Industrial Chemical

EU Proposes New POPs Regulation for PFCAs, MCCPs, and Chlorpyrifos

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EU CHEMICAL COMPLIANCE | EU POPS REGULATION UPDATE

The European Commission has launched a consultation on three draft amendments to the EU POPs Regulation, proposing to add C9-21 PFCAs, MCCPs, and chlorpyrifos to Annex I for control. The proposals may affect companies placing relevant substances, mixtures, or articles on the EU market.

The consultation period was scheduled to close on December 19, 2025. If adopted, the amendments are expected to enter into force in 2026. Companies should continue to monitor the final adopted text and assess whether affected substances may be present in raw materials, mixtures, finished articles, spare parts, or supply chains.

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News Brief

On November 21, 2025, the European Commission launched a public consultation on three draft amendments to the POPs Regulation (EU) 2019/1021. The drafts propose adding long-chain perfluorocarboxylic acids (C9-21 PFCAs), their salts and related compounds, medium-chain chlorinated paraffins (MCCPs), and chlorpyrifos to Annex I of the Regulation.

The consultation period was scheduled to close on December 19, 2025. If the proposals are adopted, the three substance groups would be included in the EU POPs Regulation, with the amendments expected to enter into force in 2026. Companies should continue to monitor the final adopted text and any transitional measures before making binding compliance decisions.

Substance Information

SubstanceRepresentative CAS No.Regulatory focus
Long-chain perfluorocarboxylic acids (C9-21 PFCAs), their salts and related compounds375-95-1, 335-76-2, 2058-94-8, 307-55-1, 72629-94-8, 376-06-7, 141074-63-7, 67905-19-5, 57475-95-3, 16517-11-6, 133921-38-7, 68310-12-3, etc.PFAS-related controls under the POPs framework.
Medium-chain chlorinated paraffins (MCCPs)85535-85-9, 198840-65-2, 1372804-76-6, etc.Restrictions with specific exemptions for defined industrial uses.
Chlorpyrifos2921-88-2Proposed low unintentional trace contaminant limit.

Proposed Controls and Exemptions

Long-chain Perfluorocarboxylic Acids (C9-21 PFCAs), Their Salts and Related Compounds

  • The sum of concentrations of C9-21 PFCAs and their salts in a substance, mixture, or article shall be equal to or less than 0.025 mg/kg when present as an unintentional trace contaminant.

  • The sum of concentrations of C9-21 PFCA-related compounds shall be equal to or less than 0.26 mg/kg under the same condition.

  • For transport-isolated intermediates used to produce fluorochemicals with a perfluorinated carbon chain equal to or shorter than six atoms, the sum of C9-21 PFCAs, their salts, and related compounds shall be equal to or less than 10 mg/kg, subject to strictly controlled conditions under REACH.

  • For fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups, a specific unintentional trace contaminant limit of 0.1 mg/kg may apply to C9-21 PFCAs.

  • For PTFE micropowders, C9-21 PFCAs and their salts may be equal to or less than 1 mg/kg, provided that the micropowders are transported or processed to reduce the concentration below 0.025 mg/kg.

  • Until December 30, 2030, specific spare parts and semiconductor repair uses may continue under the proposed conditions.

  • Articles already in use in the EU before December 31, 2023 may continue to be used.

Medium-chain Chlorinated Paraffins (MCCPs)

  • The sum of concentrations of MCCPs in a substance, mixture, or article shall be equal to or less than 1000 mg/kg as an unintentional trace contaminant.

  • Specific exemptions are proposed for certain professional or industrial uses, including heavy-duty metal working fluids, polymers and rubber for spare parts and repair, flexible PVC in cables for medical devices and in vitro diagnostic devices, and selected aerospace, defense, space, and ammunition-related applications.

  • Exemptions include different end dates, including December 31, 2036, December 31, 2041, or five years after the formal entry into force of the amendment, depending on the use.

  • During manufacturing and professional or industrial use under the exemptions, emissions of MCCPs to the environment shall be avoided; if unavoidable, they shall be reduced to the lowest possible level and worker exposure shall be minimized.

  • Manufacturers, suppliers, and importers of chlorinated paraffin substances or mixtures shall provide relevant concentration and risk management information in the safety data sheet (SDS) when applicable.

  • The sum of chlorinated alkanes shall be determined using a validated analytical method, with the method description and results made available to competent authorities upon request.

Chlorpyrifos

For production, placing on the market, and use as an unintentional trace contaminant, the sum of concentrations of chlorpyrifos in a substance, mixture, or article shall be equal to or less than 0.01 mg/kg.

Update: The chlorpyrifos amendment has since been adopted by the European Commission. For the latest regulatory status, expected entry-into-force timeline and compliance actions, see REACH24H's dedicated update: European Commission Adopts Chlorpyrifos Amendment under EU POPs Regulation.

What Should Companies Watch?

C9-21 PFCAs and related compounds, MCCPs, and chlorpyrifos are chemicals with potential long-term environmental and health impacts. They have been listed under Annex A (Elimination) of the Stockholm Convention, with specific exemptions or conditions where applicable.

1. Substance and article screening

Review whether affected substances may be present in raw materials, mixtures, polymers, articles, spare parts, or legacy equipment.

2. Exemption mapping

Check whether any proposed exemption applies and whether use-specific conditions, expiry dates, or evidence requirements need to be documented.

3. SDS and supply chain communication

For MCCPs, pay particular attention to proposed SDS communication and validated analytical method requirements.

Relevant businesses should monitor the latest developments of the EU POPs Regulation, evaluate products exported to the EU, and prepare documentation for substance identification, concentration verification, exemption justification, SDS updates, and supply chain communication.

How REACH24H Can Help

REACH24H can support companies with EU POPs regulatory monitoring, product compliance assessment, substance list screening, SDS review, supply chain communication, and regulatory interpretation. For companies also managing EU chemical obligations, related services may include EU REACH, EU CLP, and global GHS/SDS/label compliance.

Need to assess whether your products may be affected?

Contact REACH24H to evaluate substance scope, proposed limits, possible exemptions, SDS implications, and supply chain documentation needs under the EU POPs framework.

Recommended Reading and Official Resources

Recommended Reading

Official Resources