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

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) and their salts and related compounds, medium-chain chlorinated paraffins (MCCPs), and chlorpyrifos to Annex I of the POPs Regulation for control.

The consultation period is scheduled to end on December 19, 2025. If the proposals are adopted, the three substances will be included in the EU POPs Regulation, with an expected entry into force in 2026.

Substance Information

Here are specific exemptions for intermediate use and other specifications:

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

1. The sum of the 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 (0.0000025% by weight) when used for production, placing on the market, and use as an unintentional trace contaminant.

2. The sum of the concentrations of C9-21 PFCAs related compounds in a substance, mixture, or article shall be equal to or less than 0.26 mg/kg (0.000026% by weight) when used for production, placing on the market, and use as an unintentional trace contaminant.

3. As an exemption to the two preceding conditions, the sum of the concentrations of C9-21 PFCAs, their salts, and related compounds present in a substance used as a transport-isolated intermediate shall be equal to or less than 10 mg/kg (0.001% by weight).

• Here, "transport-isolated intermediate" means a substance that meets the definition in point 15(c) of Article 3 of Regulation (EC) 1907/2006, and must strictly satisfy the rigorous control conditions listed in points (a) to (f) of the first subparagraph of Article 18(4) of that Regulation, for the production of fluorochemicals with a perfluorinated carbon chain equal to or shorter than 6 atoms.

4. As an exemption to condition 1, the sum of the concentrations of C9-21 PFCAs present in fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups shall be equal to or less than 0.1 mg/kg (0.00001% by weight). The limit for unintentional trace contaminants under this use does not apply to the articles mentioned above. All emissions of unintentionally formed C9-21 PFCAs during the production and use of fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups shall be avoided; if unavoidable, they shall be minimized as far as technically and practically feasible.

5. As an exemption to condition 1, the sum of the concentrations of C9-21 PFCAs and their salts present in polytetrafluoroethylene (PTFE) micropowders shall be equal to or less than 1 mg/kg (0.0001% by weight), provided that these micropowders are being transported or processed to reduce the sum of the concentrations of C9-21 PFCAs and their salts to below the 0.025 mg/kg (0.0000025% by weight) limit.

6. Until December 30, 2030, C9-21 PFCAs, their salts, and related compounds are allowed to be placed on the market and used in spare parts and semiconductors for repair in the following uses:

• Electronic equipment of vessels driven by internal combustion engines placed on the market before December 31, 2023.

• Electronic equipment of land-based motorized vehicles that have ceased mass production and were placed on the market before December 31, 2023.

7. Articles containing C9-21 PFCAs, their salts, and related compounds already in use in the EU before December 31, 2023, may continue to be used.

Medium-Chain Chlorinated Paraffins (MCCPs)

1. The sum of the concentrations of MCCPs in a substance, mixture, or article shall be equal to or less than 1000 mg/kg (0.1% by weight) when used for production, placing on the market, and use as an unintentional trace contaminant.

2. As an exemption, the manufacture, placing on the market, and use of MCCPs are allowed for the following uses:

(a) As an extreme pressure additive in metal working fluids for "heavy duty" metal working operations in professional or industrial settings, where a collection system is established, until December 31, 2036.

(b) In polymers and rubber for spare parts and repair in any of the following equipment:

           (i) Land-based motorized vehicles;

           (ii) Machinery for agriculture, construction, forestry, or gardening;

           (iii) Electrical and electronic equipment of medical devices within the scope of Regulation (EU) 2017/745;

           (iv) Electrical and electronic equipment of in vitro diagnostic devices within the scope of Regulation (EU) 2017/746;

           (v) Instruments for measuring, analyzing, manufacturing, controlling, monitoring, testing, and inspection;

           (vi) Aerospace and defense applications. Provided that MCCPs were originally used in their production, until the end of their service life or December 31, 2041, whichever is sooner.

(c) Flexible polyvinyl chloride (PVC) in cables of medical devices specified in Regulation (EU) 2017/745 and in vitro diagnostic devices specified in Regulation (EU) 2017/746, until 5 years after the formal entry into force of the amendment.

(d) Adhesives, sealants, and tapes for non-structural bonding in aerospace and defense applications, until 5 years after the formal entry into force of the amendment.

(e) Paints and coatings for ammunition and ammunition marking, until 5 years after the formal entry into force of the amendment.

(f) Pyrotechnic defense countermeasures for the achievement of specific effects, until December 31, 2041.

(g) Intumescent coatings and paints for protection against extreme temperatures in space and defense equipment and their packaging, until December 31, 2041.

(h) Coatings and paints for the repair and replacement of spare parts of space and defense equipment, provided that MCCPs were originally used in the production of that equipment, the exemption is valid until the end of the equipment's service life.

3. During the manufacturing and industrial and professional use of MCCPs within the scope of the exemptions listed in point 2, the emission of MCCPs to the environment shall be avoided; if unavoidable, it shall be reduced to the lowest possible level, and exposure of workers shall be minimized.

4. Articles containing MCCPs already in use in the EU before or on the expiry date of the relevant exemptions stipulated in points 2(b) to (g), may continue to be used.

5. For spare parts containing MCCPs referred to in points 2(b) and (h), their placing on the market and use are allowed if they were already present within the EU before January 1, 2042.

6. Manufacturers, suppliers, and importers of chlorinated paraffin substances or mixtures containing the chlorinated alkanes mentioned in point 1 shall provide the following information to their downstream users and customers in the safety data sheet (SDS) described in Article 31 of Regulation (EU) 1907/2006:

(i) The sum of the concentrations of the chlorinated alkanes listed in point 1 (if present);

(ii) Appropriate risk management measures and operating conditions to minimize emissions and exposure when the sum mentioned in point 6(i) exceeds 0.1% (by weight).

7. Manufacturers, suppliers, and importers of chlorinated paraffins shall determine the sum of the concentrations of the chlorinated alkanes referred to in point 6(i). To determine this content, a representative batch of chlorinated paraffins produced by the same manufacturer and according to the same technical specifications shall be tested, and the measured content must be determined using a validated analytical method. The description of the analytical method used and the test results obtained to derive the sum referred to in point 6(i) must be made available upon request to the competent authorities (regulatory bodies).

Chlorpyrifos

When used for production, placing on the market, and use as an unintentional trace contaminant, the sum of the concentrations of Chlorpyrifos (as the substance referred to in this section) in a substance, mixture, or article shall be equal to or less than 0.01 mg/kg (0.000001% by weight).

Final Thoughts

C9-21 Perfluorocarboxylic acids (PFCAs) and their related compounds, medium-chain chlorinated paraffins (MCCPs), and Chlorpyrifos—all are chemicals with potential long-term harm to the environment and health, and are facing stringent global control. All have currently been listed in Annex A (Elimination) of the Stockholm Convention, with specific exempted uses.

Currently, the international community is committed to eliminating or strictly restricting these high-risk chemicals, replacing them with alternatives, and minimizing their release into the environment. REACH24H reminds relevant businesses to timely monitor the latest developments of the EU POPs Regulation, adjust their products exported to the EU, and fulfill the corresponding compliance obligations.

For more information and inquiries on EU POPs, please feel free to contact us at customer@reach24h.com.