Overview#
The POP regulation targets the worst chemicals there are. These are substances that do not break down, that build up in bodies and ecosystems, and that spread worldwide, and the regulation largely bans them.
What a POP is#
A persistent organic pollutant has four defining traits:
- Persistent, meaning it resists environmental breakdown.
- Bioaccumulative, meaning it builds up in living organisms and the food chain.
- Mobile, meaning it travels long distances through air and water.
- Toxic, meaning it is harmful to humans and wildlife.
What the regulation does#
- It implements the Stockholm Convention, and the UNECE POP Protocol, in EU law.
- It bans or severely restricts listed substances in products, articles and waste, usually with very low limits for unintentional trace contaminants.
- Examples of POP-listed substances include PFOS and PFOA, certain brominated flame retardants such as PBDEs and HBCDD, and short-chain chlorinated paraffins (SCCPs).
Annex I bans, Annex II restricts#
Which annex a substance sits in decides what happens to it. This is the first thing to check about any POP.
Article 3(1): manufacturing, placing on the market and use are prohibited, whether the substance is on its own, in a mixture or in an article. Almost every POP is here.
Article 3(2): the same three activities are restricted rather than banned, on the conditions the entry sets out.
Annex I is itself split. Part A holds substances listed in the Convention and in the Protocol, as well as substances listed only in the Convention. Part B holds those listed only in the Protocol.
The concentration figures are not permitted levels#
Every Annex I entry carries numbers, and they are the most misread part of the regulation. They are not RoHS-style thresholds you may design up to.
Article 3 prohibits the substance. Article 4(1)(b) then says Article 3 does not apply to "a substance present as an unintentional trace contaminant, as specified in the relevant entries of Annex I or II, in substances, mixtures or articles". The figures in an entry are the ceiling for that exemption. Below it, contamination you did not intend is tolerated. Deliberate use at any concentration is still prohibited.
Article 4 carries two other general reliefs worth knowing: a substance used for laboratory-scale research or as a reference standard is out of scope, and articles already in use in the Union before the regulation became applicable to the substance may continue to be used.
How a substance reaches Annex I#
A Stockholm Convention decision does not change what a company may sell on the day it is taken. The EU has to write it down first, and that takes a defined route with its own dates.
The newest listing: long-chain PFCAs (C9-C21)#
On 7 September 2026 the Commission adopted a delegated regulation adding long-chain perfluorocarboxylic acids, their salts and related compounds to Part A of Annex I. It implements Stockholm Convention decision SC-12/12, taken at the twelfth Conference of the Parties in Geneva from 28 April to 9 May 2025, which put the group in Annex A to the Convention.
This is a prohibition, not a permission. At the time of writing the act has been adopted but has no Official Journal number yet, and it is still inside the two-month scrutiny period of Article 18(6). It enters into force twenty days after publication and applies from 16 December 2026. Check the published text for the final number before citing it.
What is in scope#
The entry defines the group by structure, not by a list of substances:
The Commission notes that no exhaustive list of CAS numbers is possible, because new related compounds can be identified later; the Convention Secretariat keeps a non-exhaustive list instead. The entry itself names twelve CAS numbers "and others".
The trace contaminant limits#
Sum of C9-C21 PFCAs and their salts, in substances, mixtures or articles0,025 mg/kg Sum of C9-C21 PFCA related compounds, same scope0,26 mg/kgThose are the general figures. Five derogations set their own, and the two for fluoropolymers are temporary because analytical standards for several of the longer chains do not yet exist:
| Where | Until 16 December 2030 | From 17 December 2030 |
|---|---|---|
| Fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups | C9-C14: 0,1 mg/kg; C15-C21: 15 mg/kg | C9-C21: 0,1 mg/kg |
| PTFE micropowders from ionising irradiation or thermal degradation, and mixtures and articles for industrial and professional use containing them | C9-C14 and salts: 1 mg/kg; C15-C21 and salts: 15 mg/kg | C9-C21 and salts: 1 mg/kg |
In both cases the entry also requires that emissions unintentionally formed during production and use be avoided, or reduced as far as technically and practically possible.
Three further derogations stand apart from that timetable:
- Transported isolated intermediates: 10 mg/kg for the sum of the acids, salts and related compounds, where the substance is used under the strictly controlled conditions of REACH Article 18(4), points (a) to (f), to produce fluorochemicals with a perfluoro carbon chain of six atoms or fewer.
- Firefighting foam already installed in systems, for class B fires: 1 mg/kg for the sum of the acids or any of their salts, and 10 mg/kg for related compounds, until 3 August 2028. That matches the deadline the existing PFOA entry uses.
- Fluorine-free foam from cleaned equipment: 10 mg/kg for the sum of the acids, salts and related compounds, where they originate from firefighting equipment cleaned in accordance with best available techniques, with no end date attached.
The exemptions, and what may stay in use#
The narrower group C9-C14 PFCAs is currently restricted by entry 68 of REACH Annex XVII. In the explanatory memorandum accompanying the delegated act the Commission says it will start the procedure to remove entry 68 as soon as the act is adopted, to avoid regulating the same substances twice. The same pattern was followed for PFOA. Until that removal actually happens, entry 68 is still law.
How it relates to other topics#
- It runs alongside REACH but is generally stricter. For a listed POP, the phase-out regime takes precedence over REACH's authorisation route.
- Some POPs overlap with PFAS and with substances that are also relevant to RoHS in electronics.
The international basis#
The Stockholm Convention is the worldwide POPs treaty under the UN.
The Aarhus Protocol is the UNECE-region POPs instrument.
The EU POP Regulation implements both in directly applicable EU law.