NGO Response to the EU Proposal for Short-chain Chlorinated Paraffins Waste Limits under the Basel and Stockholm Convention

Dear President Juncker,

We are writing to express concerns surrounding EU actions on setting hazardous waste limits for short-chain chlorinated paraffins (SCCPs) under the Basel and Stockholm Conventions. This is an issue which has horizontal implications for issues such as circular economy, health, environment and internal market, each of which is affected by what hazardous waste limits are set for SCCPs. The Basel Convention Open-Ended Working (OEWG11) will discuss this issue for SCCPs and other substances at their meeting next week, 3-6 September 20181. Governments will finalize these limits at the Conferences of Parties for the treaties in April/May 20192. The EU has an important role to play as the nominator of SCCPs for listing in the Stockholm Convention, but its current proposal raises questions about its commitment to the Convention’s objectives.

At issue is the “low POPs content” that defines the level at which waste must be treated according to stringent Stockholm Convention obligations to destroy their POP content. Waste with POPs below the low POPs content level are considered “clean” by the treaty. Most substances listed in the treaty have a low POPs content level of 50 ppm – a level that is still too high because such waste is highly hazardous, can contribute to the long-range transport of POPs, and can cause serious harm to public health and the environment. In contrast, the EU is proposing a recklessly high “low-POPs-content level” for SCCPs – 10,000 ppm3. This is the weakest proposal for a low POPs content level in the history of the Basel and Stockholm Conventions and 200-fold weaker than the limits for PCBs and other similar POPs. It is ironic that the EU originally proposed SCCPs for listing in the Stockholm Convention due to concerns over its harm, but now seeks to undermine protections against these same unmanageable POPs properties.

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