---
title: "POPs — POPs Regulation"
description: "The POPs Regulation prohibits the manufacturing, placing on the market and use of the 32 persistent organic pollutants listed in Annex I, tolerating only trace contaminants, and requires waste above the Annex IV limits to be destroyed. It has applied since 15 July 2019; the newest delegated act adds chlorpyrifos from 30 September 2026."
type: "guide"
url: "https://www.conphora.com/regulations/pops/"
markdown: "https://www.conphora.com/regulations/pops.md"
locale: "en"
language: "en"
published: "2019-07-15"
updated: "2026-09-30"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Regulation (EU) 2019/1021"
celex: "32019R1021"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1021"
tags: ["POPs", "Chemicals & Substances"]
license: "Free to quote with attribution and a link to the page"
---

# POPs — POPs Regulation

The POPs Regulation prohibits the manufacturing, placing on the market and use of the 32 persistent organic pollutants listed in Annex I, tolerating only trace contaminants, and requires waste above the Annex IV limits to be destroyed. It has applied since 15 July 2019; the newest delegated act adds chlorpyrifos from 30 September 2026.

## Key facts

- **Official title:** Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants (recast)
- **Reference:** Regulation (EU) 2019/1021
- **CELEX:** 32019R1021
- **Act type:** Regulation
- **In force:** 2019-07-15
- **Applies from:** 2019-07-15
- **Enforced by:** National competent authorities designated under Article 19 enforce the regulation, coordinated through the Forum for Exchange of Information on Enforcement at the European Chemicals Agency and with the market-surveillance powers of Regulation (EU) 2019/1020, whose Annex I lists Regulation (EC) No 850/2004 (read as Regulation (EU) 2019/1021 since the recast repealed it); in Denmark Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) supervises under lov om kemikalier (kemikalieloven, lovbekendtgørelse nr. 1200 af 25. september 2025). The toolkit is orders to bring the situation into compliance, to stop sales, to recall from dealers and users and to destroy the substance, mixture or article, seizure, the power to order the owner of an online interface to change or remove content that refers to non-compliant substances, mixtures or articles (§ 50) and, where such an order is not complied with or unlawful sales are repeated, have the online interface blocked by court order at its request (§ 50 a), fines, and imprisonment of up to two years for intentional or grossly negligent infringements that harm or endanger health or the environment or where the offender obtained or intended an economic advantage.
- **Category:** Chemicals & Substances

## Who it applies to

**Covered by the act:** Substances listed in Annex I, on their own, in mixtures or in articles: their manufacturing, placing on the market and use are prohibited, subject to the exemptions in Article 4 and in the entry itself; The 32 entries in Annex I Part A as of 1 January 2026: the five PBDEs, PFOS, DDT, chlordane, hexachlorocyclohexanes including lindane, dieldrin, endrin, heptachlor, endosulfan, hexachlorobenzene, chlordecone, aldrin, pentachlorobenzene, PCBs, mirex, toxaphene, hexabromobiphenyl, HBCDD, hexachlorobutadiene, pentachlorophenol, polychlorinated naphthalenes, SCCPs, PFOA, dicofol, PFHxS, methoxychlor, UV-328 and Dechlorane Plus; chlorpyrifos joins them on 30 September 2026; Waste consisting of, containing or contaminated by any of the 30 substances in Annex IV, which must be destroyed or irreversibly transformed unless the content is below the Annex IV limit; Stockpiles of substances, mixtures or articles that consist of or contain an Annex I or II substance; Releases of the Annex III substances (dioxins and furans, PCBs, hexachlorobenzene, PAHs, pentachlorobenzene, hexachlorobutadiene and polychlorinated naphthalenes), which Member States inventory and reduce

**Derived and downstream products:** Annex I Part B (substances listed only in the Protocol) and Annex II (substances subject to restrictions) currently contain no entries; every listed substance is in Annex I Part A and therefore prohibited rather than restricted (Annex I and Annex II); 'Placing on the market', 'article', 'substance', 'mixture', 'manufacturing', 'use' and 'import' carry their REACH meanings, so an import counts as placing on the market and a recycled material containing a listed substance is caught like a virgin one (Art. 2(1) to (7)); A substance present only as an unintentional trace contaminant, that is incidentally present in a minimal amount below which it cannot be meaningfully used and above the detection limit, at or below the concentration set in its Annex I entry, is outside the prohibition (Art. 2(12) and Art. 4(1)(b)); Articles already in use before the date the regulation or Regulation (EC) No 850/2004 became applicable to a substance may continue to be used, and for a substance listed after 15 July 2019 articles produced before the listing date get a six-month period (Art. 4(2)); Recovery, recycling, reclamation or re-use of an Annex IV substance on its own is prohibited; waste below the Annex IV limits may be recovered under ordinary Union waste law (Art. 7(3) and Art. 7(4)(a)); Member States may apply stricter requirements than the regulation, in accordance with the TFEU (Art. 1)

**Roles under the act:**

- **Manufacturer or formulator** — Anyone who manufactures a substance, on its own, in a mixture or in an article; 'manufacturing' has the meaning given in point 8 of Article 3 of Regulation (EC) No 1907/2006 (REACH). The prohibition in Article 3(1) is addressed to the activity, not to a defined operator, so every natural or legal person carrying it out is bound.
- **Importer** — Anyone who imports a substance, mixture or article into the Union; 'import' and 'placing on the market' have the meanings given in points 10 and 12 of Article 3 of REACH, so bringing goods containing a listed substance into the Union is placing on the market and prohibited unless an exemption applies.
- **Distributor, retailer or downstream user** — Anyone who places a substance, mixture or article on the market or uses it; 'placing on the market' and 'use' have the meanings given in points 12 and 24 of Article 3 of REACH. The regulation names no separate distributor role: whoever supplies or uses a listed substance above its limit infringes Article 3.
- **Holder of a stockpile, producer or holder of waste, waste operator** — The holder of a stockpile of substances, mixtures or articles that consist of or contain an Annex I or II substance, and the producers and holders of waste consisting of, containing or contaminated by an Annex IV substance, including the operators that dispose of or recover it; 'waste', 'disposal' and 'recovery' have the meanings given in Directive 2008/98/EC.

## Key dates

- 2019-06-20: Regulation (EU) 2019/1021 adopted by the European Parliament and the Council as a recast of Regulation (EC) No 850/2004
- 2019-07-15: Entry into force, the twentieth day after publication in OJ L 169 of 25 June 2019; Regulation (EC) No 850/2004 repealed and references to it read as references to the recast
- 2019-10-15: Deadline for Member States to inform the Commission of the competent authorities responsible for administration and enforcement, three months after entry into force
- 2020-07-04: PFOA, its salts and PFOA-related compounds listed in Annex I by Delegated Regulation (EU) 2020/784, with an unintentional-trace limit of 0,025 mg/kg for PFOA and its salts and 1 mg/kg for PFOA-related compounds
- 2020-07-16: Deadline for Member States to notify their penalty rules to the Commission
- 2020-12-03: End of the transitional derogation for PFOA in non-implantable medical devices, latex printing inks and plasma nano-coatings
- 2023-06-10: Regulation (EU) 2022/2400 applies: new Annex IV waste limits including 500 mg/kg for the sum of PBDEs, 1 500 mg/kg for SCCPs, 5 μg/kg for PCDD/PCDF and dioxin-like PCBs, 500 mg/kg for HBCDD, and new rows for pentachlorophenol, dicofol, PFOA and PFHxS
- 2023-08-18: Delegated Regulation (EU) 2023/866 applies: the 1 mg/kg limit for PFOA in PTFE micropowders expires except for transport and treatment to reduce the PFOA content, and the exemption for PFOA in PTFE and PVDF manufacture is deleted
- 2023-08-28: PFHxS, its salts and PFHxS-related compounds listed in Annex I by Delegated Regulation (EU) 2023/1608 with limits of 0,025 mg/kg and 1 mg/kg
- 2023-12-31: The 5 μg/kg Annex IV limit for PCDD/PCDF and dioxin-like PCBs applies to fly ashes from biomass units for heat and power production; 10 μg/kg applied until 30 December 2023
- 2024-10-17: Delegated Regulations (EU) 2024/2555 and 2024/2570 in force: HBCDD unintentional-trace limit lowered from 100 mg/kg to 75 mg/kg, and methoxychlor listed with a limit of 0,01 mg/kg
- 2025-01-01: The 5 μg/kg Annex IV limit for PCDD/PCDF and dioxin-like PCBs applies to ashes and soot from private households; 15 μg/kg for PCDD/PCDF applied until 31 December 2024
- 2025-08-04: UV-328 listed in Annex I by Delegated Regulation (EU) 2025/843 with an unintentional-trace limit of 100 mg/kg and exemptions for motor vehicles, industrial coatings, blood collection tubes, polarisers, photographic paper, aircraft and spare parts
- 2025-10-15: Dechlorane Plus listed in Annex I by Delegated Regulation (EU) 2025/1930 with a limit of 1 000 mg/kg until 15 April 2028 and exemptions for aerospace, defence, medical imaging, radiotherapy and spare parts
- 2025-11-17: Delegated Regulation (EU) 2025/1482 in force: the sum of tetra-, penta-, hexa-, hepta- and decaBDE in mixtures and articles is limited to 10 mg/kg, with a derogation of 500 mg/kg for recovered material
- 2025-12-03: The PFOS unintentional-trace limits of 0,025 mg/kg for PFOS and its salts and 1 mg/kg for PFOS-related compounds apply, and the derogation for PFOA in fire-fighting foam already installed in systems ends
- 2025-12-30: The PBDE sum limit for mixtures and articles made of or containing recovered material, and for toys and childcare products from recovered material, falls from 500 mg/kg to 350 mg/kg; the Annex IV waste limit for the PBDE sum falls to 350 mg/kg
- 2025-12-31: Deadline for Member States to identify and remove from use equipment containing more than 0,005 % PCBs in volumes above 0,05 dm3
- 2026-01-01: Regulation (EU) 2025/2457 in force: the Agency reports on waste limits at the Commission's request, Annexes IV and V are amended by delegated act, and the delegation of power runs for five years from this date; Commission review of the HBCDD exemptions due
- 2026-08-28: Deadline for the Commission to review the 0,1 mg/kg limit for PFHxS in concentrated fire-fighting foam mixtures
- 2026-09-30: Chlorpyrifos listed in Annex I by Delegated Regulation (EU) 2026/1423 without specific exemptions and with an unintentional-trace limit of 0,01 mg/kg
- 2026-12-31: Deadline for the Commission's first review of the derogation for perfluorooctyl bromide containing perfluorooctyl iodide in pharmaceutical production; then every four years until 31 December 2036
- 2027-05-17: The PBDE sum limit for toys and products for children's seating, sleep, hygiene, feeding, transport and protection made of or containing recovered material falls to 10 mg/kg
- 2027-08-04: The unintentional-trace limit for UV-328 falls to 10 mg/kg
- 2027-12-30: The PBDE sum limit for recovered material falls to 200 mg/kg and the Annex IV waste limit to 200 mg/kg; deadline for the Commission to review the Annex IV limits for SCCPs, PCDD/PCDF and dioxin-like PCBs, HBCDD, PFOA and PFHxS
- 2028-04-15: The unintentional-trace limit for Dechlorane Plus falls from 1 000 mg/kg to 1 mg/kg after this date; the Commission assesses the aerospace, medical imaging and radiotherapy exemptions by 1 April 2028
- 2028-08-03: End of the specific limits of 1 mg/kg and 10 mg/kg for PFOA in fire-fighting foam already installed in systems
- 2029-08-04: The unintentional-trace limit for UV-328 falls to 1 mg/kg
- 2030-02-26: Expiry of the Dechlorane Plus exemptions for aerospace, space and defence, medical imaging and radiotherapy applications
- 2030-08-04: Expiry of the UV-328 exemptions for land-based motor vehicles, industrial and heavy-duty coatings, blood collection tubes, polarisers, photographic paper and aircraft
- 2043-12-31: Latest end of the spare-part exemptions for UV-328 and Dechlorane Plus in motor vehicles, industrial machines and instruments, unless the service life ends earlier

## What you must do

### Manufacturer or formulator

- Do not manufacture an Annex I substance, on its own, in a mixture or in an article, and do not place such substances, mixtures or articles on the market or use them, unless Article 4 or the entry itself allows it.
- Keep any residual presence of a listed substance below the unintentional-trace limit in its entry, for example 0,025 mg/kg for PFOA, PFOS and PFHxS and their salts, 1 mg/kg for their related compounds, 10 mg/kg for the sum of the five PBDEs, 75 mg/kg for HBCDD, 0,01 mg/kg for methoxychlor and, from 30 September 2026, 0,01 mg/kg for chlorpyrifos; where an entry sets no limit there is no tolerance.
- If you rely on a specific exemption, stay within its purpose and end date and meet its conditions: articles in which decaBDE is used must be identifiable by labelling or other means throughout their life cycle, PFOA fire-fighting foam may not be used for training, and PFOA in installed foam is tolerated only up to 1 mg/kg and 10 mg/kg until 3 August 2028.
- If you rely on a specific exemption, you may use it only within its purpose and end date and under its conditions; PFOA fire-fighting foam may not be used for training, and PFOA in installed foam is tolerated only up to 1 mg/kg and 10 mg/kg until 3 August 2028.
- Make articles in which decaBDE is used under a specific exemption identifiable by labelling or other means throughout their life cycle.
- Manufacture or use a Part A substance as a closed-system site-limited intermediate only where the entry carries an annotation, your Member State has notified the Convention Secretariat, and you have demonstrated to the competent authority that the process transforms the substance into non-POPs under rigorous containment and reported actual or estimated quantities and residual contamination.
- Manage a stockpile of a listed substance for which no use is permitted as waste, and report a stockpile above 50 kg of a substance still permitted to the competent authority within 12 months of its listing and annually thereafter, keeping it in a safe, efficient and environmentally sound manner.
- Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size.
- As a producer of waste, undertake all reasonable efforts to avoid contaminating it with Annex IV substances, and make sure waste above the Annex IV limits goes to destruction or irreversible transformation rather than recycling.

### Importer

- Do not import substances, mixtures or articles containing an Annex I substance above its unintentional-trace limit: import is placing on the market, and the prohibition in Article 3(1) applies to it without any company-size threshold.
- Obtain evidence from your suppliers, and test where needed, that textiles, coatings, plastics, electronics and other articles respect the entry limits, in particular the 0,025 mg/kg limits for PFOA, PFOS and PFHxS and their salts, 1 mg/kg for their related compounds, 0,15 % by weight for SCCPs in articles, 10 mg/kg for the PBDE sum in articles not made of recovered material, 100 mg/kg for UV-328 until 4 August 2027 and 1 000 mg/kg for Dechlorane Plus until 15 April 2028.
- For articles from recovered material, apply the derogation limits for the PBDE sum of 350 mg/kg until 29 December 2027 and 200 mg/kg thereafter, and for toys and childcare products 350 mg/kg until 16 May 2027 and 10 mg/kg from 17 May 2027; food contact materials get no derogation.
- Import articles containing decaBDE, UV-328 or Dechlorane Plus only for the purposes and until the dates in the entry: imported decaBDE articles under the specific exemptions are allowed until those exemptions expire and must be labelled as if produced under the exemption; UV-328 articles for motor vehicles, coatings, blood collection tubes, polarisers, photographic paper and aircraft until 4 August 2030; Dechlorane Plus for aerospace, defence, medical imaging and radiotherapy until 26 February 2030.
- Articles containing decaBDE, UV-328 or Dechlorane Plus may be imported only for the purposes and until the dates in the entry: decaBDE articles until the specific exemptions expire, UV-328 articles for the listed uses until 4 August 2030, Dechlorane Plus for aerospace, defence, medical imaging and radiotherapy until 26 February 2030.
- Label imported articles containing decaBDE under a specific exemption as if they had been produced under that exemption, so that they are identifiable throughout their life cycle.
- When a substance is newly added to Annex I, articles produced before or on the date the regulation becomes applicable to it may still be placed on the market for six months; after that, only articles already in use may continue to be used.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months and annually thereafter, and manage stockpiles of substances with no permitted use as waste.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size.
- Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner.

### Distributor, retailer or downstream user

- Do not place on the market or use substances, mixtures or articles containing an Annex I substance above its unintentional-trace limit; the prohibition binds every person in the supply chain, not only the manufacturer or importer.
- Check that goods made of recycled plastic or polystyrene respect the recovered-material limits for the PBDE sum (350 mg/kg until 29 December 2027, 200 mg/kg from 30 December 2027; 10 mg/kg for toys and childcare products from 17 May 2027) and for HBCDD (75 mg/kg, 100 mg/kg only in recycled polystyrene for EPS and XPS building insulation).
- Distinguish articles already in use, which may continue to be used, from second-hand sales: an entry that allows only 'use' of articles in use before its listing date does not authorise placing them on the market again, whereas the endosulfan, hexachlorobutadiene and polychlorinated naphthalene entries allow 'placing on the market and use' of articles in use before or on 10 July 2012.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, and manage unsellable stock of a substance with no permitted use as waste under Article 7.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size.
- Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner.
- Hand over recalled or unsellable stock to the disposal route the Danish supervisory authority orders; under kemikalieloven the authority can require a product to be recalled from dealers and users and destroyed, and dealers and users must return it as instructed.

### Holder of a stockpile, producer or holder of waste, waste operator

- As a producer or holder of waste, undertake all reasonable efforts to avoid contaminating waste with Annex IV substances.
- Dispose of or recover waste consisting of, containing or contaminated by an Annex IV substance above its limit without undue delay through an Annex V Part 1 operation (physico-chemical treatment D9, incineration D10, energy recovery R1 except for PCB waste, or restricted metal recovery R4) so that the POP content is destroyed or irreversibly transformed; a listed substance may be isolated during pre-treatment only if it is then destroyed the same way.
- Do not carry out disposal or recovery operations that may lead to the recovery, recycling, reclamation or re-use of an Annex IV substance on its own.
- Waste with a POP content below the Annex IV limits may be otherwise disposed of or recovered under ordinary Union waste law; for the wastes in Annex V Part 2, such as fly ash, soil and stones or chimney-sweeping waste, the competent authority may in exceptional cases authorise permanent storage up to the Part 2 limits once you have shown that decontamination is not feasible and destruction is not the environmentally preferable option, and have provided information on the POP content.
- Keep the control and traceability records required by Article 17 of Directive 2008/98/EC for waste containing or contaminated by an Annex IV substance; Member States must ensure this control.
- As the holder of a stockpile, manage a stockpile of a substance with no permitted use as waste, and report a stockpile above 50 kg of a substance still permitted within 12 months of its listing and annually thereafter, managing it in line with the thresholds and requirements of Directive 2012/18/EU.
- Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner, in line with the thresholds and requirements of Directive 2012/18/EU.
- Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size.
- Apply the transitional ash limits: 5 μg/kg for PCDD/PCDF and dioxin-like PCBs in fly ashes from biomass units since 31 December 2023 and in ashes and soot from private households since 1 January 2025.

## Requirements

Each duty above as an identified requirement (22); ids are permanent and shared with the compliance engine.

### evidence

- `pops-mfr-manufacture-annex-substance` (Manufacturer or formulator, product, before-market) — Do not manufacture an Annex I substance, on its own, in a mixture or in an article, and do not place such substances, mixtures or articles on the market or use them, unless Article 4 or the entry itself allows it. [Art. 3(1) and Art. 4]
- `pops-mfr-keep-residual-presence` (Manufacturer or formulator, product, before-market) — Keep any residual presence of a listed substance below the unintentional-trace limit in its entry, for example 0,025 mg/kg for PFOA, PFOS and PFHxS and their salts, 1 mg/kg for their related compounds, 10 mg/kg for the sum of the five PBDEs, 75 mg/kg for HBCDD, 0,01 mg/kg for methoxychlor and, from 30 September 2026, 0,01 mg/kg for chlorpyrifos; where an entry sets no limit there is no tolerance. [Art. 4(1)(b) and Annex I, Part A; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1423 · Annex]
- `pops-imp-import-substances-mixtures` (Importer, product, before-market) — Do not import substances, mixtures or articles containing an Annex I substance above its unintentional-trace limit: import is placing on the market, and the prohibition in Article 3(1) applies to it without any company-size threshold. [Art. 2(1), Art. 2(7) and Art. 3(1)]
- `pops-imp-obtain-evidence-suppliers` (Importer, product, before-market) — Obtain evidence from your suppliers, and test where needed, that textiles, coatings, plastics, electronics and other articles respect the entry limits, in particular the 0,025 mg/kg limits for PFOA, PFOS and PFHxS and their salts, 1 mg/kg for their related compounds, 0,15 % by weight for SCCPs in articles, 10 mg/kg for the PBDE sum in articles not made of recovered material, 100 mg/kg for UV-328 until 4 August 2027 and 1 000 mg/kg for Dechlorane Plus until 15 April 2028. [Art. 4(1)(b) and Annex I, Part A]
- `pops-imp-apply-derogation-limits` (Importer, product, before-market) — For articles from recovered material, apply the derogation limits for the PBDE sum of 350 mg/kg until 29 December 2027 and 200 mg/kg thereafter, and for toys and childcare products 350 mg/kg until 16 May 2027 and 10 mg/kg from 17 May 2027; food contact materials get no derogation. [Annex I, Part A, PBDE entries, point 2]
- `pops-dist-place-market-use` (Distributor, retailer or downstream user, product, before-market) — Do not place on the market or use substances, mixtures or articles containing an Annex I substance above its unintentional-trace limit; the prohibition binds every person in the supply chain, not only the manufacturer or importer. [Art. 2(1), Art. 2(6) and Art. 3(1)]

### mark

- `pops-mfr-label-decabde-articles` (Manufacturer or formulator, product, before-market) — Make articles in which decaBDE is used under a specific exemption identifiable by labelling or other means throughout their life cycle. [Annex I, Part A, decaBDE entry, point 6]
- `pops-imp-label-decabde-articles` (Importer, product, before-market) — Label imported articles containing decaBDE under a specific exemption as if they had been produced under that exemption, so that they are identifiable throughout their life cycle. [Annex I, Part A, decaBDE entry, points 6 and 7]

### submission

- `pops-mfr-manufacture-use-part` (Manufacturer or formulator, product, before-market) — Manufacture or use a Part A substance as a closed-system site-limited intermediate only where the entry carries an annotation, your Member State has notified the Convention Secretariat, and you have demonstrated to the competent authority that the process transforms the substance into non-POPs under rigorous containment and reported actual or estimated quantities and residual contamination. [Art. 2(11) and Art. 4(3)]
- `pops-mfr-report-stockpile` (Manufacturer or formulator, company, periodic) — Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size. [Art. 5(2)]
- `pops-imp-report-stockpile` (Importer, company, periodic) — Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size. [Art. 5(2)]
- `pops-dist-report-stockpile` (Distributor, retailer or downstream user, company, periodic) — Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size. [Art. 5(2)]
- `pops-oth-report-stockpile` (Holder of a stockpile, producer or holder of waste, waste operator, company, periodic) — Report a stockpile above 50 kg of a listed substance whose use is still permitted to the competent authority within 12 months of its listing and annually thereafter, with its nature and size. [Art. 5(2)]

### verification

- `pops-dist-check-goods-made` (Distributor, retailer or downstream user, product, before-market) — Check that goods made of recycled plastic or polystyrene respect the recovered-material limits for the PBDE sum (350 mg/kg until 29 December 2027, 200 mg/kg from 30 December 2027; 10 mg/kg for toys and childcare products from 17 May 2027) and for HBCDD (75 mg/kg, 100 mg/kg only in recycled polystyrene for EPS and XPS building insulation). [Annex I, Part A, PBDE entries, point 2; HBCDD entry, point 1]

### standing

- `pops-mfr-manage-stockpile-waste` (Manufacturer or formulator, company, ongoing) — Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner. [Art. 5(1) and Art. 5(2)]
- `pops-imp-manage-stockpile-waste` (Importer, company, ongoing) — Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner. [Art. 5(1) and Art. 5(2)]
- `pops-dist-manage-stockpile-waste` (Distributor, retailer or downstream user, company, ongoing) — Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner. [Art. 5(1) and Art. 5(2)]
- `pops-oth-manage-stockpile-waste` (Holder of a stockpile, producer or holder of waste, waste operator, company, ongoing) — Manage a stockpile consisting of or containing a listed substance for which no use is permitted as waste, and keep any permitted stockpile in a safe, efficient and environmentally sound manner, in line with the thresholds and requirements of Directive 2012/18/EU. [Art. 5(1) and Art. 5(2)]

## Penalties

Member States lay down the rules on penalties for infringements of the regulation and take all measures necessary to ensure they are implemented; the penalties must be effective, proportionate and dissuasive and had to be notified to the Commission by 16 July 2020. Each Member State designates the competent authorities responsible for administration and enforcement, reports on enforcement activities, infringements and penalties, and coordinates enforcement through the Forum for Exchange of Information on Enforcement at the European Chemicals Agency. Market surveillance draws on Regulation (EU) 2019/1020, whose Annex I lists Regulation (EC) No 850/2004, read as Regulation (EU) 2019/1021 since the recast repealed it. In Denmark, the regulation is enforced under lov om kemikalier (kemikalieloven): Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) supervises, the supervisory authority must have an unlawful situation legalised and can order the responsible party to stop sales, inform users of the danger, remedy the cause, recall the substance, mixture or article from dealers and users and destroy it, seize unlawful goods, order the owner of an online interface to change or remove content that refers to non-compliant substances, mixtures or articles (§ 50) and, where such an order is not complied with or unlawful sales are repeated, have the online interface blocked by court order at its request (§ 50 a); infringements of EU regulations on substances, mixtures and articles covered by the law are punished with a fine, rising to imprisonment of up to two years where the infringement was intentional or grossly negligent and caused harm or danger to human or animal health or the environment or where the offender obtained or intended an economic advantage, and companies can be held criminally liable. The waste rules of Article 7 and Annexes IV and V are enforced separately in Denmark under the environmental protection act (miljøbeskyttelsesloven) and the waste order, through the municipalities and Miljøstyrelsen.

## Checklist

1. Screen every product family for the 32 Annex I substances, in particular PFAS coatings and treatments (PFOA, PFOS, PFHxS), brominated flame retardants (the five PBDEs, HBCDD, hexabromobiphenyl), SCCPs in plastics and rubber, UV-328 in plastics and coatings, Dechlorane Plus in electronics and adhesives, and chlorpyrifos from 30 September 2026 (Article 3(1) and Annex I).
2. Collect supplier declarations and, where the risk warrants it, test reports against the unintentional-trace limit of each entry, remembering that entries without a limit allow no tolerance at all (Article 4(1)(b) and Annex I).
3. Treat recycled-content products separately: track the PBDE sum against 350 mg/kg until 29 December 2027 and 200 mg/kg thereafter, the 10 mg/kg limit for toys and childcare products from 17 May 2027, and the HBCDD limits of 75 mg/kg or 100 mg/kg (Annex I, PBDE and HBCDD entries).
4. Map each use of a listed substance to a specific exemption in its entry, record its end date and conditions, and plan substitution before it expires: UV-328 and Dechlorane Plus exemptions run to 2030, spare-part exemptions to the end of service life or 31 December 2043 (Annex I, Part A).
5. Diarise the step-downs: PBDE 350 to 200 mg/kg on 30 December 2027, UV-328 100 to 10 mg/kg on 4 August 2027 and 1 mg/kg on 4 August 2029, Dechlorane Plus 1 000 to 1 mg/kg after 15 April 2028, PFOA foam limits until 3 August 2028 (Annex I, Part A).
6. Check stockpiles: manage stock of a substance with no permitted use as waste, and notify stockpiles above 50 kg of substances still permitted to the competent authority within 12 months and annually thereafter (Article 5).
7. Plan end-of-life: waste above the Annex IV limits must be destroyed or irreversibly transformed through an Annex V Part 1 operation and may not be recycled, and traceability under Article 17 of Directive 2008/98/EC must be kept (Article 7 and Annexes IV and V).
8. Follow the delegated acts that add substances or change limits, one per substance, and the Commission's reviews of the Annex IV waste limits due by 30 December 2027 (Article 15 and Annex IV).
9. Cross-check REACH Annex XVII, the RoHS Directive and the Toy Safety Directive, which the POPs entries refer to for electrical equipment, toys and food contact materials, so the same substance is handled consistently (Annex I, PBDE entries).

## Questions

### Which substances does the POPs Regulation ban?

Annex I Part A lists 32 entries as of 1 January 2026: tetra-, penta-, hexa-, hepta- and decabromodiphenyl ether, PFOS, DDT, chlordane, hexachlorocyclohexanes including lindane, dieldrin, endrin, heptachlor, endosulfan, hexachlorobenzene, chlordecone, aldrin, pentachlorobenzene, PCBs, mirex, toxaphene, hexabromobiphenyl, hexabromocyclododecane, hexachlorobutadiene, pentachlorophenol, polychlorinated naphthalenes, short-chain chlorinated paraffins, PFOA, dicofol, PFHxS, methoxychlor, UV-328 and Dechlorane Plus. Chlorpyrifos becomes the 33rd entry on 30 September 2026. Their manufacturing, placing on the market and use is prohibited, on their own, in mixtures or in articles; Annex I Part B and Annex II currently list no substances.

### What are the PFAS limits under the POPs Regulation?

PFOA, PFOS and PFHxS with their salts are tolerated only as unintentional trace contaminants up to 0,025 mg/kg (0,0000025 % by weight) in substances, mixtures and articles, and their related compounds up to 1 mg/kg as a sum; the PFOS values apply since 3 December 2025. Higher limits exist for narrow cases: 20 mg/kg for PFOA-related compounds in transported isolated intermediates for C6 fluorochemicals, 2 mg/kg in non-invasive medical devices, 1 mg/kg and 10 mg/kg in fire-fighting foam already installed in systems until 3 August 2028, and 0,1 mg/kg for PFHxS in concentrated fire-fighting foam mixtures. Waste containing PFOA or PFHxS above 1 mg/kg for the acid and its salts, or 40 mg/kg for the sum of related compounds, must be destroyed.

### What is an unintentional trace contaminant?

A level of a substance that is incidentally present in a minimal amount, below which the substance cannot be meaningfully used, and above the detection limit of existing detection methods to enable control and enforcement. Article 3 does not apply to a substance present as an unintentional trace contaminant as specified in its Annex I entry, so each entry sets the tolerated concentration; where an entry sets none, any presence is prohibited.

### Can I sell products made from recycled plastic that contains brominated flame retardants?

Only within the derogation limits. Mixtures and articles containing or made of recovered material may contain the sum of tetra-, penta-, hexa-, hepta- and decaBDE up to 350 mg/kg until 29 December 2027 and 200 mg/kg from 30 December 2027; toys and products for children's seating, sleep, hygiene, feeding, transport and protection from recovered material up to 350 mg/kg until 16 May 2027 and 10 mg/kg from 17 May 2027; all other mixtures and articles 10 mg/kg. Food contact materials get no derogation. Recycled polystyrene for EPS and XPS building insulation may contain HBCDD up to 100 mg/kg, otherwise 75 mg/kg. Waste above 350 mg/kg PBDE, or 200 mg/kg from 30 December 2027, may not be recycled and must be destroyed.

### How does the POPs Regulation treat waste?

Waste consisting of, containing or contaminated by an Annex IV substance above its concentration limit must be disposed of or recovered without undue delay so that the POP content is destroyed or irreversibly transformed, through physico-chemical treatment (D9), incineration (D10), energy recovery (R1, not for PCB waste) or restricted metal recovery (R4) as listed in Annex V Part 1. Recovery, recycling, reclamation or re-use of the POP itself is prohibited. Waste below the Annex IV limits may be handled under ordinary waste law, and for the wastes in Annex V Part 2 a competent authority may exceptionally allow permanent storage up to higher limits. Annex IV has 30 rows, with 50 mg/kg for most pesticides and PCBs, 1 500 mg/kg for SCCPs, 500 mg/kg for HBCDD and 5 μg/kg for dioxins and dioxin-like PCBs.

### Are products that were already on the market before a substance was listed exempt?

Articles already in use before or on the date the regulation, or Regulation (EC) No 850/2004, became applicable to the substance may continue to be used, and for a substance added after 15 July 2019 articles produced before or on the listing date may still be supplied for six months. The entries add specific rules: decaBDE articles in use before 15 July 2019, PFOA articles in use before 4 July 2020 and PFOS or PBDE articles in use before 25 August 2010 may be used, and articles in use when an exemption for PFOA, UV-328 or Dechlorane Plus expires may continue to be used. Continued use does not mean the article may be placed on the market again unless the entry says so.

### Who enforces the POPs Regulation in Denmark and what are the penalties?

Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) supervises under lov om kemikalier (kemikalieloven), which lets the supervisory authority order sales stopped, products recalled from dealers and users and destroyed, seize unlawful goods, order the owner of an online interface to change or remove content that refers to non-compliant substances, mixtures or articles (§ 50) and, where such an order is not complied with or unlawful sales are repeated, have the online interface blocked by court order at its request (§ 50 a). Infringing an EU regulation on substances, mixtures and articles covered by the law is punished with a fine, and the penalty can rise to imprisonment of up to two years for intentional or grossly negligent infringements that harm or endanger health or the environment or where the offender obtained or intended an economic advantage; companies can be fined as legal persons. The regulation itself requires Member State penalties to be effective, proportionate and dissuasive.

### How are new substances added to the POPs Regulation?

Substances enter the annexes by Commission delegated act, one per substance, after the Union has supported their listing under the Stockholm Convention or the UNECE Protocol by a Council decision, or to adapt existing entries to scientific and technical progress; Annexes IV and V are amended the same way since 1 January 2026. The European Chemicals Agency supports the Commission, publishes a notice and an eight-week consultation when a listing proposal is prepared, and reports on the impacts of new waste limits within 12 months of a Commission request. Delegated acts enter into force only if neither the European Parliament nor the Council objects within two months, extendable by two months.

## What changed

- 2027-12-30 (applies): **PBDE limit for recovered material falls to 200 mg/kg; waste-limit reviews due** — The sum of the five PBDEs in mixtures and articles containing or made of recovered material, and in waste, is limited to 200 mg/kg from this date; the Commission must by the same date have reviewed the Annex IV limits for SCCPs, PCDD/PCDF and dioxin-like PCBs, HBCDD, PFOA and PFHxS and, where appropriate, lowered them by delegated act.
- 2027-08-04 (applies): **UV-328 unintentional-trace limit falls to 10 mg/kg** — Two years after the listing, UV-328 is tolerated in substances, mixtures and articles only up to 10 mg/kg (0,001 % by weight); the limit falls to 1 mg/kg on 4 August 2029.
- 2027-05-17 (applies): **PBDE limit of 10 mg/kg for toys and childcare products from recovered material** — Toys under Directive 2009/48/EC and products facilitating children's seating, sleep, relaxation, hygiene, changing and general body care, feeding, sucking, transportation and protection that contain or are made of recovered material may contain the five PBDEs only up to a sum of 10 mg/kg.
- 2026-09-30 (amendment): **Delegated Regulation (EU) 2026/1423 in force: chlorpyrifos listed** — Chlorpyrifos, listed in Annex A to the Stockholm Convention at the twelfth Conference of the Parties in 2025, is added to Annex I Part A without specific exemptions and with an unintentional-trace limit of 0,01 mg/kg (0,000001 % by weight) in substances, mixtures and articles; the act was adopted on 30 June 2026 and published on 10 September 2026.
- 2026-09-11 (guidance): **Guide rewritten from the consolidated text of 1 January 2026** — The body was rebuilt from the consolidated text, the 18 amending acts and the Danish kemikalielov: it now states that Annex I Part B and Annex II hold no substances (the earlier text described Annex II as a list of restricted substances), gives the current unintentional-trace and waste limits with their step-down dates, and names the Danish supervisory authority and penalty provisions.
- 2026-01-01 (amendment): **Regulation (EU) 2025/2457 in force: Agency reports and delegated acts for the waste annexes** — The European Chemicals Agency reports within 12 months of a Commission request on the impacts of new or amended Annex IV and V limits, with an opinion of its Committee for Socioeconomic Analysis; Annexes IV and V are now amended by delegated act, the delegation of power runs for five years from 1 January 2026, environmental monitoring data may be reported through the European Environment Agency, and the Annex IV review clauses now point to delegated acts by 30 December 2027.
- 2025-12-30 (applies): **PBDE limits fall to 350 mg/kg in recovered material and in waste** — The sum of tetra-, penta-, hexa-, hepta- and decaBDE in mixtures and articles containing or made of recovered material, including toys and childcare products, is limited to 350 mg/kg, and the Annex IV waste limit for the same sum falls from 500 mg/kg to 350 mg/kg.
- 2025-12-03 (applies): **PFOS limits aligned with PFOA; PFOA fire-fighting foam derogation ends** — Points 2 and 3 of the Annex to Delegated Regulation (EU) 2025/718 apply: PFOS and its salts are tolerated only up to 0,025 mg/kg and PFOS-related compounds up to 1 mg/kg as a sum. The same day the derogation for using PFOA-containing fire-fighting foam already installed in systems ends; residual PFOA in such foam is tolerated up to 1 mg/kg and 10 mg/kg until 3 August 2028.
- 2025-11-17 (amendment): **Delegated Regulation (EU) 2025/1482 in force: new PBDE limits for mixtures and articles** — The general unintentional-trace limit for the sum of the five PBDEs in mixtures and articles is 10 mg/kg, with derogations for recovered material (500 mg/kg, then 350 mg/kg from 30 December 2025 and 200 mg/kg from 30 December 2027) and for toys and childcare products from recovered material (500 mg/kg, 350 mg/kg from 30 December 2025 and 10 mg/kg from 17 May 2027); food contact materials are excluded from the derogations.
- 2025-10-15 (amendment): **Delegated Regulation (EU) 2025/1930 in force: Dechlorane Plus listed** — Dechlorane Plus, including its syn- and anti-isomers, is added to Annex I Part A with an unintentional-trace limit of 1 000 mg/kg until 15 April 2028 and 1 mg/kg thereafter, exemptions until 26 February 2030 for aerospace, space and defence, medical imaging and radiotherapy, and spare-part and repair exemptions until the end of service life or 31 December 2043; the Commission assesses prolongation by 1 April 2028.
- 2025-08-04 (amendment): **Delegated Regulation (EU) 2025/843 in force: UV-328 listed** — UV-328 is added to Annex I Part A with an unintentional-trace limit of 100 mg/kg, falling to 10 mg/kg on 4 August 2027 and 1 mg/kg on 4 August 2029, and exemptions until 4 August 2030 for land-based motor vehicles, industrial and heavy-duty coatings, blood collection tube separators, polariser film, photographic paper and aircraft, plus spare-part exemptions to the end of service life or 31 December 2043.
- 2025-08-03 (amendment): **Delegated Regulation (EU) 2025/1399 in force: PFOA fire-fighting foam extended to 3 December 2025** — The use of PFOA-containing fire-fighting foam already installed in systems is extended from 4 July 2025 to 3 December 2025, residual PFOA in such foam is tolerated up to 1 mg/kg and 10 mg/kg until 3 August 2028, fluorine-free foam from cleaned equipment up to 10 mg/kg, fire-fighting foam is defined, the review clauses for intermediates and medical devices are deleted, and articles in use when an exemption expires may continue to be used.
- 2025-07-17 (amendment): **Delegated Regulation (EU) 2025/718 in force: PFOS entry renamed, plating exemption deleted** — The PFOS entry is renamed 'PFOS, its salts and PFOS-related compounds', the hard chromium plating exemption that ran until 7 September 2025 and the point on analytical methods are deleted, and the new limits of 0,025 mg/kg and 1 mg/kg apply from 3 December 2025.
- 2024-10-17 (amendment): **Delegated Regulations (EU) 2024/2555 and 2024/2570 in force: HBCDD limit lowered, methoxychlor listed** — The unintentional-trace limit for hexabromocyclododecane falls from 100 mg/kg to 75 mg/kg, with 100 mg/kg kept for recycled polystyrene in EPS and XPS building insulation and a review by 1 January 2026; methoxychlor is added to Annex I Part A with a limit of 0,01 mg/kg and no exemptions.
- 2023-08-28 (amendment): **Delegated Regulation (EU) 2023/1608 in force: PFHxS listed** — PFHxS, its salts and PFHxS-related compounds are added to Annex I Part A without specific exemptions, with limits of 0,025 mg/kg for PFHxS and its salts, 1 mg/kg for the sum of related compounds and 0,1 mg/kg in concentrated fire-fighting foam mixtures, the last to be reviewed by 28 August 2026.
- 2023-06-10 (applies): **Regulation (EU) 2022/2400 applies: new waste limits in Annexes IV and V** — The Annex IV limits become 500 mg/kg for the sum of the five PBDEs, 1 500 mg/kg for SCCPs, 5 μg/kg for PCDD/PCDF together with dioxin-like PCBs and 500 mg/kg for HBCDD, with new rows for pentachlorophenol (100 mg/kg), dicofol (50 mg/kg), PFOA (1 mg/kg and 40 mg/kg) and PFHxS (1 mg/kg and 40 mg/kg); Annex V Part 2 gains matching limits and the dioxin-like PCB toxic equivalency factors, and transitional values apply to ashes under Article 21a.
- 2023-05-18 (amendment): **Delegated Regulation (EU) 2023/866 in force: PFOA in PTFE micropowders** — Applying from 18 August 2023, the 1 mg/kg limit for PFOA in PTFE micropowders is confined to micropowders transported or treated to bring the content below 0,025 mg/kg, the review of the intermediate limit moves to 25 August 2023, and the exemption for PFOA in PTFE and PVDF manufacture is deleted because it was no longer used in the Union.
- 2022-12-29 (amendment): **Regulation (EU) 2022/2400 in force** — Adopted on 23 November 2022 and published on 9 December 2022, the regulation amending Annexes IV and V entered into force on the twentieth day after publication and applies from 10 June 2023; it also inserted the transitional Article 21a on ashes and asked the Commission to assess classifying POPs waste above the Annex IV limits as hazardous within 36 months.
- 2022-12-13 (amendment): **Delegated Regulation (EU) 2022/2291 in force: hexachlorobenzene limit** — An unintentional-trace limit of 10 mg/kg (0,001 % by weight) is set for hexachlorobenzene in substances, mixtures and articles, after the substance was found as an impurity in pesticides, solvents, inks, coatings, paints, toners, wood and textile applications and plastics.
- 2021-03-15 (amendment): **Delegated Regulation (EU) 2021/277 in force: pentachlorophenol limit** — An unintentional-trace limit of 5 mg/kg (0,0005 % by weight) is set for pentachlorophenol and its salts and esters in substances, mixtures and articles, to allow the recycling of wood chips and facilitate enforcement.
- 2021-02-22 (amendment): **Delegated Regulation (EU) 2021/115 in force: PFOA entry adjusted** — The PFOA entry gains a 2 mg/kg limit for medical devices other than invasive and implantable devices, the intermediate limit is clarified to fluorochemicals with a perfluoro carbon chain of six atoms or fewer, and the 400 kilogray condition for PTFE micropowders is removed.
- 2020-09-07 (amendment): **Delegated Regulations (EU) 2020/1203 and 2020/1204 in force: PFOS plating exemption, dicofol listed** — The PFOS exemption for mist suppressants in non-decorative hard chromium (VI) plating in closed-loop systems is limited to 7 September 2025 with reporting by 7 September 2024, and dicofol is added to Annex I Part A without any exemption.
- 2020-07-04 (amendment): **Delegated Regulation (EU) 2020/784 applies: PFOA listed** — PFOA, its salts and PFOA-related compounds are added to Annex I Part A with unintentional-trace limits of 0,025 mg/kg and 1 mg/kg, time-limited exemptions for semiconductors, photographic coatings, protective textiles, medical devices and installed fire-fighting foam, and a transitional derogation until 3 December 2020; the act applies from 4 July 2020, the date the REACH restriction on PFOA would have started to apply.
- 2019-07-15 (in-force): **Regulation (EU) 2019/1021 enters into force** — Adopted on 20 June 2019 as a recast of Regulation (EC) No 850/2004 and published in OJ L 169 on 25 June 2019, the regulation entered into force on the twentieth day after publication, repealed Regulation (EC) No 850/2004 and applies directly in all Member States; Member States had until 15 October 2019 to name their competent authorities and until 16 July 2020 to notify their penalty rules.

## POPs in plain terms

The POPs Regulation, formally Regulation (EU) 2019/1021 on persistent organic pollutants, protects human health and the environment from POPs by prohibiting, phasing out as soon as possible or restricting the manufacturing, placing on the market and use of the substances subject to the Stockholm Convention and the Protocol on POPs to the 1979 Convention on Long-Range Transboundary Air Pollution, by minimising their releases, and by laying down rules for waste consisting of, containing or contaminated by them (Art. 1). It is a recast of Regulation (EC) No 850/2004, which it repealed when it entered into force on 15 July 2019 (Art. 21 and Art. 22). As a regulation it applies directly in every Member State, and Member States may apply stricter requirements in accordance with the TFEU (Art. 1).

The operative rule is short: the manufacturing, placing on the market and use of the substances listed in Annex I, whether on their own, in mixtures or in articles, is prohibited, subject to the exemptions in Article 4 (Art. 3(1)). The definitions of substance, mixture, article, manufacturing, use, import and placing on the market are borrowed from REACH (Art. 2), so the regulation reaches consumer goods such as textiles, plastics, coatings and electronics as much as it reaches chemical producers. Because the listed substances persist and accumulate, the prohibition is close to absolute: a substance is tolerated only as an unintentional trace contaminant at the concentration set in its entry, or under a specific, time-limited exemption.

> **Official text**
> Read the regulation on EUR-Lex: [Regulation (EU) 2019/1021 (CELEX 32019R1021)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1021), or the [consolidated text of 1 January 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1021-20260101) that incorporates the 17 amending acts adopted up to then; [Delegated Regulation (EU) 2026/1423](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1423) adds chlorpyrifos from 30 September 2026.

## Scope

Annex I Part A lists the substances that are in the Convention and the Protocol or in the Convention alone. As of 1 January 2026 it holds 32 entries: tetra-, penta-, hexa-, hepta- and decabromodiphenyl ether, PFOS, DDT, chlordane, hexachlorocyclohexanes including lindane, dieldrin, endrin, heptachlor, endosulfan, hexachlorobenzene, chlordecone, aldrin, pentachlorobenzene, PCBs, mirex, toxaphene, hexabromobiphenyl, hexabromocyclododecane (HBCDD), hexachlorobutadiene, pentachlorophenol, polychlorinated naphthalenes, short-chain chlorinated paraffins (SCCPs), PFOA, dicofol, PFHxS, methoxychlor, UV-328 and Dechlorane Plus. Chlorpyrifos becomes the 33rd entry on 30 September 2026 (Delegated Regulation (EU) 2026/1423). Annex I Part B, for substances listed only in the Protocol, and Annex II, for substances subject to restriction rather than prohibition, currently contain no entries (Annex I and Annex II). Annex III names the substances whose releases Member States must inventory and reduce: dioxins and furans and PCBs in Part A, and hexachlorobenzene, polycyclic aromatic hydrocarbons, pentachlorobenzene, hexachlorobutadiene and polychlorinated naphthalenes in Part B (Art. 6 and Annex III). Annex IV lists 30 substances with the concentration limits above which waste must be destroyed (Art. 7 and Annex IV).

Article 4 carves out three situations. A substance used for laboratory-scale research or as a reference standard is outside Article 3 (Art. 4(1)(a)). A substance present as an unintentional trace contaminant, as specified in its entry, is outside Article 3 (Art. 4(1)(b)); an unintentional trace contaminant is a level that is incidentally present in a minimal amount, below which the substance cannot be meaningfully used, and above the detection limit of existing methods (Art. 2(12)). And a substance in articles already in use before the regulation or Regulation (EC) No 850/2004 became applicable to it is outside Article 3, with a six-month window for articles produced before a substance listed after 15 July 2019 became covered (Art. 4(2)). A Member State may in addition permit manufacturing and use as a closed-system site-limited intermediate, but only where the entry carries an annotation, the Convention Secretariat has been notified and the manufacturer has demonstrated rigorous containment and transformation to the competent authority (Art. 4(3)).

The regulation binds activities rather than a closed list of operators: whoever manufactures, imports, places on the market or uses a listed substance is caught (Art. 2 and Art. 3(1)). Holders of stockpiles and producers, holders and treaters of waste carry the duties in Articles 5 and 7.

## The listed substances and their limits

Each Annex I entry sets its own tolerance. PFOA, PFOS and PFHxS with their salts are tolerated up to 0,025 mg/kg (0,0000025 % by weight) in substances, mixtures and articles and their related compounds up to 1 mg/kg as a sum; the PFOS values apply since 3 December 2025 under Delegated Regulation (EU) 2025/718, which aligned the older PFOS limits with PFOA and deleted the hard chromium plating exemption that had run until 7 September 2025. PFOA keeps narrow, higher limits: 20 mg/kg for related compounds in transported isolated intermediates used to make C6 fluorochemicals, 2 mg/kg in medical devices other than invasive and implantable devices, 1 mg/kg and 10 mg/kg in fire-fighting foam already installed in systems until 3 August 2028, and 10 mg/kg for the sum in fluorine-free foam from cleaned equipment; the derogation for using PFOA foam ended on 3 December 2025 and the derogation for perfluorooctyl bromide in pharmaceutical production is reviewed by 31 December 2026 (Annex I, PFOA entry, points 1 to 7). PFHxS is tolerated up to 0,1 mg/kg in concentrated fire-fighting foam mixtures pending a review by 28 August 2026 (PFHxS entry, point 3).

The five polybrominated diphenyl ethers are limited to 10 mg/kg each in substances and, since 17 November 2025, to a sum of 10 mg/kg in mixtures and articles, with derogations for recovered material of 350 mg/kg until 29 December 2027 and 200 mg/kg thereafter, and for toys and childcare products from recovered material of 350 mg/kg until 16 May 2027 and 10 mg/kg from 17 May 2027; food contact materials get no derogation (PBDE entries, point 2, as replaced by Delegated Regulation (EU) 2025/1482). Electrical and electronic equipment within the RoHS Directive and, for decaBDE, aircraft, aircraft spare parts and spare parts for motor vehicles produced before 15 July 2019 until 2036 or end of service life remain exempt, and articles in which decaBDE is used must be identifiable by labelling throughout their life cycle (PBDE entries, points 3 and 4; decaBDE entry, points 3 to 8). HBCDD is tolerated up to 75 mg/kg, or 100 mg/kg in recycled polystyrene for EPS and XPS building insulation (HBCDD entry, point 1). SCCPs are allowed below 1 % by weight in substances and mixtures and below 0,15 % in articles (SCCP entry, point 1). Pentachlorophenol is tolerated up to 5 mg/kg and hexachlorobenzene up to 10 mg/kg (their entries); methoxychlor up to 0,01 mg/kg (methoxychlor entry), as is chlorpyrifos from 30 September 2026 (Delegated Regulation (EU) 2026/1423).

The two newest entries phase their limits in. UV-328 is tolerated up to 100 mg/kg from 4 August 2025, 10 mg/kg from 4 August 2027 and 1 mg/kg from 4 August 2029, with placing on the market and use in articles allowed until 4 August 2030 for land-based motor vehicles, industrial and heavy-duty coatings, mechanical separators in blood collection tubes, triacetyl cellulose film in polarisers, photographic paper and aircraft, and spare-part exemptions running to the end of service life or 31 December 2043 (UV-328 entry, points 1 to 3). Dechlorane Plus is tolerated up to 1 000 mg/kg until 15 April 2028 and 1 mg/kg after that date, with exemptions until 26 February 2030 for aerospace, space and defence, medical imaging and radiotherapy, spare-part and repair exemptions to the end of service life or 31 December 2043, and a Commission assessment of prolongation by 1 April 2028 (Dechlorane Plus entry, points 1 to 5). Entries without a stated limit, such as DDT, aldrin or dicofol, tolerate no presence at all. Member States must also remove from use equipment containing more than 0,005 % PCBs in volumes above 0,05 dm3 by 31 December 2025 (PCB entry).

## What you must do

Do not manufacture, place on the market or use an Annex I substance, on its own, in a mixture or in an article, above the unintentional-trace limit in its entry, unless Article 4 or the entry itself allows it (Art. 3(1) and Art. 4). In practice this means screening every product family for PFAS treatments, brominated flame retardants, chlorinated paraffins, UV stabilisers and flame-retardant additives, collecting supplier declarations and test evidence against the entry limits, and tracking the step-down dates for PBDEs in recovered material, UV-328 and Dechlorane Plus. Where you rely on an exemption, keep to its purpose, conditions and end date; decaBDE articles must be labelled and PFOA fire-fighting foam may not be used for training (Annex I, decaBDE entry, point 6, and PFOA entry, point 6).

Stockpiles have their own rules. A stockpile of a listed substance for which no use is permitted must be managed as waste under Article 7, and a stockpile above 50 kg of a substance whose use is still permitted must be notified to the competent authority within 12 months of the listing and annually thereafter and managed in a safe, efficient and environmentally sound manner (Art. 5). Member States monitor notified stockpiles (Art. 5(3)).

Waste reaches deep into circular-economy plans. Producers and holders must undertake all reasonable efforts to avoid contaminating waste with Annex IV substances (Art. 7(1)). Waste consisting of, containing or contaminated by an Annex IV substance above its limit must be disposed of or recovered without undue delay so that the POP content is destroyed or irreversibly transformed, through physico-chemical treatment (D9), incineration (D10), energy recovery (R1, excluding PCB waste) or restricted recovery of metals from iron, steel and non-ferrous residues (R4) (Art. 7(2) and Annex V, Part 1). Operations that may lead to recovery, recycling, reclamation or re-use of the POP itself are prohibited (Art. 7(3)). Waste below the Annex IV limits may be handled under ordinary Union waste law, and for the wastes listed in Annex V Part 2 a competent authority may exceptionally authorise permanent storage up to the Part 2 limits once the holder has shown that decontamination is not feasible and destruction is not the environmentally preferable option (Art. 7(4)). Member States ensure control and traceability under Article 17 of Directive 2008/98/EC (Art. 7(6)). The Annex IV limits are 50 mg/kg for most legacy pesticides and PCBs, 100 mg/kg for pentachlorophenol and hexachlorobutadiene, 10 mg/kg for polychlorinated naphthalenes, 1 500 mg/kg for SCCPs, 500 mg/kg for HBCDD, 350 mg/kg for the PBDE sum until 29 December 2027 and 200 mg/kg from 30 December 2027, 1 mg/kg for PFOA or PFHxS and their salts with 40 mg/kg for their related compounds, and 5 μg/kg for dioxins, furans and dioxin-like PCBs, with the SCCP, dioxin, HBCDD, PFOA and PFHxS values under review by 30 December 2027 (Annex IV). Transitional values of 10 μg/kg and 15 μg/kg for ashes ended on 30 December 2023 and 31 December 2024 (Art. 21a).

The annexes move. The Commission amends Annexes I, II and III by delegated act, one per substance, to follow listings under the Convention or the Protocol that the Union has supported, or to adapt entries to scientific and technical progress, and since 1 January 2026 it amends Annexes IV and V the same way (Art. 15). The European Chemicals Agency supports the Commission, publishes listing proposals for an eight-week consultation, and reports within 12 months on the impacts of new waste limits with an opinion of its Committee for Socioeconomic Analysis (Art. 8). Delegated acts take effect only if neither Parliament nor Council objects within two months, extendable by two (Art. 18).

## Enforcement and penalties

Each Member State designates the competent authorities responsible for administration and enforcement (Art. 19) and lays down effective, proportionate and dissuasive penalties, notified to the Commission by 16 July 2020 (Art. 14). Member States report on enforcement activities, infringements and penalties (Art. 13(1)(a)), and the Forum for Exchange of Information on Enforcement at the European Chemicals Agency coordinates the network of national enforcement authorities, involving waste authorities on waste issues (Art. 8(2)). Market surveillance draws on Regulation (EU) 2019/1020, whose Annex I lists Regulation (EC) No 850/2004, read as Regulation (EU) 2019/1021 since the recast repealed it (Regulation (EU) 2019/1020, Art. 2(1) and Annex I, point 16; Regulation (EU) 2019/1021, Art. 21).

In Denmark the regulation is enforced under lov om kemikalier (kemikalieloven, lovbekendtgørelse nr. 1200 af 25. september 2025). The minister can delegate tasks to Miljøstyrelsen (§ 45), and Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) supervises the POPs rules. The supervisory authority must have an unlawful situation legalised and can order the responsible party to stop sales, inform users of the danger, remedy its cause, recall the substance, mixture or article from dealers and users and destroy it, with dealers and users obliged to return recalled goods (§ 48); it can seize unlawful goods (§ 48 b), order the owner of an online interface to change or remove content that refers to non-compliant substances, mixtures or articles (§ 50) and, where such an order is not complied with or unlawful sales are repeated, have the online interface blocked by court order at its request (§ 50 a). Infringing an EU regulation on the substances, mixtures and articles covered by the law is punished with a fine, rising to imprisonment of up to two years where the infringement was intentional or grossly negligent and caused harm or danger to human or animal health or the environment or where the offender obtained or intended an economic advantage (§ 59, stk. 1, nr. 1, and stk. 2, nr. 1 to 3); companies can be held liable as legal persons (§ 60). The waste rules of Article 7 and Annexes IV and V are enforced separately in Denmark under the environmental protection act (miljøbeskyttelsesloven) and the waste order, through the municipalities and Miljøstyrelsen, not under kemikalieloven.

## How Conphora helps

Conphora monitors the POPs Regulation and every delegated act that adds a substance or changes a limit, maps your products and materials against the Annex I entries and the step-down dates that matter to you, and flags where a fluorinated coating, a flame retardant, a UV stabiliser or a recycled input could put you over a limit. The platform helps you gather and keep supplier declarations and test evidence, tracks the exemptions you rely on and their expiry dates, and alerts you when a new listing such as chlorpyrifos or a revised waste limit affects your range, so your compliance stays current across POPs, REACH and RoHS.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Regulation (EU) 2019/1021 on persistent organic pollutants, consolidated text of 1 January 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1021-20260101)
- [Regulation (EU) 2019/1021 as published in OJ L 169, 25 June 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1021)
- [Document information, dates and relationships for CELEX 32019R1021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32019R1021)
- [Commission Delegated Regulation (EU) 2020/784 listing PFOA (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0784)
- [Commission Delegated Regulation (EU) 2020/1203 on the PFOS plating exemption (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R1203)
- [Commission Delegated Regulation (EU) 2020/1204 listing dicofol (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R1204)
- [Commission Delegated Regulation (EU) 2021/115 amending the PFOA entry (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0115)
- [Commission Delegated Regulation (EU) 2021/277 on pentachlorophenol (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0277)
- [Commission Delegated Regulation (EU) 2022/2291 on hexachlorobenzene (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2291)
- [Regulation (EU) 2022/2400 amending Annexes IV and V on waste limits (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2400)
- [Commission Delegated Regulation (EU) 2023/866 on PFOA in PTFE micropowders (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0866)
- [Commission Delegated Regulation (EU) 2023/1608 listing PFHxS (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1608)
- [Commission Delegated Regulation (EU) 2024/2555 on hexabromocyclododecane (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2555)
- [Commission Delegated Regulation (EU) 2024/2570 listing methoxychlor (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2570)
- [Commission Delegated Regulation (EU) 2025/718 on PFOS limits (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0718)
- [Commission Delegated Regulation (EU) 2025/1399 on PFOA in fire-fighting foam (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1399)
- [Commission Delegated Regulation (EU) 2025/843 listing UV-328 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0843)
- [Commission Delegated Regulation (EU) 2025/1930 listing Dechlorane Plus (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1930)
- [Commission Delegated Regulation (EU) 2025/1482 on PBDE limits in recovered material (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1482)
- [Regulation (EU) 2025/2457 on the reattribution of scientific and technical tasks (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2457)
- [Commission Delegated Regulation (EU) 2026/1423 listing chlorpyrifos (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1423)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Waste containing POPs (European Commission, DG Environment)](https://environment.ec.europa.eu/topics/waste-and-recycling/waste-containing-pops_en)
- [Faktaark: Persistente organiske miljøgifte (POP-stoffer) (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-persistente-organiske-miljoegifte-pop-stoffer)
- [Bekendtgørelse af lov om kemikalier, LBK nr. 1200 af 25. september 2025 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1200)

*This guide is for general information and is not legal advice.*

## Sources

- [Regulation (EU) 2019/1021 on persistent organic pollutants, consolidated text of 1 January 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1021-20260101)
- [Regulation (EU) 2019/1021 as published in OJ L 169, 25 June 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1021)
- [Document information, dates and relationships for CELEX 32019R1021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32019R1021)
- [Commission Delegated Regulation (EU) 2020/784 listing PFOA (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0784)
- [Commission Delegated Regulation (EU) 2020/1203 on the PFOS plating exemption (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R1203)
- [Commission Delegated Regulation (EU) 2020/1204 listing dicofol (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R1204)
- [Commission Delegated Regulation (EU) 2021/115 amending the PFOA entry (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0115)
- [Commission Delegated Regulation (EU) 2021/277 on pentachlorophenol (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0277)
- [Commission Delegated Regulation (EU) 2022/2291 on hexachlorobenzene (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2291)
- [Regulation (EU) 2022/2400 amending Annexes IV and V on waste limits (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2400)
- [Commission Delegated Regulation (EU) 2023/866 on PFOA in PTFE micropowders (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0866)
- [Commission Delegated Regulation (EU) 2023/1608 listing PFHxS (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1608)
- [Commission Delegated Regulation (EU) 2024/2555 on hexabromocyclododecane (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2555)
- [Commission Delegated Regulation (EU) 2024/2570 listing methoxychlor (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2570)
- [Commission Delegated Regulation (EU) 2025/718 on PFOS limits (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0718)
- [Commission Delegated Regulation (EU) 2025/1399 on PFOA in fire-fighting foam (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1399)
- [Commission Delegated Regulation (EU) 2025/843 listing UV-328 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0843)
- [Commission Delegated Regulation (EU) 2025/1930 listing Dechlorane Plus (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1930)
- [Commission Delegated Regulation (EU) 2025/1482 on PBDE limits in recovered material (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1482)
- [Regulation (EU) 2025/2457 on the reattribution of scientific and technical tasks (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2457)
- [Commission Delegated Regulation (EU) 2026/1423 listing chlorpyrifos (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1423)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Waste containing POPs (European Commission, DG Environment)](https://environment.ec.europa.eu/topics/waste-and-recycling/waste-containing-pops_en)
- [Faktaark: Persistente organiske miljøgifte (POP-stoffer) (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-persistente-organiske-miljoegifte-pop-stoffer)
- [Bekendtgørelse af lov om kemikalier, LBK nr. 1200 af 25. september 2025 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1200)

_Reviewed 2026-09-24 by Conphora compliance team_