The European Commission has launched two public consultations on draft Delegated Regulations under the POPs Regulation (EU) 2019/1021 which implements the EU’s international commitments under the Stockholm Convention on persistent organic pollutants (chemical substances). These substances are in principle largely being phased out in the industry but can still be found.

Feedback period for both is open until 19 December 2025.

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1. Consultation: Medium-Chain Chlorinated Paraffins (MCCPs)

The Commission proposes adding MCCPs to Annex I (prohibited POPs). Feedback page is here

Key points:

• General ban on manufacture, placing on the market and use.
• Limit for unintentional traces: 0.1% by weight.
• Several time-limited exemptions (e.g., metalworking fluids, certain spare parts, medical devices, aerospace/defence uses).
• New obligations for suppliers to declare MCCP content in Safety Data Sheets.

This can have a potential impact on plastics, rubber components, adhesives, coatings, and supply chains containing MCCP-treated materials.

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2. Consultation: Long-chain Perfluorocarboxylic Acids (C9–21 PFCAs)

The proposal adds long-chain PFCAs, their salts and related compounds to Annex I. Feedback page is here

Key points:

• Extremely low trace limits, e.g. 0.025 mg/kg for PFCAs.
• Limited derogations (fluoropolymer production, PTFE micropowders, certain semiconductors in older electronics).
• Articles already in use before the cut-off date may continue to be used.

Possible implications for water-repellent textiles, technical coatings, fluoropolymer components, and compliance with very low PFAS trace limits.

Please let us know whether these proposals impact your materials, coatings, components, or supply chains, or whether you foresee challenges related to substitution or compliance. Your feedback will help us provide a coordinated industry response to the Commission.