POPs Regulation: the persistent organic pollutants banned in products you sell, and their limits

The POPs Regulation, Regulation (EU) 2019/1021Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)The whole regulationClick opens the law on the EU Publications Office., bans the substances listed in its Annex I. The ban applies to the substance “whether on their own, in mixtures or in articles” (Art. 3(1)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 3, paragraph 1Click opens the article on EUR-Lex.). It carries out the EU’s duties under the Stockholm Convention on Persistent Organic Pollutants and the Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution (Art. 1Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 1Click opens the article on EUR-Lex.). The limit sits on the finished product, whoever sells it.

Annex I, Part A lists the substances of the Stockholm Convention and the Protocol, from the brominated flame retardants to chlorpyrifos. The Regulation does not number the entries. Each is named by its substance. Annex II, which would list restricted substances, and Part B of Annex I, which would list Protocol-only substances, hold no substance in the text of 30 September 2026. The limits below are the unintentional trace contaminant values the entries set, except the SCCP row, which is a derogation. Every amending act named in the table enters into force on the twentieth day after its publication in the Official Journal, so each date is that day counted from the publication date printed on the act.

Exemptions that change the answer. For any substance, the ban does not apply to a substance present in articles “already in use before or on the date that this Regulation or Regulation (EC) No 850/2004 became applicable to that substance” (Art. 4(2)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 4, paragraph 2Click opens the article on EUR-Lex., second subparagraph). Several entries repeat the rule with their own date. For PFOS, and for the tetra-, penta-, hexa- and heptaBDEs, that date is 25 August 2010. For decaBDE it is 15 July 2019. For PFOA it is 4 July 2020. For endosulfan, hexachlorobutadiene and polychlorinated naphthalenes it is 10 July 2012.

• PBDEs. Electrical and electronic equipment within the scope of Directive 2011/65/EUDirective 2011/65/EU, Restriction of Hazardous Substances (RoHS)The whole regulationClick opens the law on the EU Publications Office. is allowed, and decaBDE has further dated exemptions for aircraft and for spare parts of motor vehicles produced before 15 July 2019. RoHS compliance covers the limits that equipment then meets. Food contact materials under Regulation (EC) No 1935/2004Regulation (EC) No 1935/2004, food contact materials (consolidated text of 27 March 2021)The whole regulationClick opens the law on the EU Publications Office. get no PBDE trace allowance: the entry leaves them out of its limits, and the recitals of Regulation (EU) 2025/1482 say PBDEs “should in principle not be present” in them. An article that holds decaBDE under an exemption must be identifiable by labelling or other means throughout its life cycle. The recitals of Regulation (EU) 2025/1482 say these substances now occur mainly in products made from recovered material, “including products for the general public”.
• HBCDD. Expanded polystyrene articles with HBCDD already in use in buildings before 21 February 2018, and extruded polystyrene ones before 23 June 2016, may stay in use. Expanded polystyrene placed on the market after 23 March 2016 in which HBCDD was used must be identifiable by labelling or other means throughout its life cycle. The recitals of Regulation (EU) 2024/2555 raise the concern that recycled polymer carries restricted brominated flame retardants into goods such as children’s toys, food-contact articles and polystyrene packaging.
• Dechlorane Plus. Aerospace, space and defence, medical imaging, and radiotherapy devices and installations are exempt until 26 February 2030. Spare parts for, and repair of, listed vehicles, machines, instruments, medical devices and aerospace products are exempt until the end of their service life or 31 December 2043, whichever is earlier (medical device spare parts: end of service life). The Commission assesses a prolongation at the latest by 1 April 2028.
• UV-328. Exempt until 4 August 2030: articles in land-based motor vehicles, industrial coatings for vehicles, machines, rail vehicles and large steel structures, mechanical separators in blood collection tubes, triacetyl cellulose film in polarisers, photographic paper, and civilian and military aircraft. Spare parts where UV-328 was first used in their production: until the end of service life, capped at 31 December 2043 for vehicle, machine and instrument parts; aircraft spare parts until 31 December 2030. Articles already in use on the expiry date of an exemption may stay in use.
• PFOA. Most exemptions that touched articles have run out: textiles for oil and water repellency for worker protection ended on 4 July 2023, and semiconductor processes, photographic coatings and invasive and implantable medical devices on 4 July 2025. One limit stays in force: 2 mg/kg of PFOA, its salts and PFOA-related compounds in medical devices other than invasive devices and implantable devices. Articles already in use on an expiry date may stay in use.
• PFHxS. The recitals of Regulation (EU) 2023/1608 state that the Stockholm Convention lists it without any specific exemption. The only higher figure in the entry is 0.1 mg/kg in concentrated firefighting foam mixtures used to make other foams.
• SCCPs. Use stays allowed for conveyor belts in the mining industry and dam sealants in use before 4 December 2015, and for other articles in use before 10 July 2012.
• Chlorpyrifos. The recitals of Regulation (EU) 2026/1423 say the Convention lists it with specific exemptions. The entry in Annex I carries only the trace limit.

Time to sell old stock. For a substance added after 15 July 2019, the ban does not apply for six months to articles produced on or before the date the Regulation became applicable to that substance (Art. 4(2)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 4, paragraph 2Click opens the article on EUR-Lex.). That window is spent for every such substance except chlorpyrifos: PFOA (applies from 4 July 2020), PFHxS (28 August 2023), methoxychlor (17 October 2024), UV-328 (4 August 2025) and Dechlorane Plus (15 October 2025). Chlorpyrifos is the newest. Regulation (EU) 2026/1423 was published on 10 September 2026 and entered into force on the twentieth day after publication, 30 September 2026. Its six months run to about 30 March 2027.

The PFAS pointer. PFOS, PFOA and PFHxS are three PFAS the POPs Regulation bans by name. A wider restriction on PFAS as a group is a separate matter and is not covered on this page.

The gap between the lists is real. The recitals of Regulation (EU) 2025/843 note that UV-328 is in Annex XIV to REACH, with no authorisation applied for, so it cannot be used in the EU, “but it can still be imported in articles”. The POPs entry for UV-328 closes that gap: it limits the substance in the article itself.

The lists also divide PFAS between them. Annex XVII entry 68 limits the C9-C14 perfluorocarboxylic acids in articles at 25 ppb, and entry 79 limits PFHxA, its salts and related substances. Entry 79(6) leaves out the substances with a C6F13- group on a sulphur atom that Annex I of Regulation (EU) 2019/1021Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)The whole regulationClick opens the law on the EU Publications Office. prohibits, and entry 82(2)(a) leaves out PFOS, PFOA and PFHxS from its firefighting foam limit for the same reason. REACH Annex XVII covers those entries; REACH compliance shows how the three REACH duties fit together.

Substances can also be on the way in. The Stockholm Convention already lists medium-chain chlorinated paraffins (MCCPs) and long-chain perfluorocarboxylic acids, their salts and related compounds in its Annex A, and Annex I does not yet list either. The Union backed both listings in Council Decision (EU) 2025/868, so they are the next EU listings. A third, TBPH, is only a proposal: the Council adopted Decision (EU) 2026/878 on 30 March 2026 for the Union to propose listing TBPH, a brominated flame retardant already identified as a substance of very high concern under REACH, in Annex A to the Convention. A proposal is not a listing. A new substance enters Annex I only after the Convention lists it and the Union has backed that change by a Council decision (Art. 15(1)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 15, paragraph 1Click opens the article on EUR-Lex.). The Commission can also modify an existing entry to adapt it to scientific and technical progress, as it did when it cut the PFOS and PBDE limits.

The Regulation names no importer, no representative and no registration. The business that brings the goods in, the distributor and the retailer each place the same article on the market, and the ban binds it in each of their hands. Importer of record in the EU covers who files the customs side. For toys, toy safety regulation sets the toy rules; the PBDE entries single out toys under Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office. and childcare products made from recovered material.

The Regulation names no test method for any entry. The PFOS entry used to refer to the availability of analytical methods in its point 5. Regulation (EU) 2025/718 deleted that point, because no other entry in the Regulation “specifies such details”. The Regulation defines the trace contaminant as a level “incidentally present in a minimal amount, below which the substance cannot be meaningfully used, and above the detection limit of existing detection methods to enable control and enforcement” (Art. 2(12)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 2, point 12Click opens the article on EUR-Lex.). Regulation (EU) 2025/1930 sets the Dechlorane Plus figure at 1,000 mg/kg first because “laboratories need to improve analysis accuracy”, and at 1 mg/kg thirty months after entry into force.

Annex I of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. lists Regulation (EC) No 850/2004, the earlier POPs Regulation, among the Union harmonisation legislation that the Market Surveillance Regulation covers (Art. 2Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 2Click opens the article on EUR-Lex.; Annex I, point 16). Art. 21Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 21Click opens the article on EUR-Lex. says references to Regulation (EC) No 850/2004 are read as references to Regulation (EU) 2019/1021Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)The whole regulationClick opens the law on the EU Publications Office.. Under the Market Surveillance Regulation, an authority that finds a non-conforming product requires corrective action: bringing the product into compliance, preventing it being made available, withdrawing or recalling it, or destroying it (Art. 16(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.). At the border, customs suspend release of a product when there is cause to believe it does not comply with the Union law applicable to it (Art. 26(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 26, paragraph 1Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.). Member States may also apply stricter requirements than the Regulation sets (Art. 1Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 1Click opens the article on EUR-Lex.).

What you can skip

What the law leaves open

• Whether the limit counts in the whole article or in each part. The entries set a concentration “where they are present in substances, mixtures or articles” and do not say whether the article is measured whole or by material. Meanwhile, test each separable material that could carry the substance.
• How a trace of an entry without a figure is treated. Art. 4(1)(b)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)Article 4, paragraph 1, point (b)Click opens the article on EUR-Lex. exempts a trace contaminant “as specified in the relevant entries”, and the entries for DDT, chlordane and the others in the last row of the table specify none. The Regulation does not say how a trace of one of them is treated. Meanwhile, use a report that states its detection limit.
• Second-hand goods first brought into the EU. The exemptions cover articles “already in use in the Union” before the date in the entry. The text does not say how that applies to an article first imported second-hand after that date. Meanwhile, treat such an article as inside the ban and test it like a new one.