1. AP 4: ECHA - preparation of work under recast POPs Regulation AP 5: ECHA – Monitoring and reporting under recast POPs Regulation
20th Meeting of the Competent Authorities for Regulation (EC) N° 850/2004 on Persistent Organic Pollutants
Johanna Peltola-Thies
Ignacio González Rodríguez
13 June 2019

2. AP 4: ECHA - preparation of work under recast POPs Regulation

3. Outline
General
New POPs identification
Questions

4. Overall status Expected entry into force: July 2019 We are in schedule
Generic ECHA-website on POPs to go live very soon after entry into force
Limited resources and uncertainty on the operational budget for this year

5. Overall timeline –adjusted to the new estimate for entry into force

6. Outline
General
New POPs identification
Questions

7. New substance identification from the recast perspective – separate PCs in the EU in parallel to POPRC –work useful?

8. Several issues to clarify and agree this year, e.g.,:
EU public consultation on the proposal (Article 8(1)(b)) and risk profile and risk management steps (Article 8(1)(c) & (d))
Several issues to clarify and agree this year, e.g.,:
What is the added value of separate EU public consultations on risk profile and risk management evaluation during the work of the POPRC?
International calls for comments launched by the SC secretariat – should ECHA merely magnify these?
Added value of an EU public consultation reached already during the public consultation stage when preparing the EU proposal (Annex D -report)

9. Alignment of the work on new POPs and EU risk management processes
The initial aim of the Commission is to align the preparation of POPs EU proposals with REACH risk management processes
Need to further develop the approach to reflect the final recast Article 8(1) with regard to REACH risk management processes
Need to also consider:
- alignment with biocides and pesticides –processes
- how to work on the substances not in use in the EU and the priority
Proposal to be developed by ECHA in the autumn - for discussion and agreement to the next POP CA meeting

10. tbd: depending on the level of ambition and available resources
Identification of new POPs (WP1) - adjusted
Deliverables
Timeline
Agreement on the principles of work steps for new substances and their relation to REACH restriction process among MSCAs, COM and ECHA (and work under other relevant processes, e.g., PPP and biocides)
By the end of 2019
Process descriptions and work instructions for drafting (1) a proposal for identification of a new substance according to Annex D of Stockholm Convention, (2) annex E risk profile and (3) annex F risk management evaluation (mainly ECHA internal)
Case management development (ECHA internal step)
2019
Agreement on the level of informing the public on on-going work with the Commission and the MSCAs at the end of the year. Adaptation of the related IT tools (ACT, PACT), if needed.
By the end of the 2019
Development of the public consultation procedure for POPs-related processes (ECHA internal step)
(Mass screening/search pilot and work instruction for regular mass screenings)
tbd: depending on the level of ambition and available resources

11. Outline
General
New POPs identification
Questions

12. Questions for discussion??

13. AP 5: ECHA – Monitoring and reporting under recast POPs Regulation
Documents
POP-CA_06-19_05-ECHA- Reporting- Reporting on implementation under the POPs Regulation –initial analysis, proposals and questions – working document
POP-CA_06-19_04-ECHA- Preparation-Template and questions for written consultation related to the set up of ECHA’s tasks on reporting and implementation under the recast POPs Regulation
Background documents:
POP-CA_11-18_04-ECHA_doc 1 – Preparation of work under recast POPs Regulation
POP-CA_11-18_04-ECHA_doc 2 - Annex - Project Initiation document for MSCAs
POP-CA_11-18_04-ECHA_doc 4 – Annex - Supplementary information to PID
POP-CA_11-18_05-ECHA_doc 5 - Monitoring and reporting under recast POPs Regulation
POP-CA_11-18_05-ECHA_doc 6 - Annex Synthesis Reports Recommendations

14. Outline Drivers for change
Working document - Reporting on implementation initial analysis, proposals and questions – a non-exhaustive overview of issues
Deliverables and timelines

15. Towards a structured (IT-based) reporting system
Drivers for change:
Improve
the comparability of the data across MS by ensuring an standardised way of reporting the data (e.g. production and placing on the market, stockpiles, release inventories)
the quality, relevance of the data
the frequency of update (where relevant)
Reduce the reporting burden by
(re)using data that is already available (to the extent that is possible)
simplifying and automatizing the reporting process
Support the reporting obligations of ECHA (Union Overview) and the Commission
Promote the active public dissemination of the data
COM(2017) 312 final- Actions to Streamline Environmental Reporting:

16. Outline Drivers for change
Working document - Reporting on implementation initial analysis, proposals and questions – a non-exhaustive overview of issues
Deliverables and timelines

17. POP-CA_05-19_05-ECHA- Reporting
Reporting on implementation under the POPs Regulation –initial analysis, proposals and questions – working document
Content:
Analysis of the reporting/data submission obligations under the Recast
Interlinks with reporting obligations under other legislative frameworks (e.g. REACH, PIC)
Review of the current reporting format, reports and practices
Proposals and questions regarding:
The update of the reporting format and
Confidentiality of the information
- Areas where ECHA’s support could be explored (depending on the resources)
Reporting elements
1. Production and placing on the market
2. Exports
3. Stockpiles
4. Inventories on intentional releases
5. Provision of financial/ technical assistance
6. National Implementation plans
7. Public awareness and information exchange
8. Enforcement

18. Annual production and placing on the market
Data currently requested
Reporting sections
Information being requested
Annual production and placing on the market
- Name of the substance
- Volume (produced, placed on the market, imported, and exported)
- Importing/ exporting country (for imported and exported volumes)
Challenges
There is no reporting obligation for industry under the POPs Regulation (in addition to art. 4(3) notifications). This means that MSCAs need to check the registrations under REACH and CLP notifications under CLH regulation and then address companies that have registered/notified POPs
Confidentiality issues when publishing data on ECHA’s website (few companies manufacturing these substances)
Interlinks
REACH registration data and PIC data could be directly extracted from ECHA’s databases

19. Stockpiles Challenges Interlinks
Data currently requested
Reporting sections
Information being requested
Stockpiles
a) Stockpiles of substances the use of which is not permitted
- Name of the substance
- Notification year
- Characterisation of the stockpile, concentration of the substance (mg/kg), volume (kg), location
- Measures in place to manage the stockpile
b) Stockpiles of substances the use of which is permitted
Challenges
- ECHA will not receive data directly from Industry, but through MSCAs.
There is a reporting obligation for industry under the POPs Regulation to notify the MSCA of stockpiles >50 kg of substances, the use of which is still permitted but there is no reporting obligation for stockpiles of substances, the use of which is not permitted (to be dealt as waste)
Interlinks
- Inventories of equipment containing PCBs in volumes above 5dm3 have been collected and should be regularly updated by MSCA as part of the implementation of the PCB directive – no need for reporting under POPs regulation?

20. Release reduction, minimisation and elimination
Data currently requested
Reporting sections
Information being requested
Release reduction, minimisation and elimination
Data on estimated releases for Annex III substances per compartment (air, water, land)
Description on the measures place for identification, characterisation and minimisation of the sources and releases.
Challenges
The quantification of the emissions is estimated based on emission factors and activity rates -> Review of data submitted is needed in order to get meaningful trends on emissions
Different methodologies/guidelines available (EMEP/EEA, UNEP-POPs toolkit)
Interlinks
Emissions to air already reported under Convention on Long Range Transport Pollution (CLRTP) to the Centre on Emissions and Projections (CEIP) of European Monitoring and Evaluation Program (EMEP) and the European Environmental agency
Emissions submitted by industry under the E-PRTR regulation (apply only to certain economic activities and facilities above capacity and emissions thresholds)
Inventory of emissions, discharges and losses of priority substances under the Water Framework Directive (submitted to the EEA and available in EIONET under WISE SoE or WFD reporting obligations).

21. Other notifications to be received from MSCAs:
Derogations of waste management [article 7(4)(b)(iii)] -> MS allows a waste operator to deal with POP waste following a method listed in part 2 of annex V
Only 4 notifications received until now (DE(2), FI, FR).
Question -> need to support COM updating the current format?
Notification of articles containing POPs which are produced or are already in use before the regulation becomes applicable to the substance [article 4(2)]
Challenge -> no obligation from industry to notify under the POPs regulation
No data has been submitted so far from MSCAs
Potential link with Waste Framework Directive database for POPs in Candidate List?
Notifications of substances produced and used as a closed-system site-limited intermediate [article 4(3)]
Question -> need to support COM on developing templates/standard formats to support such reporting by industry?

22. Outline Drivers for change
Working document - Reporting on implementation initial analysis, proposals and questions – a non-exhaustive overview of issues
Deliverables and timelines

23. Deliverables/milestones related to reporting (WP2/WP4)
Timeline
Initial analysis, questions and proposals of ECHA to the POP CAs on various aspects of the reporting – for discussion in the meeting June 13 and for written comments by end of June 2019
2018 – T1\2019
Adoption of the Recast
Entry into force of the Recast
June 2019 July 2019
Proposal of the reporting formats and instructions. To be shared with MSCAs for feedback.
Proposal of an interim submission system for the reports if considered necessary (e.g. CIRCABC).
T2/2019
POPs reporting system vision and analysis of the IT solution
T2-T3/2019
Proposal prepared to establish an implementing act (Commission in consultation of POP CAs and ECHA)
T3/2019
Finalisation of the reporting format
The precise reporting formats need to be defined before the start of the reporting period Otherwise it cannot be ensured that the CAs would be able to collect the relevant information.
T3/2019-T1/2020
Review of the possibility to develop an IT-solution for the reporting formats to enhance the level of automation in processing the submitted information
If such development is considered feasible, following deliverables would be expected:
End of
Mock-up of the IT system for reporting to be shared with MSCA and Forum for feedback
Reporting system delivered for testing. Necessary changes after testing.
Reporting system available to MSCA in ECHA’s website. Relevant work procedures in place.
Carry out training internally and externally.
to be defined

24. Ambition level for reporting on the monitoring of the implementation
ECHA as a the interface for reporting duties
Receive, aggregate and disseminate information submitted by the POP-CAs following an agreed reporting format
Similar type of reporting as done by the POP-CAs towards the SC secretariat using the electronic reporting system
ECHA as “service provider” for the reporting duties
Reuse of available information submitted under REACH, CLP and PIC Regulations to support the reporting obligations under POPs
Provide a central platform for submission of notifications by industry towards the POP-CAs
stockpiles
Art 4.(3)(d) notifications
Need to balance the ambition level and the foreseen added value with the available resources

25. Questions to trigger discussion and to focus the further work of the new reporting format
Please, see document:
POP-CA_06-19_04-ECHA- preparation- Reporting on implementation under the POPs Regulation –initial analysis, proposals and questions – working document
and template for comments ( please provide comments by the end of June):
POP-CA_06-19_05-ECHA- reporting- Template and questions for written consultation related to the set up of ECHA’s tasks on reporting and implementation under the recast POPs Regulation

26. Thank you! ECHA_POP@echa.europa.eu
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