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Joint Statement - POP Annex I – comments on the proposed UTC thresholds for PBDEs

16 December 2022

The undersigned Associations would like to provide comments on the European Commission (EC) intention presented during the last POP Expert group on 24th November 2022.

This document focuses on the environmentally sound management of plastics containing polybrominated diphenyl ethers (PBDEs).

We understand and support the necessity to progressively phase out persistent organic pollutants (POPs) as this is a key enabler to transition towards cleaner recycling cycles for plastics waste, thereby benefitting the plastics recycling industry as more waste can be recycled into new products.


Legislative framework

In the past, PBDEs have been added to plastics by producers / manufacturers to prevent or slow down an ignition process. Due to safety standards, flame retardants are mostly used in electronic and electrical equipment and in vehicles. While the ban of PBDEs in the EU under the POPs Regulation prevents the introduction of new PBDEs into plastics material cycles, plastics containing PBDEs are still present in the waste stream due to the long life- service of the article.

The most important step to phase out the POP substance group of the PBDEs took place on 1st July 2006, with the introduction of the RoHS Directive. Since then, the substance group of PBDEs was restricted for the use in new electronic appliances. However, decabromodiphenyl ether (DecaBDE) was allowed in polymeric applications until 2010 and consequently is the predominant PBDE found in the plastics derived from the treatment of Waste Electrical and Electronic Equipment (WEEE) at plastics recycling facilities. Prior to that, PBDEs were typically used in concentrations of up to 180,000 ppm, generally in the housings of electronic products such as television sets and other domestic equipment producing heat, as additives embedded in polymer matrices.

With the introduction of the WEEE Directive (2002/96/EC), electrical and electronic products started to be collected and recycled across all EU Member States from 2003. This in turn introduced a new specialised industry that recycles plastics from e-waste and produces WEEE post-consumer recycled plastics. It is important to mention that the recycling of this complex mix of WEEE plastics makes them a recoverable secondary material suitable for reuse in high-tech products.



European Electronics Recyclers Association

EERA is a non-profit organisation and is the voice of WEEE recycling in Europe, being the professional association for the re-use, recycling and re-processing industry. Our vision is for a resource efficient economy where WEEE is managed as a resource and is returned into the economy as a secondary raw material or as equipment prepared for re-use.

Our mission is to achieve a level playing field for fair competition in the WEEE value chain, harmonisation of regulations, effective and efficient recycling, and reprocessing with prevention of pollution, minimization of emissions, and the high-quality recovery of secondary raw

materials and components.

European Recycling Industries’ Confederation

EuRIC is the authoritative voice of the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States and leading recycling companies.

The Confederation represents about 5,500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion EUR by treating various waste streams such as household or industrial & commercial waste including ferrous and non- ferrous metals, electronic waste (WEEE), end-of-life vehicles (ELVs), packaging (paper and plastics), end-of-life tyres or textiles.


FEAD: European Waste Management Association

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations representing 3,000 waste management companies.

Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fueling €5 billion investment into the economy every year.

Plastics Recyclers Europe

Plastics Recyclers Europe (PRE) is an organization representing the voice of the European plastics recyclers who reprocess plastic waste into high-quality material destined for the production of new articles. Recyclers are important facilitators of the circularity of plastics and the transition towards the circular economy.

Plastics recycling in Europe is a rapidly growing sector representing over €7.7 billion in turnover, 9.6 million tonnes of installed recycling capacity, more than 650 recycling facilities and over 20.000 employees.