Impact Assessment Study
Nomination of D4, D5, and D6 to the Stockholm Convention
Conclusions of Independent Impact Assessment: Listing of D4, D5, D6 under the Stockholm Convention would have widespread negative economic impacts without corresponding environmental benefits
Brussels, 14 November 2024 – Silicones Europe has released the findings of an independent impact assessment conducted by Ricardo Plc, highlighting the substantial economic repercussions of a potential listing of silicone monomers D4, D5, and D6 under the Stockholm Convention on Persistent Organic Pollutants (POPs).
The European Commission Directorate General for the Environment has expressed an intention to put forward a nomination for D4, D5 and D6 for inclusion under Annex B of the Stockholm Convention. The aim would be to globalise the existing REACH restrictions to ensure a high level of protection of the global environment whilst mitigating trade and competition distortions that could result in a competitive disadvantage for the EU. Yet the impact assessment, which surveyed manufacturers, importers, and six strategic downstream user sectors – aerospace and defence; transport; low-carbon energy; construction; healthcare and pharmaceuticals; and electronics, – underscores the potential for widespread negative economic impacts without corresponding environmental benefits if silicones are indeed considered POPs.
Economic Impact Analysis
The assessment evaluated three policy scenarios against a baseline scenario where there is no POP listing, yet current and proposed REACH restrictions apply. The findings indicate severe economic consequences across all scenarios:
- Policy Scenario 1: This scenario, which globalises the existing REACH restrictions, would result in an annual loss of €8 billion in the EU industry’s gross value added (GVA) and direct annual production activity losses of €15 billion from 2023 to 2040. The stringent controls on manufacture, transport, use, and waste disposal under the EU POPs Regulation are the primary drivers of these impacts.
- Policy Scenarios 2 and 3: These scenarios, representing more stringent outcomes, predict even higher economic repercussions, with annual production activity losses of €165 billion and €460 billion, respectively. The cost-benefit ratios for these scenarios are equally low or lower, indicating a negative balance of economic, social, and environmental impacts.
Environmental and Social Implications
Despite the significant economic costs, the assessment found that the overall environmental impacts of listing D4, D5, and D6 under the Stockholm Convention are neutral to negative. The increased waste generation and reduced recyclability of silicone-containing products would hinder efforts to enhance circularity and achieve carbon neutrality. Additionally, the substitution of silicones with less efficient alternatives would lead to higher energy consumption and greenhouse gas emissions.
Impact on EU Competitiveness
The potential listing of D4, D5, and D6 poses a threat to the EU’s global industrial competitiveness. The increased operational costs could drive industries to relocate activities outside the EU, particularly to the US and China, further eroding the EU’s market share in the silicones industry. This shift would also increase import dependency for silicone-based materials and products, impacting strategic sectors such as healthcare, defence, and electronics.
Silicones Europe’s Position
Silicones Europe opposes the nomination of D4, D5, and D6 to the Stockholm Convention on POPs, in part based on the outcome of this assessment, but also because the science to determine whether silicones meet the nomination criteria is inconclusive. To solve these remaining scientific uncertainties we, together with the Global Silicones Council, are working with an independent scientific panel – with the support of several EU Member State and third country authorities – to conduct a comprehensive field study in the Antarctic to gather robust scientific evidence.
Meanwhile, we continue to advocate for alternative measures that address environmental emissions without compromising the EU’s industrial competitiveness and strategic autonomy.
Find out how the following sectors are impacted:
