Ref. Ares(2022)871614 - 07/02/2022
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
ENVIRONMENT
Directorate B - Circular Economy & Green Growth
ENV.B.2 - Sustainable Chemicals
Brussels,
ENV/B.2
Marie Milet,
1 Long Lane,
London
United Kingdom
SE1 4PG
Sent by email with acknowledgement of
receipt:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
Dear Ms Milet
Subject:
Your application for access to documents – Ref GestDem No 2021-7504
We refer to your e-mail dated 1 December 2021 in which you make a request for access to
documents, registered under the above-mentioned reference number. We would like to sincerely
apologise for the delay in our reply.
You requested access to: “
documents which contain the following information:
All documentation, including but not limited to attendance lists, agendas, background papers,
minutes/notes and email correspondence about or summarising, the following:
1. Meeting titled “Chemical recycling and mass balance” between the representatives of CEFIC
and the DG of Environment (ENV) representative Florika Fink-Hoojier on 07/09/2021.
2. Meeting titled “REACH” between CEFIC representatives and DG of Environment (ENV)
representative Daniel Calleja, on 04/02/2020.”.
With regard to your request, please see enclosed a copy of the document identified as falling within
its scope:
- Briefing Note referring to the meeting of Director-General Florika Fink-Hooijer with CEFIC
representatives on 07/09/2021 on the issue of chemical recycling and mass balance, with two
annexes: a letter from CEFIC referring to the organisation of the meeting of 07/09/2021 and the
CVs of the participants.
Having examined this document under the provisions of Regulation (EC) No 1049/2001 regarding
public access to European Parliament, Council and Commission documents, we have come to the
conclusion that complete disclosure is prevented by the exception concerning the protection of
privacy and the integrity of the individual outlined in Article 4(1)(b) of Regulation (EC) No
1049/2001, because it contains the following personal data, which have been redacted:
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
-
the names and contact information of Commission staff members not pertaining to the senior
management;
-
the names of other natural persons;
-
other information relating to identified or identifiable natural persons (CVs)
In your application, you indicate that your address is in the United Kingdom. Transfers of personal
data from the Commission to countries that are not members of the European Economic Area
(EEA), or to international organisations, are regulated under Chapter V of the Data Protection
Regulation1.
According to Article 47(1) of this Regulation, a transfer of personal data to a third country or an
international organisation may take place where the Commission has decided that the third country,
a territory or one or more specified sectors within that country, or the international organisation in
question, ensures an adequate level of protection and where the personal data are transferred solely
to allow tasks within the competence of the controller to be carried out.
Based on the information available, the country of your residence is recognised by the Commission
as ensuring an adequate level of protection. However, we would further like to inform you that
Article 9(1)(b) of the Data Protection Regulation does not allow the transmission of these personal
data, except if you prove that it is necessary to have the data transmitted to you for a specific
purpose in the public interest and where there is no reason to assume that the legitimate interests of
the data subject might be prejudiced. In your request, you do not put forward any arguments to
establish the necessity to have the data transmitted for a specific purpose in the public interest.
Consequently, I conclude that, pursuant to Article 4(1)(b) of Regulation (EC) No 1049/2001, access
cannot be granted to the personal data contained in the identified document, as the need to obtain
access thereto for a purpose in the public interest has not been substantiated and there is no reason
to think that the legitimate interests of the individuals concerned would not be prejudiced by
disclosure of the personal data concerned.
Please also note the following:
- The enclosed Briefing Note was drawn up for internal use under the responsibility of the relevant
officials of the Directorate-General for Environment. It solely reflects the authors’ interpretation and
does not set out any official position of the third parties to which the document refers, which were
not consulted on its content. It does not reflect the position of the Commission and cannot be quoted
as such.
- The letter included as annex in the enclosed Briefing Note originates from a third party which was
consulted for the disclosure of the letter, it is disclosed for information only, and cannot be re-used
without the agreement of the originator. It does not reflect the position of the Commission and
cannot be quoted as such.
1 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of
natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies
and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC,
OJ L 295, 21.11.2018, p. 39.
In accordance with Article 7(2) of Regulation 1049/2001, you are entitled to make a confirmatory
application requesting the Commission to review its position on the matters already mentioned.
Such a confirmatory application should be addressed within 15 working days upon receipt of this
letter to the Secretary-General of the Commission at the following address:
European Commission
Secretary-General
Transparency, Document Management & Access to Documents (SG.C.1)
BERL 7/076
B-1049 Bruxelles
or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
Yours faithfully,
Cristina de Avila
Head of Unit
Electronically signed on 07/02/2022 15:14 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482
