Questionnaire for industry associations representing users of secondary raw materials

Questionnaire for industry associations representing users of secondary raw materials

A consortium comprising RPA Europe, Risk & Policy Analysts (RPA), INERIS, and Bio Innovation Service has been contracted by the European Commission (DG Environment) to prepare an Impact Assessment study to support the preparation of a legislative proposal to amend Annexes IV and V of the Regulation (EU) No 2019/1021 (hereinafter the POP Regulation).

This includes an Impact Assessment of potential changes to Annex IV of the POPs Regulation (Low POP Content Limits, LPCLs) for the following eight Persistent Organic Pollutant (POP) substances/substance groups:
  • Polybrominated diphenyl ethers (PBDEs) already included in Annex IV of the POPs Regulation[1], with particular focus on decabromodiphenyl ether (decaBDE);
  • Hexabromocyclododecane (HBCDD);
  • Alkanes C10-C13, chloro (short-chain chlorinated paraffins) (SCCPs);
  • Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds;
  • Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds;
  • Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD & PCDF);
  • Pentachlorophenol (PCP) and its salts and esters; and
  • Polychlorinated biphenyls (PCBs) (differentiating between dioxin-like (dl) PCBs and non-dioxin like (ndl) PCBs).
Since LPCLs determine whether the waste containing these POPs can be recycled, they may impact in the availability, price or quality of secondary raw materials.

The purpose of this questionnaire is to understand the impacts of lowering LPCLs on industry stakeholders that use secondary raw materials.
This questionnaire is intended for industry associations that represent companies who use secondary raw materials which could contain POPs. 

The deadline for completion of the questionnaire is 15 June 2020.

The questionnaire consists of four parts:
  • Part A:  About your organisation;
  • Part B:  Use of relevant secondary raw materials;
  • Part C:  Impacts of legislative changes;
  • Part D:  Further communication.

All responses to this questionnaire will be treated in the strictest confidence and will only be used for the purposes of this study.  In preparing our reports for the Commission (which, subsequently, may be published), care will be taken to ensure that specific responses cannot be linked to individual companies.

Separate questionnaires are available for:
  • Waste management companies;
  • Industry associations representing waste management companies;
  • Member State authorities;
  • NGOs and other stakeholders; and
  • Manufacturers of sampling/analysis equipment.

If you have any questions about this study, please contact or +44 (0)1508 528 465.