Table of Contents
The European Union continues to tighten controls under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs). In May 2025, the European Commission adopted Delegated Regulation (EU) 2025/802, adding Dechlorane Plus and UV-328 to Annex I (Part A) of the POPs Regulation. These two high-concern chemicals are now subject to strict concentration limits and near-total phase-outs, following global alignment with the Stockholm Convention.
New 2025 Additions
Dechlorane Plus and UV-328 Now Restricted (Effective August 4 2025) On 5 May 2025, the Commission published Delegated Regulation (EU) 2025/802, entering into force on 4 August 2025.
Dechlorane Plus (CAS 13560-89-9)
- Listed in Annex I Part A with a concentration limit of 1 000 mg/kg (0.1 %).
- This limit drops to 1 mg/kg after 30 months.
- Exemptions apply for use in aircraft and automotive spare parts produced before 2025.
UV-328 (CAS 25973-55-1)
- Production and use prohibited except for closed-system intermediates and recycling under controlled conditions.
- Commonly used in plastics and coatings as a UV stabiliser — now flagged for elimination under the Stockholm Convention.
Why It Matters
- Both chemicals are persistent and bioaccumulative, posing long-range environmental risks.
- Manufacturers must screen mixtures and articles for residual content and update supplier declarations accordingly.
Earlier POPs Amendments (2023 – 2024 Recap)
On August 8, 2023, the EU published Regulation (EU) 2023/1608, amending Annex I Part A of the POPs Regulation to include:
- Perfluorohexane sulfonic acid (PFHxS)
- PFHxS salts
- PFHxS-related compounds (including degradable substances that contain the structural element C6F13S-)
Key Implications:
- PFHxS and related compounds are widely used in textiles, firefighting foams, and coatings.
- The amendment allows exemptions for intermediate use or essential applications under strict control.
- PFHxS is known for its high persistence and bioaccumulation potential, prompting its global restriction under the Stockholm Convention.
Methoxychlor & HBCDD Thresholds Updated (Effective October 17, 2024)
In a follow-up amendment published on September 27, 2024, the European Commission introduced two new controls:
- 1 Methoxychlor
- Now listed under Annex I (Part A)
- Threshold: 0.01 mg/kg in any material
- Previously used in agriculture as a pesticide, its toxicity and environmental persistence led to global restriction proposals
- 2 HBCDD (Hexabromocyclododecane)
- Lowered UTC threshold from 100 mg/kg to 75 mg/kg for most products
- Exception: Recycled EPS/XPS polystyrene insulation materials (remains 100 mg/kg)
- Aimed at supporting circular economy goals while minimizing emissions
Industry Sectors Impacted by EU POPs Regulation Update
- Electronics: Flame retardants, insulation materials, printed circuit boards
- Construction: Polystyrene insulation, recycled materials
- Agriculture: Pesticide manufacturers and suppliers
- Plastics & Polymers: UV stabilisers and additives in consumer goods
- Aerospace & Automotive: Legacy applications of Dechlorane Plus in electrical components
Why These Amendments Matter
These 2025 amendments close the loop on several long-standing POP candidates, extending the EU’s ban to flame retardants and UV stabilisers that previously escaped restriction.
- Health Protection: Reduces human and wildlife exposure to known carcinogens, endocrine disruptors, and bioaccumulative toxins
- Circularity with Control: Recycled HBCDD usage shows EU’s support for circular economy within defined safety limits
- International Alignment: Matches EU standards with Stockholm Convention obligations
Compliance Deadlines Recap
- PFHxS: Already in effect since August 28, 2023
- Methoxychlor & HBCDD: Enforceable from October 17, 2024
Businesses must screen their BOMs, engage suppliers, and update documentation to stay compliant.
2025 Additions:
- Dechlorane Plus and UV-328 – Effective 4 August 2025
- 30-month transition for specific uses and waste thresholds (through early 2028)
- UK alignment via The Persistent Organic Pollutants (Amendment) Regulations 2025 effective 15 April 2025
Action Steps for 2025 Compliance
- Screen BOMs and supplier data for Dechlorane Plus and UV-328.
- Update declarations and Safety Data Sheets to reflect Annex I changes.
- Validate recycled material streams against POP limits before reuse.
- Implement waste segregation and treatment processes for POP-containing articles.
- Monitor UK and Stockholm Convention alignment for global exports.
How Acquis Helps You Stay Compliant
Navigating these regulatory shifts can be complex. That’s where Acquis comes in:
- Supply Chain Data Collection & Material Declaration Management
- Regulatory Threshold Analysis for POPs, PFAS, REACH, and more
- On-demand reporting to support audits and inspections
- Compliance automation tools tailored to electronics and manufacturing industries
Ready to future-proof your POPs compliance? Contact us for a free risk assessment.