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APPLiA's position on the Recast of the Persistent Organic Pollutants Regulation

APPLiA, Home Appliance Europe, would like to express its concerns about the unalignment of Articles 4(1)(b) and 7(4)(a) regarding the concentration limits for decaBDE and PBDE, respectively.

APPLiA calls on the Council to:

  • Align the concentration limit for decaBDE in Annex I related to Article 4(1)(b) with the concentration limit for the sum of poly-BDE (PBDE) in Annex IV related to Article 7(4)(a)
  • Reject the decaBDE concentration limits of 10 and 500ppm (Parliament Amendments 25 & 37)

APPLiA, Home Appliance Europe, would like to express its concerns about the unalignment of Articles 4(1)(b) and 7(4)(a) regarding the concentration limits for decaBDE and PBDE, respectively.

Whereas Article 4(1)(b) and Annex I set a concentration limit of 10 mg/kg (i.e. 10ppm) for decaBDE as an unintentional trace contaminant (UTC) in substances, mixtures, articles and constituents of flame-retardant articles, Article 7 (4)(a) and Annex IV prescribe a concentration limit of 500ppm for the sum of PBDE in recovered materials.

We would like to draw the attention of legislators to this existing contradiction between the decaBDE concentration limit set by Parliament Amendment 25 under Article 4(1)(b) and Annex I, including derogations, and the concentration limit set by Parliament Amendment 37 under Article 7(4)(a) and Annex IV of Regulation EC 850/2004. APPLiA firmly believes that this contradiction will inevitably raise negative consequences in terms of chemical-compliance when recycled materials are brought back to the market as recovered articles and/or as part of complex objects.

Therefore, for the purpose of developing coherent legislation for the control and management of Persistent Organic Pollutants (POPs), APPLiA calls for the alignment of decaBDE concentration limits under Articles 4(1)(b) (Annex I) and 7(4)(a) (Annex IV) of the corresponding Regulation.

APPLiA understands that it is not possible to reliably analyse, control and enforce a 10ppm limit value of BDE Congeners in recycled WEEE plastics through present detection methods. Hence, we would like to raise our concern to legislators that the proposed UTC limit will be an unrealistic and unfeasible target.

In addition, if approved, this limit value will challenge the legally-required WEEE recycling targets laid down in WEEE Directive 2012/19/EU. Consequently, the proposal will undermine and negatively impact the aims and objectives of the EU Circular Economy Package as we expect certain WEEE plastics to be landfilled and/or incinerated, instead of being recycled and brought back to the market.

For the purpose of setting an adequate, scientifically based decaBDE concentration limit, APPLiA urges the Council to provide a mandate to the Commission for the development of an Impact Assessment which will assign a concentration value for virgin and recovered materials considered as being a safe limit for the public health and for the environment. We firmly believe that both, 10 and 500ppm, are neither justified nor scientifically corroborated concentration limits.

APPLiA calls upon legislators to reject the 10ppm UTC proposal under Amendment 25 and the 500ppm proposal under Amendment 37. As long as an Impact Assessment is not available, the limit of decaBDE under Article 4(1)(b) (Annex I) and the limit of the sum of PBDE under Article 7(4)(a) (Annex IV) should remain aligned with the present decaBDE limit value as set under REACH Annex XVII (i.e. 1000 ppm).

Full PDF version of the Position Paper.