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EU Proposes Ban on Three POP Chemicals

SafeGuardSHardgoods, Electrical & Electronics, Personal and Protective Equipment, Softlines, Toys and Juvenile Products, Cosmetics & Personal Care, AutomotiveDecember 02, 2025

SG 175/25

The European Union (EU) is consulting on three draft laws to revise its legislation on persistent organic pollutants (POPs).

In May 2025, the twelfth meeting of the Conference of the Parties to the Stockholm Convention (SC COP-12) added chlorpyrifos (SC-12/9), medium-chain chlorinated paraffins (MCCPs, SC-12/10) and long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and LC-PFCA-related compounds (SC-12/12) to Annex A (elimination) of the Stockholm Convention on POPs, with specific exemptions.

On November 21, 2025, the European Commission announced three separate consultations on the proposed listing of chlorpyrifos and MCCPs, as well as LC-PFCAs (aka C9-21 PFCAs), their salts and LC-PFCA-related compounds (aka C9-21 PFCA-related compounds) under Part A of Annex I to Regulation (EU) 2019/2012 on persistent organic pollutants (POP Recast Regulation, consolidated version to October 2025).

According to the draft regulations:

  • ‘MCCPs’ are defined as substances or mixtures containing linear C14-17 chloroalkanes with the following formulae:
    • C14H(30-y)Cly, where y ≥ 5
    • C15H(32-y)Cly, where y ≥ 5
    • C16H(34-y)Cly, where y ≥ 6
    • C17H(36-y)Cly, where y ≥ 6
  • ‘C9-21 PFCAs’ means linear and branched PFCAs with the formula CnF2n+1COOH, where 8 ≤ n ≤ 20
  • ‘C9-21 PFCA-related compounds’ are substances that may degrade or transform into C9-21 PFCAs

To reinforce the application and enforcement of Article 3(1)(b) to the POP Recast Regulation, unintentional trace contaminant (UTC) values have been set for these three POP chemicals in substances, mixtures and articles.

Highlights of these three draft regulations to amend Part A of Annex I to the POP Recast Regulation are summarized in Table 1.


Substance Scope Specific exemption on intermediate use or other specification Proposed effective date
Chlorpyrifos
  • Substances
  • Mixtures
  • Articles
≤ 0.01 mg/kg 20 days following its publication in the Official Journal of the EU (OJEU)
MCCPs
  • Substances
  • Mixtures
  • Articles
≤ 1,000 mg/kg (sum)* Date of entry into force of the amendment to the Stockholm Convention
C9-21 PFCAs and their salts
  • Substances
  • Mixtures
  • Articles
≤ 0.025 mg/kg (sum)* 20 days following its publication in the OJEU
C9-21 PFCA-related compounds ≤ 0.26 mg/kg (sum)*
*Certain derogations apply

Table 1

Comments will be accepted for each of the three draft regulations until December 19, 2025.

These regulations are intended to be adopted in Q2 of 2026.

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