EERA Position Paper on PBDEs and the POP Regulation
EERA Position Paper | January 2024 | PBDEs and the POP Regulation
EERA’s Position Paper addresses proposed changes to the unintentional trace contaminant (UTC) limits for polybrominated diphenyl ethers (PBDEs) under the POPs Regulation and their implications for plastics recovered from WEEE.
EERA supports the progressive phase-out of persistent organic pollutants and cleaner recycling cycles, while calling for a regulatory framework that is scientifically robust, consistently applied and compatible with commercially viable plastics recycling in Europe.
Proposed changes to PBDE limits
The Position Paper addresses proposals to further reduce the unintentional trace contaminant (UTC) limits for PBDEs under the POPs Regulation. These included reducing the existing 500 mg/kg threshold to 350 mg/kg, with a further reduction to 200 mg/kg.
Proposals discussed by the European Commission in November 2023 also considered different limits for PBDE-containing recyclates, mixtures and articles, including a 10 mg/kg limit for certain products. EERA raised concerns about the implications of these proposals for the recycling and use of plastics recovered from WEEE.
EERA's position
EERA supports the progressive phase-out of persistent organic pollutants and the development of cleaner recycling cycles. However, any reduction in PBDE limits must be supported by scientifically validated testing methods that can be applied consistently and on a commercially viable basis.
EERA maintains that a stable regulatory environment is essential for investment in European WEEE plastics recycling and calls for a harmonised approach to testing across Member States before lower limits are introduced.
Impact on WEEE plastics recycling
EERA Members reported that existing screening technology could achieve the 500 mg/kg threshold but expressed less confidence in consistently achieving 350 mg/kg across different WEEE-derived plastic streams. The Position Paper highlights particular challenges arising from mixed polymers and the different additives and fillers present in WEEE plastics.
EERA also raises concerns that limits which cannot be reliably measured or achieved could reduce European plastics treatment capacity, divert recyclable plastics towards disposal, affect WEEE recycling and recovery performance and increase reliance on virgin plastics.
EERA's recommendations
EERA calls for a pragmatic and scientifically robust approach to future PBDE limits. Lower UTC limits should not be introduced until reliable testing methods are available that can be applied consistently and on a commercially viable basis across the industry.
EERA recommends maintaining a limit of 500 mg/kg for PBDE-containing recyclates, mixtures and articles following adoption, with a reduction to 200 mg/kg no earlier than 1 January 2030. For mixtures and articles containing only non-recycled material, EERA recommends a limit of 10 mg/kg following adoption.
Background documents
This Position Paper builds on EERA’s previous work on PBDE limits and the treatment of WEEE-derived plastics. It refers to discussions within the European Commission on proposed UTC limits for PBDEs, as well as EERA and industry positions published in 2022.
The documents referenced in the original Position Paper include:
European Commission, POP-CA_11-23_04-PBDE-UTC, November 2023
EERA, Statement on the Limit Values for Unintentional Trace Contaminants (UTC): One Substance – One Assessment, October 2022
Joint Statement – POP Annex I: Comments on the Proposed UTC Thresholds for PBDEs, November 2022
Read EERA’s full Position Paper on PBDEs and the POP Regulation, including the detailed technical analysis and recommendations.
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