What is the EU POPs Regulation?

The EU POPs Regulation (Regulation (EU) 2019/1021) bans or restricts the manufacture, sale, and use of persistent organic pollutants (POPs). These chemicals pose serious risks to human health and the environment because they persist in nature and build up in living organisms. The regulation covers substances, mixtures, and articles placed on the EU market, and it puts the EU’s commitments under the Stockholm Convention into law. 

For manufacturers, importers, and sellers, that means knowing whether POPs appear in your products, components, and materials. The list keeps growing, with chlorpyrifos, Dechlorane Plus, and UV-328 among the most recent additions. 

Scope of the EU POPs Regulation

POPs are regulated worldwide under the Stockholm Convention on Persistent Organic Pollutants, an international treaty that sets the official list of POPs and the obligations that come with it. Countries then turn those obligations into national or regional law. In the EU, that law is Regulation (EU) 2019/1021, which applies directly in every Member State and is updated as the Stockholm list expands. 

The regulation protects human health and the environment through control measures that: 

• Prohibit or restrict the production, marketing, and use of POPs 
• Minimize the environmental release of POPs by-products 
• Ensure the safe management of restricted POPs stockpiles 
• Monitor the proper disposal of POPs waste or waste contaminated by POPs 

Regulatory responsibility is shared. The European Commission updates the substance list through delegated regulations. The European Chemicals Agency (ECHA) supports the Commission’s technical work, publishes Member State reports, and coordinates a network of national enforcement authorities. Each Member State designates its own competent authorities to enforce the rules and publishes a report on implementation that it updates as new information becomes available, and at least every three years. 

Who must comply with the EU POPs Regulation

The regulation applies to manufacturers, importers, and sellers of chemicals or articles that contain or release POPs. In practice, that means making sure the substances, mixtures, and articles you place on the EU market stay within the prohibitions and trace contaminant limits set out in the regulation’s annexes, and being able to demonstrate it if a national authority asks. Non-EU suppliers are affected too, because the requirements follow the product onto the EU market. 

EU POPs substance list

The EU POPs substance list sits across four annexes, each with its own measures: 

• Annex I: substances subject to prohibition on manufacturing, placing on the market, and use 
• Annex II: substances subject to restriction on manufacturing, placing on the market, and use 
• Annex III: substances subject to release reduction provisions 
• Annex IV: substances subject to waste management provisions 

Annex I is where new substances are added, including the recent additions covered below. View the full list of substances regulated under EU POPs. 

What are POPs?

Persistent organic pollutants (POPs) are chemicals that resist breakdown in the environment, accumulate in living organisms, and travel by air, water, soil, and migratory animals. 

Because of that long-range transport, POPs have contaminated regions where they were never produced or used. They are now found worldwide in measurable concentrations, which is why they are managed through international agreements rather than country by country. 

People are exposed mainly through food and air, but also through everyday items such as electronics, textiles, and products containing flame retardants, surfactants, or pesticides. Even at low concentrations, exposure can lead to reproductive disorders, immune system alterations, neurobehavioral impairment, and increased cancer risk. 

POPs generally fall into three categories: 

• Pesticides, such as DDT and chlorpyrifos 
• Paints, coatings, and sealants 
• Plastics, including non-food contact materials in food packaging 
• Printing inks and adhesives for food packaging 
• Resins for vehicle parts 

A limit for unintentional trace contaminants (UTC) of ≤ 1 mg/kg (0.0001%) has been established for UV-328 in substances, mixtures, and articles.

Recent additions to the EU POPs list

The EU periodically adds substances to Annex I of the POPs Regulation, usually to align with listings under the Stockholm Convention. Each addition brings its own prohibition, trace contaminant limit, and exemptions. The most recent additions are chlorpyrifos, Dechlorane Plus, and UV-328.  

Chlorpyrifos added to Annex I

Delegated Regulation (EU) 2026/1423, adopted June 30, 2026 and published September 10, 2026, adds chlorpyrifos (CAS 2921-88-2) to Annex I, Part A. It took effect on September 30, 2026. Chlorpyrifos is now subject to the regulation’s prohibition on manufacture, placing on the market, and use. The unintentional trace contaminant limit is 0.01 mg/kg (0.000001% by weight) in substances, mixtures, and articles. No chlorpyrifos-specific exemptions apply, though the regulation’s general exemptions remain in effect. The amendment applies directly in every Member State. 

Dechlorane Plus added to Annex I

Delegated Regulation (EU) 2025/1930, published September 25, 2025, added Dechlorane Plus to Annex I, Part A, effective October 15, 2025. The unintentional trace contaminant limit is 1,000 mg/kg (0.1%) until April 15, 2028, after which it falls to 1 mg/kg (0.0001%). 

Exemptions run on different timelines: 

• Aerospace and defense, medical imaging, and radiotherapy: until February 26, 2030 
• Spare parts for vehicles, machinery, outdoor power equipment, and analytical instruments: until end of service life or December 31, 2043, whichever comes first 
• Medical and in vitro diagnostic devices: until end of service life 

The Commission will review these exemptions by April 1, 2028. Articles already in use may continue to be used. 

UV-328 added to Annex I

UV-328 is a UV absorber used to prevent degradation and discoloration in automotive parts, paints, coatings, plastics, inks, and adhesives. Delegated Regulation (EU) 2025/843, adopted May 5, 2025 and published July 15, 2025, added it to Annex I, effective August 4, 2025. The regulation bans manufacture, placing on the market, and use of UV-328 in the EU, with limited exemptions. Articles already in use before an exemption expires may continue to be used. 

The unintentional trace contaminant limit tightens in phases: 

• 100 mg/kg from August 4, 2025 
• 10 mg/kg from August 4, 2027 
• 1 mg/kg from August 4, 2029 

Tighter PFOS limits

The EU also lowered the unintentional trace contaminant limits for PFOS under Delegated Regulation (EU) 2025/718, a change that matters to teams keeping up with the latest PFAS regulatory developments. 

What these additions mean for compliance teams

Most listings pair a ban with a trace limit that tightens over time, which makes exemption expiry dates the key planning milestones. Teams that know which components and materials contain these substances can plan substitutions early. Teams that don’t will be doing supplier outreach under deadline pressure. 

How to comply with the EU POPs Regulation

Complying with the EU POPs Regulation means making sure the substances, mixtures, and articles you place on the EU market stay within the prohibitions, limits, and exemptions set out in the regulation’s annexes. A practical process looks like this: 

Identify which substances apply to you

Article 3 prohibits the manufacture, sale, and use of Annex I substances, and restricts those in Annex II. This applies whether the substance is on its own, in a mixture, or in an article. Review the annexes against what you make, import, or sell. 

Check the limits and exemptions for each substance

Each Annex I and II entry sets its own unintentional trace contaminant limit (Article 4(1)(b)), and many carry exemptions with expiry dates. Articles already in use before a substance becomes regulated may stay in use (Article 4(2)). Exemptions for laboratory-scale research and reference standards also apply (Article 4(1)(a)). 

Collect supplier data on components and materials

The regulation doesn’t prescribe how to gather this, but the prohibition reaches articles, so you need to know what is in the parts you buy. Ask suppliers to confirm POPs status and request material declarations for in-scope components. 

Map the data to your products 

Match supplier declarations to your bills of materials to find where restricted substances appear and where concentrations come close to a limit. Limits for substances like Dechlorane Plus and UV-328 tighten over time, so concentrations that pass today may not pass later. 

Plan substitutions around exemption timelines 

Reduce or eliminate restricted substances in your products and components, starting with the applications where exemptions expire soonest. 

Handle stockpiles and waste correctly

A stockpile of an Annex I or II substance with no permitted use must be managed as waste under Article 7 (Article 5(1)). Holders of stockpiles over 50 kg of a substance whose use is still permitted must give their competent authority information on its nature and size and update it annually (Article 5(2)). Waste containing Annex IV substances is also regulated by Article 7. 

Stay current with the substance list

The Commission adds substances through delegated regulations, so build a way to track amendments. Because the regulation applies directly across the EU, the core rules are the same everywhere, but each Member State designates its own competent authorities and sets its own penalties for infringements and may apply stricter requirements where appropriate. Know who enforces the rules in the markets where you sell. 

How automation supports EU POPs compliance

These steps depend on data from many suppliers, which is where manual processes break down. Spreadsheet-based outreach produces incomplete responses, makes substances hard to trace to the right components, and leaves little documentation when an authority asks for proof. Source Intelligence’s EU POPs solution automates supplier outreach and data collection, flags POPs in products through bill of materials analysis, and centralizes declarations in one place. It also monitors regulatory updates and generates audit-ready reports, so teams spend less time chasing data and more time acting on it. 

Move from reactive to proactive EU POPs compliance

As the EU adds substances to the POPs list, compliance work that starts only when a customer asks gets harder to sustain. A list update between a request and your response can invalidate the supplier data you already collected, and the same component research gets repeated across products. 

Our Guide to Automating Product Compliance Management shows how to turn that reactive cycle into a proactive program. You’ll learn how to check existing data before contacting suppliers, replace manual follow-up with automated validation and non-responder visibility, and choose the delivery model that fits your team.