Reporting Requirements

Under Regulation 850/2004/EC

- Experiences in Germany -

Dr. Heike Kaupp

Berlin Senate Department for Health,
Environment and Consumer Protection

1
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Contents
Reporting Requirements under Regulation 850/2004/EC

Specifics of the Administrative Structure and the Division of Responsibilities in the

Federal Republic of Germany

Example: PRTR

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 2
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Reporting Requirements under 850/2004/EC

Reporting Requirements Status in Germany*, **

Art. 5 (2): holder of stockpiles > 50 kg consisting of or No such stockpiles were reported to
containing Annex I or II compounds report this to the the responsible state agencies
competent authority
Art. 6 (1): MS draw up and maintain release inventories Project “National Implementation Plan
(…) in accordance with the Convention and the Protocol under the Stockholm Convention on
Persistent Organc Compounds
(POPs)”, report published in 2008
Art. 6 (2): Communicate the action plan on measures to Action plan focuses on uPOPs
identify, characterise and minimise the total releases in
accordance with the Convention and the Protocol
Art. 8: MS communicate their National Implemetation NIP 2006*, NAP2008*
Plan to the Com and other MS

*http://www.pops.int/documents/implementation/nips/submissions/Germany_NIP.pdf
** http://www.umweltdaten.de/publikationen/fpdf-l/3354.pdf Dr. Heike Kaupp
Senate Department for Health, Environment and Consumer Protection 3
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Reporting Requirements under 850/2004/EC

Reporting Requirements Status in Germany*, **

Art. 12: MS inform the COM each three yrs on

the application of the regulation including
information on infringements and penalties
Art. 12: MS provide the COM yearly with
statistical data on the actual or estimated total
production and placing on the market of Annex I
or II compounds
Art. 12: 3 yrs after entry into force and update
each 3 yrs for information on notification on
stockpiles, compiled from release inventories
and on the presence of Annex III compounds in
the environment
Plant protection products: No production
and placing on the market in DE
Biocide products: No registration in DE
- stockpiles: No stockpiles reported
- PCBs: disposal nearly completed
- release inventories: NAP (2008)
- presence of Annex III compounds in the
environment “POP-Dioxin Database”

*http://www.pops.int/documents/implementation/nips/submissions/Germany_NIP.pdf
** http://www.umweltdaten.de/publikationen/fpdf-l/3354.pdf Dr. Heike Kaupp
Senate Department for Health, Environment and Consumer Protection 4
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Conclusion 1
(cited from German NIP* chapters 3.1.4 and 4)
• "On the basis of the current list of substances in Annexes A and B, no further action is
envisaged within the National Implementation Plan.
• National priorities
- national action plan on Annex III chemicals (unintentionally produced POP)
- development of an emission inventory
- contribution the the BAT/BEP work
- public information
- environmental monitoring
- identification of new POP
- investigating retrospective trends for new POP with samples from the
environmental specimen bank
- harmonising the calculation method for TEQ

Dr. Heike Kaupp

*http://www.pops.int/documents/implementation/nips/submissions/Germany_NIP.pdf Senate Department for Health, Environment and Consumer Protection 5
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Administrative Structure of Germany

Federal government

16 Governments of the States (“Länder”)

Dr. Heike Kaupp

http://www.deutsche-staedte.de/bundeslaender_fr.html
Senate Department for Health, Environment and Consumer Protection 6
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

850/2004/EG: Division of Responsibilities between

Federal and Länder Level in Germany
850/2004 Addressees
Stockpiles of POP Reporting stockpiles of Annex I and II Agencies of the states
chemicals (> 50 kg) (Article 5 (2) in (chemicals, waste, agriculture/
conjunction with Article 12 (3a)). forestry)

Ban on the Annual transmission of data on actual or Agencies of the states

manufacture and estimated total volume of all Annex I and Chemicals Industry
use of POP II substances (Art. 12 (2)) manufactured
(associations)
and placed on the market

Wastes containing Informing the COM on exemptions Agencies of the states

or consisting of POP granted under Annex V, part 2 (Article 7 responsible for waste
(4b)

Dr. Heike Kaupp

*http://www.pops.int/documents/implementation/nips/submissions/Germany_NIP.pdf Senate Department for Health, Environment and Consumer Protection 7
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

850/2004/EG: Division of Responsibilities between

Federal and Länder Level in Germany
850/2004 Addressees
Release Release inventories for Agencies of the states
inventories -PCDD/PCDF, PCB, HCB, PAH
for POP -Emissions to Air, Water bodies, Soil (Article 5 a, i):
Anthropogenic The COM and Member States establish in close Agencies of the states
impact on the soil cooperation appropriate programmes and
Environmental mechanisms, consistent with the state of the art, Agencies of the states
quality (air) for the regular provision of comparable monitoring + federal/state agreement
data on the presence of dioxins, furans and PCB (Oct. 1994)
as identified in Annex III in the environment.
(Article 9)
Dioxins and PCB Agencies of the states
in the environment + federal/state agreement
(March 1996)

Dr. Heike Kaupp

*http://www.pops.int/documents/implementation/nips/submissions/Germany_NIP.pdf Senate Department for Health, Environment and Consumer Protection 8
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Competent Authorities
Responsible National Autority
• POP: Federal Institute for Occupational Safety and Health (BAuA)
• plant protection products: Federal Office of Consumer Protection and Food Safety (BVL).
• biocide products: Federal Institute for Occupational Safety and Health (BAuA)

Designated Competent Autority to cover the provisions of the Stockholm Convention

- Federal Institute for Occupational Safety and Health (BAuA) and
- Federal Environmental Agency (UBA)

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 9
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Conclusion 2

In a federal state the collection of comparable data to fulfill a reporting obligation

requires a high level of communication and coordination.

For routine tasks technical solutions can make things easier.

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 10
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Example: PRTR
• Due to Comission Decision 2000/479/EC (based on Art. 15 of the IPPC directive) a
Pollutant Emission Register (EPER) was established at European level for large
stationary sources.

EPER includes obligations to report annual emissions of PCDD/Fs (1 g TEQ/a), HCB

(10 kg/a) and PAHs (50 kg/a).

EPER is being upgraded to the Pollutant Release and Transfer Register (PRTR), which
also includes PCBs (100 g/a); this process shall be finalised in 2009.

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 11
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

Differences between EPER and PRTR

Source: www.home.prtr.de
Dr. Heike Kaupp
Senate Department for Health, Environment and Consumer Protection 12
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

PRTR-Protocol
The obligation to develop a national PRTR leads back to the Protocol on Pollutant
Release and Transfer Registers (PRTR-Protocol).

It was signed by 36 states, including Germany, and the EC at Kiev, 21. May 2003. The
PRTR-Protocol is a protocol under the Aarhus Convention.

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 13
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

PRTR: Division of Responsibilities in Germany

According to the German law for the implementation of the protocol on pollutant
release and transfer registers of 21. May 2003 and the directive 166/2006
(SchadRegProtAG)
Establishing and maintaining a publicly accessible, internet based Federal Environmental Agency
pollutant release and transfer register
Incorporation of the information into the register Federal Environmental Agency
Presentation of the information in the register in aggregated and non- Federal Environmental Agency
aggregatet form, so that releases and transfers can be searched for /
identified by facility, location, activity, owner/operator, pollutant/waste,
environmental medium, release from diffuse sources
Transfer of the information / the reports of the operators in electronic form Responsible state authority
to the Federal Environmental Agency
Electronic transmission of the data to the responsible authority Operators of facilities which
undertake relevant activities

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 14
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

German ePRTR
• Germany is about to take into routine operation a national PRTR using data reported
to the E-PRTR and including data on emissions from diffuse sources.

• The German ePRTR is an electronic, web based system for the annual data
collection, the plausibility check and the publication of PRTR data as well as for the
reporting for E-PRTR towards the European Union.

• To realise this project the Federal Government and all States established the
cooperation „Elektronisches PRTR (e-PRTR)“ which is coordinated by the Federal
Environmental Agency.

• The aim of the project was the development of a uniform software ("BUBE-Online",
Betriebliche Umweltdatenberichterstattung) for the all reporting obligations determined
by PRTR, 11th Federal Immission Protection Regulation (11. BImSchV, Emission
reporting) and 13th Federal Immission Protection Regulation (13. BImSchV, large
combustion plants) and to integrate further obligations for future reporting.

Dr. Heike Kaupp

www.home.prtr.de Senate Department for Health, Environment and Consumer Protection 15
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

German ePRTR
• Electronic processing of reporting:
- data input by the operators,
- quality assessment by the competent
authorities,
- the compilation of the data at the
Federal Environment Agency, including
the publication of the national register
and the data transmission to the EC

Dr. Heike Kaupp

Source: www.home.prtr.de Senate Department for Health, Environment and Consumer Protection 16
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

German ePRTR

Dr. Heike Kaupp

Source: www.home.prtr.de Senate Department for Health, Environment and Consumer Protection 17
 Reporting Requirements under Regulation 850/2004/EC
- Experiences from Germany -

THANK YOU
FOR YOUR ATTENTION!

Dr. Heike Kaupp

Senate Department for Health, Environment and Consumer Protection 18