The Latest Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POP) Updates Impacting Retailers

This article is provided by BRC Associate Member, UL Solutions.

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Regulation (EU) 2019/1021 prohibits or restricts the manufacture, placing on the market and use of listed persistent organic pollutants, whether on their own, in mixtures or in articles. Recent amendments directly affect finished consumer products and imported components, not only chemical substances.

Read more in our article and contact Katie.Ellen.Moore@ul.com to learn more about how UL Solutions can help you implementing and improve your chemical compliance strategy.

1.    Chlorpyrifos: an exceptionally low trace limit

Commission Delegated Regulation (EU) 2026/1423 adds chlorpyrifos (CAS 2921-88-2) to Annex I without specific exemptions. The unintentional trace contaminant limit is 0.01 mg/kg, or 10 µg/kg, in substances, mixtures and articles. The measure was adopted on June 30, 2026, published on Sept. 10, 2026 and applies from  Sept. 30, 2026.

The key issue is not intentional use in finished goods, but possible upstream pesticide residues or cross-contamination. Risk assessment may be appropriate for natural and agricultural-origin materials such as cotton and other fibers, leather, wood, cork and plant-based components. At 0.01 mg/kg, laboratories must confirm that the detection and reporting limits are fit for purpose.

2.    PBDEs (Polybrominated diphenyl ethers): tighter controls on recycled materials

Commission Delegated Regulation (EU) 2025/1482 revises the limits for tetraBDE, pentaBDE, hexaBDE, heptaBDE and decaBDE, which have historically been used as flame retardants. For general mixtures and articles, the limit for the sum of the listed PBDEs falls from 500 mg/kg to 10 mg/kg. Recovered-material provisions phase down from 350 mg/kg on Dec. 30, 2025 to 200 mg/kg on  Dec. 30, 2027. For toys and childcare products made from or containing recovered material, the limit becomes 10 mg/kg on Dec. 30, 2027.

•   Priority materials: recycled and other polymers originating from electrical or electronic applications.

1.  Priority products: toys, childcare articles, electrical housings and products with poorly documented recycled plastic.

3.    Dechlorane Plus: a new POP listing with future stricter limits

Commission Delegated Regulation (EU) 2025/1930 adds Dechlorane Plus to Annex I following its listing under the Stockholm Convention. Adopted on 15 May 2025 and published on 25 September 2025, the measure includes specific exemptions for defined applications and transitional uses.

Dechlorane Plus has been used as a flame-retardant additive. Consumer-product screening should therefore focus on components where fire performance is technically relevant, including flame-retarded plastics, polymer housings, cables, wires, connectors, electrical and electronic components, spare parts and legacy imported components. A detection must be assessed against the applicable concentration, use and exemption, rather than treated as automatically non-compliant.

The limits are:

(a)  equal to or below 1,000 mg/kg (0.1% by weight) where they are present in substances, mixtures or articles until  April 15, 2028;

(b)  equal to or below 1 mg/kg (0.0001% by weight) where they are present in substances, mixtures or articles after  April 15, 2028.

4.    UV-328: progressively stricter limits

Commission Delegated Regulation (EU) 2025/843 adds UV-328, a benzotriazole UV stabilizer, to Annex I. The Regulation was adopted on 5 May 2025, published on 15 July 2025 and entered into force on 4 August 2025. Its staged unintentional trace contaminant limits apply to substances, mixtures and articles:

(a)  100 mg/kg from Aug. 4, 2025

(b)  10 mg/kg from Aug 4, 2027

(c)   1 mg/kg from Aug 4, 2029

UV-328 was already subject to REACH authorization controls, but imported articles could remain a route into the EU market. The POP entry therefore has relevance for imported polymeric components. Priority materials include outdoor plastics, UV-resistant housings, coatings, rubber and elastomers, automotive-related components and long-life plastics. Specific exemptions apply to certain vehicles, industrial coatings, blood-collection tube separators, polarizers, photographic paper, aircraft and defined spare parts.

What May Be Published Next

1.    Medium-chain chlorinated paraffins MCCPs: the next chlorinated-paraffin control

The upcoming development on chlorinated paraffins concerns medium-chain chlorinated paraffins (MCCPs), not SCCPs, which are already controlled under the POPs framework. Following their 2025 listing under the Stockholm Convention, the European Commission adopted a delegated act on 11 September 2026. The text proposes a 1,000 mg/kg (0.1% by weight) unintentional trace contaminant limit for the sum of specified linear C14–C17 chloroalkanes in substances, mixtures or articles.

The act also contains derogations, including a temporary limit for defined recovered materials.

2.    Long-chain perfluorocarboxylic acids LC-PFCAs: POP controls expand further into PFAS

The Commission adopted a delegated act on 7 September 2026 for long-chain perfluorocarboxylic acids, covering C9–C21 PFCAs, their salts and related compounds.

The adopted text sets very low proposed limits in substances, mixtures and articles:

•  0.025 mg/kg for the sum of C9–C21 PFCAs and their salts.

•  0.26 mg/kg for the sum of C9–C21 PFCA-related compounds.

C9–C14 PFCAs are already restricted under REACH Annex XVII, Entry 68; the POP measure extends the approach to the wider C9–C21 group. Risk-based surveillance should prioritize materials where fluorinated chemistry is plausible, while also checking the detailed derogations and transitional provisions in the final published text.

4 updates and 2 future proposals at a glance

^{Sources:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R1021-20260930 (Last consolidated text available on November 5, 2026)
https://echa.europa.eu/it/list-of-substances-proposed-as-pops}