Ref. Ares(2021)6233449 - 13/10/2021
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP
AND SMES
Ecosystems I: Chemicals, Food, Retail
REACH
Brussels,
GROW/F1/KH/nt
grow.f.1(2021) 6995877
Ms Francesca Cicculli
xxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
Subject:
Your application for access to documents
Ref GestDem No 2021/5104
Dear Ms Cicculli,
We refer to your email of 17/08/2021 in which you make a request for access to
documents, registered on 19/08/2021 under the above-mentioned reference number.
Your application was as follows:
“
For the period between 1 January 2017 to date:
- a list of all lobby and industry meetings and/or calls held by the Directorate-General
for Internal Market, Industry, Entrepreneurship and SMEs, including any Cabinet
Members and/or officials, during which “PFAS” and/or “C604” and/or “PFOA” and/or
“GenX” were discussed. The list should include: date, individuals attending and
organisational affiliation, as well as the issues discussed;
- all minutes and other reports of these meetings and/or calls;
- all documents prepared for the purpose of the meetings issued both in preparation and
after the meetings took place.
- all correspondence, including attachments (i.e. any emails, mail correspondence or
telephone call notes) between the Directorate-General for Internal Market, Industry,
Entrepreneurship and SMEs, including any Cabinet Members and/or officials, and any
lobby group and/or industry representative discussing “PFAS” and/or “C6O4” and/or
“PFOA” and/or “GenX”.”
Please note that this letter is the second and last part of our reply.
For this second reply, we have identified 13 documents falling in the scope of your
request. Please see the details in the attached document register.
Please note that, since some of the documents listed in the attached document register
also originate from a third party, the originators have been consulted.
Having examined the documents requested under the provisions of Regulation (EC) No
1049/2001 regarding public access to documents, we have come to the conclusion that
documents 2, 3, 8, 9 and 10, listed in the attached document register, can be fully
disclosed.
Please note that parts of the documents 1, 4, 5, 6, 7, 11, 12 and 13 contain personal data,
which have been redacted.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
A complete disclosure of the identified document 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: the
names/initials and contact information of staff members not pertaining to the senior
management.
Article 9(1)(b) of the Data Protection Regulation1 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
express any particular interest to have access to these personal data nor do you put forward
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 requested
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
In accordance with Article 7(2) of Regulation (EC) No 1049/2001, you are entitled to
make a confirmatory application requesting the Commission to review this position.
Such a confirmatory application should be addressed within 15 working days upon
receipt of this letter to the Secretariat-General of the Commission at the following
address:
European Commission
Secretariat-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 sincerely,
(e-sign)
Giuseppe Caslla
Head of Unit
Encl.: Document register
13 documents (partially) disclosed
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.
Electronically signed on 13/10/2021 11:25 (UTC+02) in accordance with article 11 of Commission Decision C(2020) 4482
2