing of polychlorinated dibenzodioxins 
(PCDDs), polychlorinated dibenzofurans (PCDFs) and polychlorinated biphenyls (PCBs) in different 
in vitro systems; comparison of systemic TEFs (rodent models) and in vitro TEFs (rodent and human 
models) by applying multivariate statistical techniques; contribution to risk assessment; validation of 
biomarkers; contribution to establishing international consensus values of human ‘systemic’ TEF 
values for dioxin-like compounds, including some highly toxic PCBs. 
To set up a semantic web solution to close the discovery gap that prevents a full and easy access to 

179 

More information 

- no project website  

http://www.qsaffe.eu/  

http://www.abdn.ac.uk/r
eef/  

http://www.systeqproje
ct.eu/  

http://www.tatoo-

 
 
No. 

Acronym, Project Title, 
EU contribution 
based on a Semantic 
Discovery Framework, EU 
Contribution €2.52M 

Programme, 
Duration time 
Start date: 2010-01-01 
End date: 2012-12-31 

Short description and main objectives  

environmental resources on the web. The Central and Eastern European Centre for Persistent 
Organic Pollutants will participate in the project of validation. 

TMP53COMPMIX, 
Transcriptional mutagenesis 
in mammalian cell systems: 
p53 signaling as a probe of 
cellular effects, EU 
Contribution €100,000 

FP7-PEOPLE 
Start date: 2010-05-01 
End date: 2014-04-30 

TRANSPHORM, Transport 
related Air Pollution and 
Health impacts - Integrated 
Methodologies for 
Assessing Particulate 
Matter, EU Contribution 
€6.91M 

FP7-ENVIRONMENT 
Start date: 2010-03-01 
End date: 2014-02-28 

FP7-NMP 
Start date: 2012-12-01 
End date: 2015-11-30 

DEROCA, Development of 
safe and eco-friendly flame 
retardant materials based on 
CNT co-additives for 
commodity polymers, EU 
Contribution €2.95M 
MOSQUITOBLOCK, 
Integrated biomolecular 
methods to control 
mosquito-borne diseases, 

43 

44 

45 

46 

The model is based on the central role of p53 in the cellular response to DNA damages derived from 
carcinogenic polycyclic aromatic hydrocarbons (PAHs). 

The project will develop and implement an integrated methodology to assess the health impacts of 
particulate matter (PM) resulting from transport related air pollution. 
Quantification of pollutant-specific human exposure to airborne particulate matter in urban 
environments resulting from emissions from the main transport sectors; conduction of measurement 
campaigns in Rotterdam, Helsinki and Thessaloniki for source apportionment, exposure assessment 
and model evaluation purposes establishing new and unique datasets to better reflect actual exposure 
to air pollution caused by the transport sector; development, improvement and integration of air 
quality dispersion and exposure models for urban and regional scales; determination of improved 
and, where necessary, new emission factors of ultrafine particle number expressed as PN0.1 and 
mass fractions of PM1, PM2.5 and PM10 for key transport sources; development of an integrated 
assessment methodology to connect the various transport sources to human exposure to air pollution; 
development of new concentration-response or exposure-response functions linking long and short-
term ambient residential exposure to size-resolved and speciated PM with key health endpoints; 
application of the full chain integrated health assessment method to a number of selected European 
cities experiencing pollution from road traffic, harbours and shipping, airports and other sources such 
as railways. 
Currently, best flame retardant formulations are still often based on halogenated flame retardants 
(FR).  Those halogneted FR are supsected to endcrine disrupters when leaching from the material 
and produce toxic fumes and acids (HBr, HCl, organoirritants, PCDD/Fs etc.). 

More information 

fp7.eu/tatooweb/  

http://cordis.europa.eu/f
etch?CALLER=FP7_P
ROJ_EN&ACTION=D
&DOC=1&CAT=PROJ
&QUERY=0130b2381
20e:ba93:06e913f6&R
CN=94459 
- no project website yet 

http://www.transphorm.
eu/  

https://cordis.europa.eu/
project/rcn/105644/fact
sheet/en  

FP7-PEOPLE 
Start date: 2015-12-01 
End date: 2016-11-30 

DEROCA project aims at (i) developing and introducing new safer and more eco-friendly FRs 
through exploiting the synergistic effect of carbon nanotubes with phosphorus based flame retardants 
and other new promising additives in intumescent or carbon crust formation systems by promoting a 
more efficient/cost competitive solution; (ii) developing small scale test methods and models to 

https://cordis.europa.eu/
project/rcn/106494/fact
sheet/en  

180 

 
 
 
No. 

Acronym, Project Title, 
EU contribution 
EU Contribution €15,000 

Programme, 
Duration time 

47 

4G-PHOTOCAT, Fourth 
generation photocatalysts: 
nano-engineered 
composites for water 
decontamination in low-
cost paintable 
photoreactors, EU 
Contribution €3.73M 

FP7-NMP 
Start date: 2013-01-01 
End date: 2015-12-31 

48 

MOSQUITOBLOCK, 
Integrated biomolecular 
methods to control 
mosquito-borne diseases, 
EU Contribution €280,000 

FP7-PEOPLE 
Start date: 2013-09-01 
End date: 2015-08-31 

49 

TDSEXPOSURE, Total 
Diet Study Exposure, EU 
Contribution €5.97M 

FP7-KBBE 
Start date: 2012-02-01 
End date: 2016-01-31 

Short description and main objectives  

More information 

predict full end product standard scale test results based on small scalte tests. 
The approach will be multifaceted: (i) to better understand and promote interactions between CNT 
and different (FR) additives; (ii) to develop FR applications for five final products which represent 
large volumes of commodity polymers, i.e. automotive industry, wire and cable, industrial packaging 
and foam; (iii) to demonstrate and to assess fire performance of end-products, including fire toxicity; 
(iv) to develop models for the prediction of fire classification of materials based on small scale tests; 
(v) to introduce small scale test methods and models developed into international standardization; 
(vi) to assess the mechanical and other product specific essential properties of the FR polymer; (vii) 
to assess toxcicity and environmental impact of the FRs developed both in the manufacture chain and 
in the end use product; (ix) to assess the overall envrionmental impact of the Frs developed FRs 
through LCA." 
Mosquitoes transmit some of the world's most serious diseases. The most important disease vectors 
are members of the subfamilies Anophelinae and Culicinae. Anopheles mosquitoes transmit malaria, 
filarial parasites , and a few arboviruses. There are 30 genera in the Culicidae subfamily, but the 
medically important mosquitoes are Culex, Aedes, Mansonia, and Annigeres (Culex would be 
important in Europe for West Nile Disease and Avian malaria), while (Aedes would be more 
important in Tropical countries). Over the last 45 years, the use of chemical pesticides such as 
dichlorodiphe-nyltrichloroethane (DDT), gammaxane, malathion, and chlordane has been the method 
of choice for mosquito control, and the antimalarial drugs chloroquine and the affordable 
pyrimethamine-sulfadoxine combination have proved successful in lowering morbidity and 
mortality. In addition, the emergence of pesticide and drug resistant mosquitoes, coupled with a 
clearer appreciation of the long-term detrimental effects of powerful chemicals to non pest insects 
and concern about accumulation of pesticides in the food chain and environment, has high lighted the 
need to quickly develop an alternative. A promising alternative is biological control. So, this project 
would focus on non-chemical methods of control mosquitoes 
The project 4G-PHOTOCAT allies the expertise of 7 academic and 3 industrial partners from 5 EU 
countries (Germany, United Kingdom, Czechia, Poland, and Finland) and 2 ASEAN countries 
(Malaysia and Vietnam) for the development of a novel generation of low-cost nano-engineered 
photocatalysts for sunlight-driven water depollution. Through rational design of composites in which 
the solar light-absorbing semiconductors are coupled to nanostructured redox co-catalysts based on 
abundant elements, the recombination of photogenerated charges will be suppressed and the rate of 
photocatalytic reactions will be maximized. In order to achieve fabrication of optimal architectures, 
advanced chemical deposition techniques with a high degree of control over composition and 
morphology will be employed and further developed. Furthermore, novel protocols will be 
developed for the implementation of the photocatalysts into a liquid paint, allowing for the 
deposition of robust photoactive layers onto flat surfaces, without compromising the photoactivity of 
immobilized photocatalysts. Such paintable photoreactors are envisaged particularly as low-cost 

http://www.4g-
photocat.eu/  

https://cordis.europa.eu/
project/rcn/106417/fact
sheet/en  

http://www.tds-
exposure.eu/  

181 

 
 
No. 

Acronym, Project Title, 
EU contribution 

Programme, 
Duration time 

Short description and main objectives  

More information 

devices for detoxification of water from highly toxic persistent organic pollutants which represent a 
serious health issue in many remote rural areas of Vietnam and other countries. The 4G-PHOTOCAT 
project will provide novel scientific insights into the correlation between compositional/structural 
properties and photocatalytic reaction rates under sunlight irradiation, as well as improved 
fabrication methods and enhanced product portfolio for the industrial partners. Finally, 4G-
PHOTOCAT will lead to intensified collaboration between scientists working at the cutting edge of 
synthetic chemistry, materials science, heterogeneous photocatalysis, theoretical modelling, and 
environmental analytics, as well as to unique reinforcement of cooperation between scientists and 
industry partners from EU and ASEAN countries. 
Mosquitoes transmit some of the world's most serious diseases. The most important disease vectors 
are members of the subfamilies Anophelinae and Culicinae. Anopheles mosquitoes transmit malaria, 
filarial parasites , and a few arboviruses. There are 30 genera in the Culicidae subfamily, but the 
medically important mosquitoes are Culex, Aedes, Mansonia, and Annigeres (Culex would be 
important in Europe for West Nile Disease and Avian malaria), while (Aedes would be more 
important in Tropical countries). Over the last 45 years, the use of chemical pesticides such as 
dichlorodiphe-nyltrichloroethane (DDT), gammaxane, malathion, and chlordane has been the method 
of choice for mosquito control, and the antimalarial drugs chloroquine and the affordable 
pyrimethamine-sulfadoxine combination have proved successful in lowering morbidity and 
mortality. In addition, the emergence of pesticide and drug resistant mosquitoes, coupled with a 
clearer appreciation of the long-term detrimental effects of powerful chemicals to non pest insects 
and concern about accumulation of pesticides in the food chain and environment, has high lighted the 
need to quickly develop an alternative. A promising alternative is biological control. So, this project 
would focus on non-chemical methods of control mosquitoes 
Total Diet Studies (TDS) allow getting information on real dietary exposure to food contaminants 
consumption (heavy metals, mycotoxins, POPs...) and estimating chronic exposure to pesticide 
residues in food and food additives intake. TDS consider total exposure from whole diets and are 
based on food contamination as consumed rather than contamination from raw commodities, thus 
ensuring a realistic exposure measure. 

TDS facilitate risk assessment (RA) and health monitoring (HM). Some EU Member States (MS) 
and Candidate Countries (CC) have no TDS programme or use various methods to collect data, 
which were not examined yet to tell whether they are comparable or not. This is of interest for EFSA 
or WHO-FAO. Similarly it is important to harmonise methods to assess dietary exposure risks in 
MS, CC and at the European level compared with other world regions. 

https://cordis.europa.eu/
project/rcn/106982/fact
sheet/en  

https://cordis.europa.eu/
project/rcn/99555/facts
heet/en  

https://cordis.europa.eu/
project/rcn/103148/fact
sheet/en  

182 

50 

FOLDHALO, Folding with 
Halogen Bonding, EU 
Contribution €1.39M 

FP7-IDEAS-ERC 
Start date: 2013-03-01 
End date: 2018-02-28 

51 

52 

DEGRAPOLL, 
Degradative potential of 
rivers as a key driver of the 
environmental fate and sink 
of organic pollutants, EU 
Contribution €170,000 
MOSSCLONE, Creating 
and testing a method for 
controlling the air quality 
based on a new 
biotechnological tool. Use 
of a devitalized moss clone 
as passive contaminant 
sensor, EU Contribution 

FP7-PEOPLE 
Start date: 2011-11-01 
End date: 2013-10-31 

FP7-ENVIRONMENT 
Start date: 2012-04-01 
End date: 2015-03-31 

 
 
No. 

53 

54 

Acronym, Project Title, 
EU contribution 
€3.49M 
TOP, Trophodynamics of 
Organic Pollutants Studied 
by Compound-Specific 
Isotope Analysis, EU 
Contribution €15,000 
TOP, Trophodynamics of 
Organic Pollutants Studied 
by Compound-Specific 
Isotope Analysis, EU 
Contribution €250,000 

Programme, 
Duration time 

FP7-PEOPLE 
Start date: 
End date: 

FP7-PEOPLE 
Start date: 2010-03-01 
End date: 2012-02-29 

Short description and main objectives  

More information 

The methods proposed will aim for food sampling, standard analytical procedures, exposure 
assessment modelling, priority foods and selected chemical contaminants consistency across MS and 
CC. Various approaches and methods to identify sampling and analyses will be assessed and best 
practice defined. Contaminants and foods which contribute most to total exposure in European 
populations will be defined. 
Priority will be given to training and support in EU MS and CC currently without TDS. It will 
demonstrate best practice in creating a TDS programme using harmonised methods in regions 
previously lacking TDS, and ensure consistency of data collected. A database will be set up 
describing existing EU studies and collating harmonised exposure measures and designed to allow 
risk assessors and managers handling dietary exposure more accurately and more specifically. 

https://cordis.europa.eu/
project/rcn/193060/fact
sheet/en  

https://cordis.europa.eu/
project/rcn/92328/facts
heet/en  

183 

 
 
 
 
 
Table 15   Research Projects with references to POPs funded by LIFE+ 

No. 

1 

2 

3 

4 

5 

Programme, Duration 
time 

Start date: 01.04.2010 
End date: 01.10.2010 

Start date: 01.10.2010 
End date: 31.12.2013 

Start date: 03.10.2016 
End date: 30.09.2019 

Acronym, Title, EU 
contribution 

WOMENBIOPOP, Linking 
Environment and Health: a 
Country-based Human 
Biomonitoring Study on 
Persistent Organic Pollutants 
in Women of Reproductive 
Age, €0.8M 
EXPAH, Population 
Exposure to PAH, €2M 

LIFE-COMBASE - 
COMputational tool for the 
assessment and substitution 
of Biocidal Active 
substanceS of 
Ecotoxicological concern, 
€680,000 

LIFE-BIOREST - 
Bioremediation and 
revegetation to restore the 
public use of contaminated 
land, €970,000 

Start date: 01.07.2016 
End date: 30.06.2019 

LIFE BIOPOL - Manufacture 
of Leather making 
BioPolymers from biomasses 

Start date: 01.07.2016 
End date: 30.09.2019 

Project reference, Objectives or Main results 

More information 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=3433  

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=3756  

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=5749 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=5769 

LIFE08/ENV/IT/000423, To respond to the increasing 
demand for information on the level of exposure to POPs 
of environmental origin. It will focus on the subpopulation 
of women of reproductive age (20-40 years), whose 
exposure to POPs will be assessed through biomonitoring. 

LIFE09 ENV/IT/000082, To address the environmental 
and health problems caused by the emission, dispersion 
and transformation of PAH compounds. 
The LIFE-COMBASE project will demonstrate a new 
computational tool for assessing and reducing the impact 
of biocides of ecotoxicological concern, and will promote 
their substitution with safer substances. Project results will 
be communicated to the Biocidal Products Committee 
(BPC) of the European Chemicals Agency (ECHA), in 
order to boost replicability. The project will make a special 
contribution to the EU Biocides Product Regulation, 
especially regarding the precautionary principle; the 
promotion of low-risk substances; and the reduction of 
animal testing. 
Contamination by hazardous substances is one of the main 
causes of soil degradation and loss of terrestrial ecosystem 
services. The most common soil contaminants in Europe 
are heavy metals, mineral oils, polycyclic aromatic 
hydrocarbons (PAHs) and mixtures of benzene, toluene, 
ethylbenzene and xylene (BTEX). Mineral oils, PAHs and 
BTEX make up 45% of the inventory of contaminants in 
Europe. The LIFE-BIOREST project aims to provide a 
viable method that uses fungal and bacterial strains for the 
in situ bioremediation of contaminated sites. 
The leather industry consumes large volumes of water and 
chemicals. The chemicals used are mostly petrochemical-
based, due to the easy availability of such materials and to 

184 

 
 
 
 
and industrial by 
products,through Life Cycle 
Designed processes, €2.1M 

6 

7 

8 

9 

LIFE-FLAREX - Mitigation 
of environmental impact 
caused by Flame Retardant 
textile finishing chemicals, 
€700,000 

Start date: 01.07.2017 
End date: 30.06.2020 

LIFE VERMEER - 
Integrating VEGA, toxRead, 
MERLIN-Expo, and ERICA 
in a platform for risk 
assessment and substitution 
of risky substance, €1.5M 

LIFE PHOENIX - 
Perfluorinated compounds 
HOlistic ENvironmental 
Interistitutional eXperience, 
€1.3M 

Start date: 01.09.2017 
End date: 30.06.2021 

Start date: 01.09.2017 
End date: 31.03.2021 

LIFE-PSLOOP - Polystyrene 
Loop, €2.7M 

Start date: 01.07.2017 
End date: 01.07.2021 

their chemical stability. The BIOPOL project aims to 
demonstrate the technical performance and economic 
viability of an innovative process for producing new 
biopolymers (‘green chemicals’) to be used in the tanning 
industry. Decreasing use of water and the use of hazardous 
chemicals and pollutants such as heavy metals, 
formaldehyde, chromium, chlorinated paraffin, VOCs 
(volatile organic compounds) and inorganic salts. 
Flame retardants (FRs) are a group of anthropogenic 
environmental contaminants, many of them are considered 
toxic, persistent and bio-accumulative. 
The main objective of the LIFE-FLAREX project is to 
promote the use of safer alternative flame retardants (FRs) 
in order to mitigate the environmental and health impacts 
caused by toxic compounds in FRs containing bromine, 
formaldehyde and antimony in textile finishing products. 
LIFE VERMEER project is to deliver flexible and user-
friendly software tools, called SPHERA and ToxEraser, for 
the substitution of harmful chemicals. An assessment of the 
risks must evaluate the impacts on human health and 
environment, which are separate disciplines. The indicators 
for distinguishing between safe and unsafe chemicals must 
incorporate multiple criteria related to both exposure and 
hazard. 
The LIFE PHOENIX project aims to demonstrate how a 
new interinstitutional governance system, supported by 
innovative forecast tools based on ongoing monitoring, can 
more effectively and efficiently manage the risks related to 
the diffusion of Persistent Mobile Organic Contaminants 
(PMOC) – with a particular focus on PerFluorinated Alkyl 
Substances (PFAS). This system will help avoid, or at least 
reduce, public expenditure on damage caused by PMOC, 
which represents a major threat to public health through 
drinking and irrigation water.  
Expanded polystyrene (EPS) foam is used extensively 
throughout Europe as an insulation material. EPS that was 
produced before 2015 contains the flame retardant 
Hexabromocyclododecane (HBCD). The objective of the 
PSLoop project is to recycle both EPS construction waste 

185 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6182 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6191 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6206 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6263 

 
 
10 

11 

12 

13 

LIFE AskREACH - Enabling 
REACH consumer 
information rights on 
chemicals in articles by IT-
tools, €4.2M 
LIFE SURFING - 
SURFactant enhanced 
chemical oxidation for 
remediatING DNAPL, €1.2M 

Start date: 01.09.2017 
End date: 31.08.2022 

Start date: 01.01.2019 
End date: 30.06.2022 

LIWE LIFE - Lidköping 
Innovation Wastewater Eco-
Hub, €3.0M 

Start date: 01.07.2018 
End date: 30.06.2023 

LIFE APEX - Systematic use 
of contaminant data from 
apex predators and their prey 
in chemicals management, 
€2.0M 

Start date: 01.09.2018 
End date: 31.08.2022 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6325&d
ocType=pdf 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6765 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6768&d
ocType=pdf 

http://ec.europa.eu/environment/life/project/Projects/ind
ex.cfm?fuseaction=search.dspPage&n_proj_id=6747 

and extruded polystyrene (XPS) and to demonstrate an 
economically viable alternative to incineration. 
LIFE AskREACH has the overall goal of helping the 
implementation of the REACH Regulation.  

The LIFE SURFING project aims to fully eradicate 
pervasive pollutants in sites contaminated by Lindane. 
Regional authorities in Aragon, Spain, will demonstrate the 
benefits of combining techniques from surfactant enhanced 
aquifer remediation and surfactant-enhanced in situ 
chemical oxidation to extract Lindane residues from even 
the smallest fractures in rocks and remove it from natural 
environments completely. 
The LIWE LIFE project aims to demonstrate advanced 
wastewater treatment technologies that improve water 
quality while boosting both resource and energy 
efficiency. The so-called Circular Wastewater System 
(CWS) developed by the municipality of Lidköping will 
tackle emerging pollutants and pathogens in local 
effluents, notably removing pharmaceuticals, hormones 
and micro-plastics that conventional wastewater plants 
struggle to filter out of water supplies. 
The project expects to Reduce the concentration of micro-
plastics and persistent organic pollutants by 99.5% 
The LIFE APEX project aims to enable regulators of 
chemicals to make more systematic use of monitoring data 
from apex predators and prey. This will reduce exposure to 
harmful substances and protect human health and the 
environment. 
Data from apex predators and prey samples will be used to 
detect the presence of chemical contaminants in the 
environment, help pick the most relevant substances for 
further hazard assessment, assess the impact and 
effectiveness of substance risk mitigation measures, and 
define predominant chemical mixtures in the environment 

186 

 
 
 
187 

 
 
 
 
9. 

OBSOLETE ACTIONS FROM PREVIOUS UIP 

This section provides details of actions from the previous version of the UIP which have 
either been completed or which are no longer relevant for other reasons. The actions 
presented here have retained the numbering used from the previous UIP with a brief 
description of how the action has been completed or is no longer needed. 

Action 1: Commission to compile information on HBCDD alternatives from the 
REACH process and feed this information into the Stockholm Convention process on 
alternatives to HBCDD to guide the selection process of HBCDD alternatives for the 
uses in expanded polystyrene and extruded polystyrene in buildings. (ongoing action) 

The primary use of HBCDD (≥90% of all use) was within polystyrene insulation boarding 
(EPS/XPS). Authorisations under REACH for HBCDD within these two applications were 
granted but these expired in August 2017. Since the Authorisations for use of HBCDD have 
now expired, it is expected that alternatives have been identified and are in use.  

Furthermore, in January 2019, the Stockholm Convention Secretariat published details on its 
guidance for alternatives to HBCDD359, which includes data from the European Union and 
ECHA. This action can now be considered complete. 

Action 5: Commission to continue to gather available information on the effective 
screening and separation of PBDE-containing materials in the recycling flow of WEEE 
in the EU and depending on the outcome consider further actions. (ongoing action). 

The UNEP Stockholm Secretariat published two sets of guidance in 2017, one with detailed 
information on guidance for developing POP-PBDE emission inventories including waste 
activities, and a second with detailed information on guidance for sampling, analysis, and 
separation of POP-PBDEs within waste streams. These two documents could be expected to 
fulfil Action 5, meaning that the action is no longer needed, but is replaced by a new action 
for the Commission to encourage the use of the guidance in Member State planning and 
implementation plans.  

Action 7: The Commission should develop guidance related to “closed-loop” in the 
metal plating industry including PFOS-containing waste handling as part of the “closed-
loop”. (This action was also listed within the previous implementation plan and is still 
ongoing) 

359 

http://chm.pops.int/Implementation/NationalImplementationPlans/Guidance/tabid/7730/ctl/Download/
mid/20999/Default.aspx?id=1&ObjID=27217 

188 

 
 
 
                                                           
The recast of the POPs Regulation in 2019 now includes a definition of what is meant by 
closed-site, which will cover ‘closed-loop’ as detailed within Action 7. This Action is now 
considered complete. 

Action 8: Commission to support the validation of a CEN standard on measurement of 
PFOS in coated and impregnated solid articles, liquids and fire-fighting foams. (ongoing 
action) 

The technical specification for measuring PFOS in coated and impregnated solid articles, 
liquids and fire-fighting foams has been developed and can be used in a CEN standard. 
Therefore, this action can be removed as completed. 

Action 17: The Commission and the Member States should support the work on 
decontamination of POP PBDE containing materials through collection of information 
that should be disseminated to all stakeholders. This would also include promotion of 
techniques to manage POP PBDE containing materials across the European Union. (This 
action was also listed within the previous implementation plan and is still ongoing) 

A Study by Ramboll (2019) on behalf of the European Commission assessing the waste 
thresholds under Annex IV and V includes detailed information on decaBDE, including 
material flows and identification of where emission sources may occur. Furthermore, two 
guidance documents published in 2017 by the UNEP Stockholm Convention Secretariat on 
development of emission inventories for POP-PBDEs and sampling, analysis, and screening 
of POP-PBDEs in waste provide significant amounts of data addressing Action 17. Finally, 
CEN standards for PBDEs released from WEEE have also been developed to assist in 
monitoring of PBDEs. This action is considered completed. 

Action 25: Commission to promote a more coherent approach to the generation, 
collection, storage and use of chemical monitoring data in relation to humans and the 
environment, through the creation and maintenance of an information platform for 
chemical monitoring data. (This is a continuous action) 

The creation of the IPCheM platform360 provides a centralised repository for key information 
on POPs. This fulfils Action 25. 

360 https://ipchem.jrc.ec.europa.eu/RDSIdiscovery/ipchem/index.html 

189