Intervention on chlorpyrifos, presented by Dr. Samarys Seguinot Medina, April 28 2025

Thank you, Madame President. 

My name is Dr. Samarys Seguinot Medina, and I am a Boricua from Boriken/Archipelago of Puerto Rico. I’m an environmental and public health scientist working in the Arctic for the past 16 years. I am making this intervention on behalf of Alaska Community Action on Toxics, a participating organization of the International Elimination Pollutants Network (IPEN). IPEN is a network of 676 organizations in 131 countries.

Science is clear and overwhelming concerning the severe health harms of the insecticide chlorpyrifos, particularly on the developing brains of children. A statement of 38 preeminent scientists from Project TENDR with expertise in toxic chemicals that harm the developing brain declared: “We are writing in support of listing chlorpyrifos as a persistent organic pollutant (“POP”) under Annex A of the Stockholm Convention with no specific exemptions. Based on decades of scientific evidence of harm, we believe chlorpyrifos should be eliminated from use worldwide to protect children’s developing brains from lasting impacts.”

Health impacts from chlorpyrifos exposure have been documented in many countries. There is a significant cost to society and public health from the continued use of chlorpyrifos associated with lost IQ and other neurodevelopmental harm, including loss of intellectual potential and lifetime productivity, health care costs, and costs associated with care for those with resultant developmental and learning disabilities.

The States must comply with the intent and mandate of the Stockholm Convention. For example, the preamble of the Convention, states: “that the Arctic ecosystems and indigenous communities are particularly at risk because of the biomagnification of POPs and that contamination of their traditional foods is a public health issue.” Rapid climate change of the Arctic is exacerbating the mobilization and transport of POPs, including chlorpyrifos. 

We remind the delegates that the decisions here at COP12 will have significant and lasting impacts now on Indigenous Peoples of the Arctic and communities throughout the globe. Its significantly important to be mindful of the human rights standards including the United Nations Declaration on the Rights of Indigenous Peoples.

Chlorpyrifos has been detected in women’s breast milk in many parts of the world and in traditional foods of Indigenous People. Chlorpyrifos is a highly toxic chemical that has safe alternatives that are available, economically viable, and in use. A complete ban is feasible. Chlorpyrifos is already fully or partially banned in over 50 countries across a wide range of climates, and economic development levels. 

We strongly recommend and emphasize the urgency of listing chlorpyrifos in Annex A without exemptions.

Intervention on waste acid batteries, presented by Tadesse Amera, April 28, 2025

Thank you, Mr. President,

I am giving this intervention as the Executive Director of PAN-Ethiopia, a member of PAN-International and  a participating organization of IPEN

Waste lead Acid Batteries are not the only sources of lead poisoning, but it is one of the major exposure sources especially with 85% lead is used for batteries and 60% of the lead acid batteries are produced from recycling lead.

According to the World Health Organization, lead exposure contributed to over 1.5 million deaths worldwide in 2021 (WHO 2024) and recent health studies conclude that it is one of the most relevant environmental factors impacting public health globally. Children are known to be the worst affected population group as childhood lead exposure causes severe and permanent damage to the brain and central nervous system. While the world community via the United Nations Environment Assembly has committed to take effective steps to reduce lead-exposure from unsound battery recycling in 2017 through UNEA-3 Resolution, the situation is still far from being resolved. on the continent.

While acknowledging the need for recycling capacities for lead-acid batteries, we call for action that focusses onat stimulating a systematic push for improvements in this field and we calls upon all stakeholders to join forces towards the common goal for a safe and healthy environment, as well as fully responsibilityble for end-of-life management of batteries with guidance, that aims to:

·      Strengthening Industry Standards.

·      Empowering Civil Society

·      Recognizezing Responsible Recyclers and

·      Facilitateting Regional Collaboration

• Create and enforce a zero-tolerance policy for polluting recyclers

Thank you, Mr. President.

Intervention on the General Technical Guidelines for POPs Wastes, delivered by Gilbert Kuepouo, Executive Director of Centre de Recherche et d’Education pour le Developpement (CREPD), Cameroon.

Thank you, Madam President, for giving me the floor.

IPEN recognizes the importance of the technical guidelines for the management of POPs wastes and in particular the General Technical Guidelines on the environmentally sound management of POP wastes. The two main features of the General Technical Guidelines are

(1) low POPs levels, which define POPs wastes that must be destroyed or irreversibly transformed to eliminate their POPs characteristics.

and 

(2) a list of proven technologies capable of destroying or transforming this POPs waste.

Unfortunately, some of these technologiesgenerate more unintentional  POPs in emissions and tailings. These are combustion technologies such as incineration and co-incineration in cement kilns, which are proving to be unsuitable for the destruction of PFAS.

The suitability of these technologies for the destruction of POPs wastes should be examined. Technologies other than combustion that do not generate other POPs are also mentioned in thetechnical guidelines.

IPEN is aware that there are several other commercialized non-combustion technologies for the destruction of POPs wastes that are not yet included in the technical guidelines and that their evaluation should be a priorityfor the dedicated Small Intersessional Working Group.

The 2028 deadline for PCB stockpile destruction is approaching and we believe that the widespread implementation of smokeless technologies is now essential to meet this deadline. We encourage the GEF and UN implementing agencies to intensify their programmes to promote smoke-free technologies and to assist countries in phasing out their stockpiles of PCBs.

It is essential to establish ten POPs at the lowest possible levels that protect the environment and human health. In some cases, economic factors have taken precedence over this objective and intent of the Convention, resulting in the adoption of very high concentrations of low levels of POPs. All of which is not in line with the precautionary objectives of the Convention and results in large quantities of wastes contaminated with POPs escaping regulatory controls and being freely subject to transboundary movement as a commodity. It also allows the contamination of toys through recycling and locally grown food on soils amended with ash containing POPs, as demonstrated by a number of studies conducted by IPEN.

Based on these facts, we call for constructive engagement by all delegates to establish low levels of POPs that are much more protective. In particular, IPEN suggests adopting a low POPs content of 10 mg/kg for dechlorane plus and 15 mg/kg for UV-328.

Thank you.

IPEN Intervention on Used and Waste Pneumatic Tyres Technical Guidelines presented by Dr. Leslie Adogame

April 28, 2025

Thank you, Madam President.  

I am giving this intervention as the Executive Director of SRADeV Nigeria, a participating organisation of IPEN. I speak on behalf of IPEN, a global network of public interest, civil society organizations in more than 120 countries.

Madamr. President, waste tyre or materials recovered from waste tyres are known to generate potential impacts on human health and the environment, some of which are still being further investigated. However, the scope of the present technical guidelines is still largely inadequate to provide the required guidance on the environmentally sound management (ESM) of used and waste pneumatic tyres. 

IPEN believes some key issues still need to be addressed which include: 

Ensuring and making the synthetic polymer content and the chemical content of tyres transparent e.g. PFHXs, 6PPD-Quinone, and its devasting impacts on certain fish species.

The need to include tyre wear particles (microplastics) in the guidelines as waste material. 

Toxicity, leaching and emissions need consideration in the recycling process and then in subsequent use.

In fact, there is considerable evidence that Chemical Recycling of tyres via pyrolysis or gasification is not ESM if maintaining consistency with the plastic waste technical guidelines, particularly, when energy consumption, climate impacts, and all forms of residual pollution is taken into account. Similarly, are the ESM concerns of used and waste tyres in co-processing industrial activities such as - tyre derived fuel, cement kiln combustion etc.

Madame President, more work is needed to finalize the guideline to ensure that it contains sufficient information about hazardous chemicals, health and safety, and remediation of contaminated sites. Therefore, the mandate of the Small Intersessional Working Group (SIWGs) should be extended to incorporate these concerns.  

Intervention on MCCPs, presented by Pamela Miller, Alaska Community Action on Toxics Executtive Director and IPEN Co-chair

Thank you, Madame President.

My name is Pamela Miller and I serve as Co-Chair of the International Pollutants Elimination Network (IPEN), a network of 676 participating organizations in 131 countries. We support listing of MCCPs in Annex A with no exemptions, using the chemical formula instead of the average chlorination level. There are safe alternatives for all uses.

The issue of MCCPs holds more than a scientific interest for me. I grew up in a small town in Dover Ohio, in the US, the site of a primary manufacturing facility for MCCPs. Our neighborhood and my family has suffered cancers and other health disparities due to the flagrant and illegal discharges to air, water, and land. This is not just a local issue. MCCPs are a major concern for the health of traditional foods and peoples of the Arctic where I now live and work. 

MCCPs are regrettable substitutes for SCCPs (listed under the Stockholm Convention in 2017). Their production now exceeds that of SCCPs and they are frequently measured in higher concentrations in the environment.  MCCPs are found in biota of remote regions, including the Arctic and Antarctic, including seabirds, seals, whales, and polar bears. The levels of MCCPs observed in polar regions are higher than some listed POPs such as polybrominated diphenyl ethers (PBDEs), and SCCPs. 

MCCPs are found in the breast milk of women throughout the world. MCCPs are now the most abundant of the chlorinated paraffins in breast milk. This is a terrible injustice and violation of human rights. 

MCCPs are used as flame retardants, plasticizers, sealants, and in metal cutting fluids. They are found in household products that can result in human exposures including hand blenders used for making baby food, toys, ovens, cable sheathing, adhesives, and food. An IPEN study found MCCPs in all toys tested from 10 countries. 

MCCPs are toxic to aquatic animals. In humans, they adversely affect the liver, kidney, thyroid, and are developmental toxicants.

The time is long overdue for the elimination of this harmful chemical that has contaminated the global environment, including remote regions of the world. We recommend listing MCCPs in Annex A with no exemptions.

Intervention on LC-PFCAs presented by Sonia Buftheim, Nexus3 Foundation, Indonesia, and IPEN Youth Caucus Co-chair

Thank you, Madame Chair,

I am Sonia Buftheim, I am speaking on behalf of the Nexus3 Foundation Indonesia, an IPEN participating organisation, and the IPEN Youth Caucus.

We are pleased to see another group of PFAS chemicals recommended for listing under the Stockholm Convention. This group approach is the most effective, precautionary, and practical method for protecting health and the environment.

Long-chain PFCAs have been detected on every continent and in all parts of the environment. They do not degrade and cause serious health effects. Critically, they pass through the placenta and breast milk, meaning babies are born already pre-polluted, with lifelong impacts from infancy.

As youth, we are alarmed. We are witnessing rising cancer rates among young people, reproductive health problems in young couples, and growing hormonal disorders. In the Global South, weak healthcare systems often fail to recognise the connections between environmental exposures and non-communicable diseases.

Recent IPEN studies show long-chain PFCAs are widely found in consumer products such as clothes, food packaging, and recycled materials. Continued use will escalate contamination, expose consumers and workers, and drive up society’s costs for waste management, remediation, and healthcare.

It is also crucial that these PFAS chemicals are not replaced with other PFAS chemicals, as we have seen happening far too often. Therefore, the COP should adopt a similar recommendation to not use PFAS alternatives as was done previously for PFOA and PFHxs, and as recommended by the POPRC.

The science is clear: safer alternatives already exist, and the benefits of global action far outweigh the costs. We must not repeat the mistake of replacing these harmful chemicals with other PFAS.

On behalf of the IPEN Youth Caucus, we strongly support listing long-chain PFCAs, their salts, and related compounds in Annex A without exemptions. 

Please do not sacrifice our future for your profits.

Intervention opposing exemptions to the listing of UV-328 presented by Yuyun Ismawati, IPEN Co-chair

Thank you, Madame President.

I am Yuyun Ismawati, the IPEN co-chair. 

The proposal to reopen the COP's previous decision to add a new exemption is unprecedented in the history of the Stockholm Convention. It would jeopardise the convention's integrity and undermine its objective of protecting human health and the environment from POPs.

This call would create a dangerous precedent for the Convention, which may have several significant consequences, including:

• First, conveying messages that no listing can be regarded as final. This would diminish the effectiveness of the Convention and create uncertainty for policymakers, manufacturers, and waste management sectors.
• Second, increasing administrative burdens strain the Convention's resources and undermine the effective use of project resources such as GEF funding. 
• Third, it would disadvantage companies and countries that have initiated or finalised the phase-in of safer alternatives. 

We all know that the aviation industry, particularly the military, has the capacity and ample resources to transition to safer alternatives. No excuses.

Supporting and enforcing the discontinuation of UV-328 will catalyse advancements in sustainable practices and materials in this sector.

Doing this will honour our commitment to the Stockholm Convention and reaffirm our promise to eliminate POPs.

Therefore, IPEN recommends that the listing of UV-328, as decided by the 11th Conference of the Parties in 2023, remain closed to new exemptions.

IPEN Intervention on finance presented by Gohar Khojayan, Armenian Women for Health and Healthy Environment (AWHHE) and IPEN Steering Committee member

Thank you, Madame President. I am making this statement on behalf of IPEN. 

The projected cost of comprehensively addressing POPs currently covered by the Stockholm Convention is estimated at US$ 18,332 million between 2026–2030. Additionally, several new POPs are in the process for listing under the Convention and will also require funding. For comparison, the GEF-8 replenishment included $413 million allocated to the Stockholm Convention for 2022 – 2026.

• Economic instruments to recover costs from companies that have produced POPs and/or countries in which they are based should be explored to operationalize the polluter pays principle. For many POPs, a relatively small number of companies have externalized enormous costs onto governments and the public that should be recovered.

• The COP should encourage a process for the Special Programme to enable access to funding for public interest NGOs for activities in line with Programme objectives, noting the important role of NGO contributions to Convention implementation and institutional strengthening.

Thank you, Madame President.

Intervention on contaminated sites, presented by Piyush Mohapatra of Toxics Link, India

Thank you Madam President. 

I speak on behalf of the International Pollutants Elimination Network (IPEN). 

A key measure  to reduce or eliminate releases from POP wastes is the identification and remediation of POP  contaminated sites. Globally there are tens of thousands of POP  contaminated sites that pose a risk to the health on millions of people and the environment while creating an ongoing source of POPs releases. POP PFAS contaminated sites are especially problematic due to the high solubility of PFAS which allows it to travel much more  rapidly through ground and surface water than other POPs. IPEN has created an online map of global POPs contaminated sites with a visual representation provided at the IPEN booth which we encourage interested parties to view.

For Parties to address POP contaminated sites, clear, practical guidance is needed to identify, inventory and then remediate such sites to reduce exposure risks and environmental harm.                   

IPEN welcomes the guidance finalised by the BAT BEP Expert Group on best available techniques and best environmental practices for the management of sites contaminated with persistent organic pollutants that addresses the key issues facing many countries seeking clean up POP contaminated sites.  While the guidance is not legally binding it provides a comprehensive, risk based, phased approach for countries seeking to establish a new framework for contaminated sites management or improve their existing framework. 

Importantly the guidance covers more than technical issues and provides clear guidance on policy, legislative and financial approaches to site identification and remediation. It is time to accelerate the depollution of the planet and clean up  the legacy of POPs contamination.  The BAT BEP  Guidance contributes significantly to this task and we encourage parties to welcome the guidance at this COP.

IPEN intervention on PCBs, presented by Aileen Lucero, EcoWaste, Philippines

Thank you Madam President

I am from Ecowaste Coalition in the Philippines and I am making this intervention in behalf of IPEN

The issue of PCB stockpile destruction is becoming urgent. This year we have reached the deadline for the phase out of any remaining PCBs in use yet there is still a significant volume of PCBs being used – particularly in PCB transformers in private ownership. The deadline for destruction of all stockpiles of PCBs is 2028 yet recent studies indicate that only around 20% of stockpiles have been destroyed leaving an estimated 10 million tonnes of PCB containing materials to be destroyed. 

For decades there has been an overreliance on combustion technology such as incineration of PCBs and co-processing PCB waste in cement kilns. This approach has not delivered. Not only does this approach require PCB wastes to be transported great distances to fixed combustion facilities, increasing transport and insurance costs, but these facilities continue to emit dioxin like PCBs in emissions and in residues like bottom and fly ash. However, non-combustion technologies that do not have emissions or residues of unintentional POPs  also have the advantage of being relatively small, modular and transportable. This allows the destruction technology to be transported to the PCB stockpile avoiding  waste transport risk and insurance fees. These technologies have the capacity to be rolled out at large scale and to accelerate the destruction program for PCBs.

PCB manufacture and sales made hundreds of millions of dollars for the manufacturers of these toxic chemicals and they should be held accountable for the PCB legacy and the polluter pays principle should be applied to help raise the funds to support destruction.  While the new funding strategy for PCB destruction is important – those funds should not be used to perpetuate polluting combustion technologies like incineration,  but should be applied to sustainable, effective non-combustion technologies to ensure we end the legacy of PCB pollution forever.

Intervention on DDT, presented by Ram Charitra Sah, Center for Public Health and Environmental Development (CEPHED), Nepal

Thank you Madam President 

I am speaking on behalf IPEN              

DDT was one of the initial “Dirty Dozen” POPs listed in the Stockholm convention in 2001,  with the specific purpose of vector control. Today, very few countries are using DDT since  there are effective, safer and environment friendly   alternatives  available globally.  India, which is the only remaining producer of DDT, has successfully transitioned to  alternatives. 

Therefore, the remaining countries still using DTT should  shift to the alternatives and ensure the world successfully becomes DDT free. We have witnessed the success story in India and other countries, providing good examples of how the remaining countries also  can completely eliminate the use of DDT.

Finally, effective non combustion technologies are widely available and should be used for the disposal of stockpiles of DDTs.

Intervention on the proposed exemption for PFOA in firefighting foam, presented by Pamela Miller, IPEN Co-Chair

Thank you Madame President.

We are concerned about this proposed exemption because this would be another dangerous precedent for the Convention after the chemicals are listed. We also recognize that there are many safe fluorine free alternatives available and in use world wide at major airports, military bases, oil and gas facilities.

There are also options for the safe destruction of PFAS based firefighting foams. Continued use of PFAS-based firefighting foams threaten drinking water and public health, with increasing liabilities for clean up and health costs. IPEN has convened a global panel of experts from manufacturing, the firefighting community, public health experts, oil and gas industry—and produced several reports.

We stand ready to assist in the safe transition to fluorine-free foams.

The safe solutions are available, economically viable, and possible for immediate transition. 

Intervention on National Implementation Plans, presented by Mari Carcamo, RAPAL Uruguay

May 1, 2025

Thank you Madam President,

I am speaking on behalf of Rapal Uruguay, a Participating Organization of IPEN.

National Implementation plans are the basis for effective implementation of the Convention. However, Parties are severely lagging behind in fulfilling their obligation to submit and update National Implementation Plans (NIPs). For the POPs listed in 2019, 87% of Parties still need to submit their NIPs.

Civil society plays a crucial role in implementation of the Convention. Parties have obligations to ensure meaningful multi-stakeholder consultation in the design and implementation of NIPs to enable an effective, inclusive, and regular public participation process.

In addition, national implementation plans are key to gather information about POPs and make this information publicly available, as required under the Convention. However, there is a significant lack of information on the quantities of POPs produced, imported, exported, and disposed of. 

Finally, updated NIPs and Increased reporting would allow for better assessment of the effectiveness of implementing the Convention.

intervention on Further Consideration of Plastic Waste, presented by Anna Odur, Association of Uganda Professional Women in Agriculture and Environment

May 2, 2025

Thank you, Madame President

My name is Anna Odur from the Association of Uganda Professional Women in Agriculture and Environment, a Participating Organization of IPEN. I am speaking on behalf of IPEN.

IPEN participating organizations have become increasingly concerned by the growth of trade in plastic waste fuels, known as Refuse-Derived Fuel (RDF). 

The high potential of RDF to generate chlorinated and brominated dioxins and other POPs when burned requires a thorough and transparent scientific assessment of the health and environmental impacts associated with burning RDF. The burning of plastic waste as fuel releases large volumes of toxic air pollutants, exacerbating the existing global pollution crisis. It also entrenches the escalating production of plastic and export of plastic waste to countries where it should be prohibited by the Basel Ban amendment. As the hazards associated with plastic waste fuel and RDF technology are not publicly disclosed, substantial risks and threats to public health and the environment are imminent.

IPEN supports the proposed additional work on plastic waste. A Small Intersessional Working Group should be created to evaluate the effectiveness of the plastic waste amendments, to classify refuse-derived fuel (RDF) as plastic waste rather than a product or non-waste. This is an opportunity to conduct a review and amendment of specific Basel POP waste technical guidelines as they relate to plastic wastes and its transboundary movement.  

>The Group should discuss assigning a new, specific waste code to RDF to track its trade, recommend controls of synthetic textile wastes, and remove the exemptions for specific polymers that cannot be recycled. Until a specific code is created for RDF, both RDF and synthetic textile wastes should be labelled as  ‘other plastic wastes’ (Y48) or hazardous plastic wastes (A3210) covered by the prior informed consent procedure for transboundary movement and allowing this waste type to be tracked. Also, it is important to remove exemptions in Y48 for fluoropolymers, cured resins, and condensation products that cannot be recycled in an environmentally sound manner after use.

Until this effectiveness evaluation is conducted, the plastic waste technical guidelines should remain as adopted by the COP in 2023. IPEN believes that opening up the plastic waste technical guidelines is premature until the evaluation is complete.

Statement on the Outcomes of Contact Groups, Presented by Pamela Miller, IPEN Co-chair

Thank you, Madame President. We are intervening concerning the previous agenda item on the outcomes of the contact groups and draft decisions. I speak as co-chair of IPEN and on behalf of 676 public interest NGOs in 131countries. We have traveled from countries from all regions throughout the world to participate constructively in the deliberations of the Stockholm Convention this week. We represent our communities and the people who cannot be here to represent themselves.

We are deeply disturbed about actions we have witnessed this week that we believe undermine the integrity of the Convention and the science that must be its foundation, the spirit and intent to protect the health of women, children, workers, Indigenous peoples, and future generations. 

The work of the Convention’s expert committee has been undermined this week with the extensive number of exemptions introduced in contact groups for the proposed list of chemicals. These proposed exemptions were introduced by Parties here at the COP and circumvented the scientific review process and recommendations of the POPRC which we have participated in since the beginning.

We call upon Parties to consider the implications of your decisions this week. 

The Convention is vital to protect human health and the environment. Exemptions perpetuate harm to children, women, workers, communities, and Indigenous peoples of the Arctic and globally. Instead, your actions this week clearly protect the interests of industry. 

You have a responsibility to ensure justice, health, human rights, our existence and that of future generations.

Intervention on mercury listing, Rotterdam Convention, by Sounkoura Adetonah, Groupe d’Action pour la Promotionetla Protection de la Flore et la Faune (ONG-GAPROFFA), Benin

Thank you, Mr President:

I am Sounkoura Adetonah and I speak on behalf of IPEN.

Mercury is a highly toxic metal, and the global community has adopted the Minamata Convention on Mercury to protect human health and the environment from mercury. However, mercury use has been exempted in certain products, considering the needs and requirements of each country.  

While there are some restrictions on the trade of mercury depending on the source of the mercury, it can still be traded for allowable uses under the Minamata Convention. There is a growing problem with mercury being shipped for use in products and industrial processes but then being diverted illegally into small scale gold mining causing widespread pollution  thus undermining the objective of the convention to protect human health and the environment from mercury. Much tighter controls on mercury trade are required such as prior  informed consent and tracking of mercury volumes and destinations.

Considering this, IPEN supports listing mercury as elemental mercury in the Rotterdam Convention Annex, which we believe will bring transparency to the mercury trade.

Intervention on chlorpyrifos listing, Rotterdam Convention, Fernando Bejarano, Executive Director, RAPAM (Pesticide Action Network in Mexico)

I am Fernando Bejarano, Executive Director of RAPAM (Pesticide Action Network in Mexico), and I am giving this intervention on behalf of  IPEN.

Chlorpyrifos is a highly toxic pesticide that harms the brain development of children even at very low concentrations. Harm to farming communities and ecosystems is well documented in many countries, leading to significant social costs in addition to the human suffering.

Almost 50 countries have already banned or severely restricted the use of chlorpyrifos. The Rotterdam Chemical Review Committee has also determined that all the requirements for listing in Annex III to the Rotterdam Convention have been met, and has recommended its for listing. 

Government have already reached a consensus to list chlorpyrifos under the Stockholm Convention for global elimination. However, a long list of exemptions was included in this decision. It is therefore important that Parties to the Convention get the support from the Rotterdam Prior Informed Consent Procedure to ensure that chlorpyrifos is only traded if the importing country provides an informed consentan informed consent is provided by the importing country and only for allowed uses to ensure compliance. Also, the information requirements under the Rotterdam Convention areis crucial to ensure that safeguards to protect human health and the environment are implementedput in place for exempted uses. 

IPEN therefore call on Parties to list chlorpyrifos in Annex 3 of the Rotterdam Convention.

Intervention on effectiveness evaluation, presented by Lia Esquillo, IPEN Program Director

For many years, we have seen attempts to weaken the listing process of the Rotterdam Convention and undermine the Chemicals Review Committee under the guise of “enhancing the effectiveness”. These have been accompanied by demands for consideration of issues that are not criteria of the Convention, such as trade, socio-economic analysis and availability of alternatives. These have also been used as excuses for blocking the listing of chemicals for two decades, including at this Conference of the Parties, despite verification from the CRC that these meet all Convention criteria and recommendations for listing.

This continued opposition to listing chemicals undermines the regulatory actions of countries and their sovereign right to control what enters over their borders and into their markets, and hinders countries to fulfill their obligations to protect the human right to a clean, healthy, and sustainable environment, including a safe and healthy working environment. This is the real obstacle for the Rotterdam Convention to effectively meet its objective of protecting human health and the environment.

The actions in CRP 4 aiming at influencing processes under WHO and FAO, as well as in private standard-setting bodies and certification schemes, are outside the mandate of the COP and should be rejected. Also, given the high cost of establishing a new committee and the very limited resources available, this proposal should be rejected. Therefore, IPEN do not support CRP 4.

Intervention on SC Technical Assistance, presented by Elham Refat

Thank you, Chair, for the opportunity to take the floor on this important agenda item.

IPEN underscores the critical importance of robust, well-coordinated technical assistance in advancing the objectives of the Stockholm Convention, particularly for developing countries and countries with economies in transition facing growing challenges related to the management of newly listed POPs, industrial chemicals, and unintentional POPs to achieve their commitments.

In this context, we wish to highlight the following key points:

IPEN emphasises that technical assistance must include stockpile elimination, environmentally sound disposal, and public health risk communication. 

Mechanisms for technical assistance and technology transfer must be strengthened and prioritised to eliminate listed POPs and effectively phase in alternatives. IPEN strongly supports the promotion of safe, non-chemical alternatives to persistent organic pollutants (POPs), with particular emphasis on their application in agriculture, vector control, and industrial processes. 

Considering the large remaining stockpiles of PCBs, DDT, and other POPs, Regional Centres should conduct training on non-combustion methods of destruction that meet Convention requirements as a high priority. In addition, Regional Centres should increase the involvement of public-interest NGOs and civil society in their work through direct participation in the design and implementation of projects. This criterion should be included in their evaluations and reporting.

Intervention on synergies in combatting illegal traffic and trade, presented by Semia Gharbi, IPEN Steering Committee member and founder and Chairperson of Tunisia's Association de l'Education Environnementale pour les Futures in Tunisia

Thank you, Madame President,

I am speaking on behalf of IPEN.

In my country Tunisia, I have seen the arrival of illegal waste from developed countries, although the Basel Convention has plastic waste amendments.. It took two years after national and global efforts to return to sender. In another country, it took 6 to 9 years to return the illegal shipments to the exporting countries. The unwanted waste is usually illegally dumped, burned in open space, or incinerated.

IPEN welcomes the work on synergies between the Conventions and calls for more harmonisation to combat illegal traffic and the trade in hazardous chemicals and wastes. IPEN recommends the following points:

First, Parties to the Rotterdam and Stockholm Conventions should provide information about illegal traffic and trade cases to be made available on the website.

Second, Parties to the Basel Convention must fulfil their legal obligations not to export or import illegal waste and must report all such shipments.

Third, Parties should end the export of banned substances in their own countries and prevent their manufacture in other regions. 

Fourth, continue the effort and transparency track to detail the World Customs Organization's coding system by identifying all chemicals present in products and wastes. 

Finally, support and work closely and sustainably with the regional Conventions, such as the  Bamako Convention for Africa, to strengthen the implementation of the Basel Convention. 

Intervention on mainstreaming gender equality, presented by Maimouna Ndye

Thank you, Madame President

Continued efforts should be supported to ensure that gender considerations are an integral part of the implementation of all the policies, programmes, and activities under the BRS Conventions. Equal participation should be upheld in local, regional, and global decision-making. 

The BRS Conventions can more effectively address the intersection of women and chemicals by systematically integrating gender analysis into national implementation plans, policy development, and reporting mechanisms. This includes collecting sex-disaggregated data on chemical exposures, especially in high-risk sectors such as informal waste management and agriculture where women are overrepresented. 

Parties should incorporate gender-responsive risk assessments and prioritize the phase-out of hazardous chemicals that disproportionately affect women’s health. Policy frameworks developed under the Conventions should mandate gender impact assessments and include gender-specific objectives and indicators in National Implementation Plans. 

National legislation should reflect differentiated exposure pathways and health outcomes for women, particularly among vulnerable groups such as pregnant women, indigenous women, and those in the informal economy. Capacity-building programs should target women workers and community leaders, and BRS regional centres can serve as platforms for gender-focused research and exchange. 

Finally, strengthening collaboration with networks like IPEN and its participating organizations, which document and advocate on gendered chemical impacts, will help ensure that BRS implementation advances both chemical safety and gender equality.

Intervention on CRP 2, presented by Rafael Eudes, Aliança Resíduo Zero, Brasil

Thank you Mr. President.

We are deeply concerned by the proposal from CRP 2 to amend the Rule 16 of the Rules of Procedure. This proposal not only undermines the integrity of the Rotterdam Convention but threatens the core principles on which this Convention was founded and would encourage and reward the continued unjustified blocking of chemicals for listing.

Let me be clear: listing chemicals in Annex III of the Rotterdam Convention is not a ban and it is not a restriction. It is a tool for transparency and informed decision-making. By failing to list a substance that meets the criteria laid down in the Convention, Parties are deprived of their right to receive information on substances that enter their own countries and its risks. Farmers, workers, vulnerable populations and consumers - the ones least equipped to access independent information - will remain in the dark about the dangers they are facing without this global mechanism. This includes developing countries without the proper resources to conduct comprehensive risk assessments.

Allowing it to fall off the agenda because of repeated political deadlock sends the dangerous message that vested interests and corporate capture can override both CRC work and wiliness of donor countries. 

Moreover, allowing non-consensus to justify inaction sets a dangerous precedent. It transforms the consensus rule into a veto power, while sidelining the overwhelming majority of countries who want transparency and protection.

Any proposal to undermine the Rotterdam Convention should be rejected. Therefore, IPEN does not support CRP 2.

Intervention on paraquat, presented by Fredrick Otieno, Centre for Environment Justice and Development (CEJAD), Kenya

My name is Fredrick Otieno, and I am speaking on behalf of IPEN.

Listing of chemicals in Annex III of the Convention empowers countries to make rational decisions on the import and export of hazardous chemicals that have been banned or severely restricted based on their risks to human health and the environment. Listing in Annex III does not prevent the trade and use of these chemicals.

Paraquat and paraquat dichloride have been linked to poisonings in many parts of the world, particularly in low and middle income countries. 

Paraquat dichloride should have been listed under the Convention in 2013, as recommended by the CRC. Instead, it has been blocked through six consecutive COPs. This amounts to 12 years of delays, perpetuating harm. Listing of acetochlor, Iprodione, Fenthion and Paraquat has also been  blocked in the previous COPs. 

The long-standing failure by the COP to list highly toxic  chemicals in Annex III is undermining the work of the objectives of the Convention, and allows for continued harm to human health and the environment. Economy and trade should never come before people and environment well-being. These chemicals have been evaluated, found to meet all criteria under the Convention, and therefore recommended for listing by the CRC. 

Therefore, IPEN calls on parties to protect human health and the environment and approve listing these chemicals in Annex III in this COP. This will empower countries to decide whether they want the listed chemicals imported and ensure their safe use.  

IPEN intervention on chrysotile asbestos (RC listing Annex III), presented by Yuyun Ismawati, IPEN Co-chair

Thank you, Mr President.

Asbestos is among the oldest toxic substances traded in the world, and its use dates back to ancient times over 4000 years. It is shameful that we still use and trade it until now. In modern times, chrysotile asbestos is widely recognised for its severe health risks, especially lung cancer, asbestosis, and mesothelioma. Despite the overwhelming evidence supporting its dangers, chrysotile continues to be produced, traded, and used worldwide.

In developing countries, regulatory frameworks may not protect workers and communities from asbestos exposure until the end of its life. Furthermore, vulnerable populations in natural disaster-prone areas and poor settlements suffer from damaged or demolished asbestos building materials.

The PIC procedure is not merely an administrative measure. It is essential to ensure that countries are fully informed of the health risks associated with hazardous substances before they import them. Adding chrysotile to Annex III would empower nations to make informed decisions about its use, facilitate greater responsibility in trade, and ultimately protect workers and public health.

The need for action is urgent. As we reflect on the years of discussion surrounding this topic, it is evident that continued delays in listing chrysotile in Annex III only prolong the risks associated with chrysotile asbestos. We must prioritise the health and safety of our populations over outdated economic interests related to asbestos.

In conclusion, IPEN wants to remind delegates that the Rotterdam Convention’s objective is to protect human health and the environment from the potential harm of certain hazardous chemicals in international trade. We must recognise the scientific recommendations, take decisive action by adding them to the Annex III list, and provide countries with options for choosing safer alternatives. The COP needs to find a way to end the toxic trade and take advantage of the synergies among conventions.

IPEN Closing Statment, presented by Yuyun Ismawati, IPEN Co-chair

Good evening, Presidents and Distinguished Delegates. My name is Yuyun Ismawati, and I serve as Co-Chair of IPEN. 

We commend the listingse of chlorpyrifos, long-chain PFCAs, and MCCPs in Annex A of the Stockholm Convention that set the path to their global elimination. We appreciate the hard work necessary to take global action on these high-use and complex chemicals. Nevertheless, including unjustified and prolonged exemptions without expert committee review compromises the Convention. Exemptions perpetuate harm to children, women, workers, communities, and Indigenous peoples of the Arctic and globally. 

We also commend the inclusion of carbosulfan and fenthion in Annex III of the Rotterdam Convention. However, the continued blocking of chemicals for listing that the expert committee determined to have met the Convention criteria must end. 

We must acknowledge that failing to list these toxic chemicals represents a failure to ensure countries' rights to make informed decisions and protect their communities. Thus, harmful exposures without consent and violations of human rights are allowed. 

We acknowledge the critical decision to establish low POPs content levels for listed chemicals, including deca-BDE, dioxin-like PCBs, and SCCPs. Adopting the contaminated site guidelines is also a significant achievement. This will assist countries in making progress toward the remediation of sites that pose a health threat to communities. 

IPEN also strongly supports strengthening the Bamako Convention because it can significantly enhance protections in Africa against hazardous wastes. The Bamako Convention provides rigorous and innovative obligations. Therefore, enhancing the Bamako Convention will strengthen the implementation of Basel in Africa. 

As we come to a close, we would like to reflect on our collective moral responsibility. We must not sacrifice the integrity of these Conventions to shield the profit-seeking interests of corporations. Instead, producers need to internalise the cost now borne by the public. The polluters pay principle needs to be operationalised. Our ultimate and collective responsibility is to protect the health of the most vulnerable. 

We look forward to the opportunity to work constructively and collaboratively with you. Thank you, Presidents and delegates. Best wishes to all as you return home.