Document 4YmMNvGmL84gMav7GYd3EJX1
EUROPEAN COMMISSION
DIRECTORATE-GENERAL ENVIRONMENT Directorate B - Circular Economy ENV.B.2 - Safe and Sustainable Chemicals
Ref. Ares(2023)7829799 - 17/11/2023
Brussels,
ENV.B.2
Vicky Cann CEO
By email: ask+request-12815b650f618@asktheeu.org
Dear Ms Cann,
Subject: Your application for access to documents: Ref EASE No 2023/2041
We refer to your request for access to documents dated 31/03/2023, registered under the above-mentioned reference number and our holding reply Ares(2023)2986310. We would like to sincerely apologise for the delay in our reply.
Your application was as follows:
"Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I would like to request access to the following documents related to lobbying on PFAS, per and polyfluoroalkyl substances. In particular I would like:
1. A list of all meetings/ discussions since 1 April 2022 between officials and or Commissioners with businesses, trade associations, or think tanks where this topic was discussed.
2. Any records, minutes or notes of these meetings/discussions.
3. All correspondence since 1 April 2022, where this topic was discussed, exchanged between officials and or Commissioners with businesses, trade associations, or think tanks."
Please note that due to the scope of your request covering also areas falling under the responsibility of other Directorates-General, this reply relates only to the documents held by DG-Environment. You have received the replies from the other respective Directorates-General.
We identified 31 documents falling in the scope of your request. They are listed in the attached register of identified documents.
With regard to documents 1 to 6, listed in the annex, we have come to the conclusion that a 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 they contain the following personal data:
Commission europenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGI - Tel. +32 22991111
- the names and contact information of Commission staff members not pertaining to the senior management; - the names and contact details of other natural persons; - abbreviated signatures of natural persons.
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 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, we 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 documents, 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.
With regards the documents 7 to 15 we note that we have identified them in a reply to a previous case submitted to us in EASE 2022/5764.
With regards the documents 16 to 31 we note that the DG-GROW has identified them in a reply to you in case EASE 2023/2045.
In addition, documents 3 and 6 were drawn up for internal use under the responsibility of the relevant services of the Directorate-General for Environment. They solely reflect the services' interpretation of the interventions made and do not set out any official position of the third parties to which the documents refer, which were not consulted on their content. They do not reflect the position of the Commission and cannot be quoted as such.
Finally, please note that the documents originating from third parties are disclosed to you based on Regulation (EC) No 1049/2001. However, this disclosure is without prejudice to the rules on intellectual property, which may limit your right to reproduce or exploit the released documents without the agreement of the originator, who may hold an intellectual property right on them. The European Commission does not assume any responsibility from their reuse.
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 to the Secretariat-General of the Commission within 15 working days upon receipt of this letter. You can submit it in one of the following ways:
by asking for a review via your portal1 account (available only for initial requests submitted via the portal account),
or by mail:
1 https://www.ec.europa.eu/transparency/documents-request
2
European Commission Secretariat-General Transparency, Document Management & Access to Documents (SG.C.1) BERL 7/076 B-1049 Bruxelles or by email to: sg-acc-doc@ec.europa.eu. Yours sincerely,
Cristina de Avila Head of Unit
Electronically signed on 17/11/2023 10:00 (UTC+01) in accordance with Article 11 of3Commission Decision (EU) 2021/2121