Update on POP Regulation

The EU implements new listings agreed under the Stockholm Convention by adopting Commission Delegated Regulations that amend Annex I of the POPs Regulation (EU) 2019/1021. Following COP-12 (April–May 2025) decisions to list three chemicals/groups in Annex A (elimination), the Commission has created three “Have your say” entries to prepare the corresponding EU delegated acts. FESI will monitor each page for the call for feedback and, especially, for the Commission’s adoption of the delegated regulations (the key milestone before EP/Council scrutiny and OJ publication).

  1. MCCPs - Medium-chain chlorinated paraffins

EU delegated act to add MCCPs to Annex I of Reg. 2019/1021, aligning with COP-12 listing (Annex A) and any narrowly scoped exemptions. This update highlights a phase-out trajectory for MCCPs across articles/materials. MCCPs have historically been used as plasticisers or auxiliary flame retardants in PVC trims & films, synthetic leather, rubber (e.g., outsoles), inks, paints, adhesives and surface coatings. They can be present as legacy compounds and are present also as impurities in some leather chemicals

  1. LC-PFCAs - Long-chain perfluorocarboxylic acids (C9–C20), their salts & related compounds

EU delegated act to add LC-PFCAs (and related compounds) to Annex I, transposing the COP-12 Annex A decision with specific exemptions. LC-PFCAs are directly tied to legacy fluorinated DWR (side-chain polymers with C8–C12 side chains) historically used on shells, tents, packs, gloves, and footwear uppers. Even where you no longer intentionally use them, they can show up as residuals/impurities or as degradation products of older finishes. The EU already restricts C9–C14 PFCAs under REACH Annex XVII (25 ppb for the acids/salts; 260 ppb for related substances in substances, mixtures and articles). The POPs listing goes broader (up to C20 and includes precursors) and typically comes with very low “unintentional trace contaminant” limits—so compliance gets tighter.