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If you’re a compliance manager juggling multiple EU regulations, you’ve probably asked this before:
“Aren’t POPs already covered under REACH?” “Do I need to track the same substances twice?”
The short answer? No—and yes.
Let’s break down the critical differences between the EU POPs Regulation (EU) 2019/1021 and the REACH Regulation (EC) No 1907/2006—and why ignoring the nuance could expose your business to regulatory risk.
What Is the EU POPs Regulation?
The Persistent Organic Pollutants (POPs) Regulation is laser-focused on one thing: long-lived, bioaccumulative, and toxic chemicals that travel globally and build up in ecosystems and humans.
It enforces the EU’s commitment to the Stockholm Convention—a global treaty on banning/restricting POPs.
Key obligations under EU POPs:
- Prohibit manufacture, use, and placing on the market of listed POPs (Annex I)
- Mandate waste destruction above thresholds Annex IV.
- Align with international bans and controls
POPs are regulated whether they are:
- Intentionally used (e.g., flame retardants in electronics)
- Unintentionally generated (e.g., industrial by-products like dioxins)
What Is REACH?
The REACH Regulation is the EU’s all-encompassing chemical safety framework. It stands for:
Registration, Evaluation, Authorisation, and Restriction of Chemicals
REACH is about risk management at scale—covering all chemicals, not just POPs. That includes:
- Industrial chemicals
- Additives
- Intermediates
- Substances in articles
It enforces:
- Substance registration for >1 tonne/year SVHC tracking and Candidate List obligations
- Annex XIV (Authorisation) and Annex XVII (Restriction)
POPs vs. REACH – Key Differences at a Glance
Why This Matters for Manufacturers
If you manufacture, import, or sell products in the EU—especially electronics, textiles, or machinery—you may be subject to both regulations for the same chemical.
Example 1: DecaBDE (a flame retardant)
- Listed in POPs Annex I (banned above 10 mg/kg)
- Also restricted under REACH Annex XVII → Must comply with both product and waste rules.
Example 2: PFHxS
- Added to POPs Annex I (2023)
- Likely to trigger scrutiny under REACH SVHC Candidate List in the future → Dual tracking required.
Do POPs and REACH Overlap?
Yes, but the difference lies in purpose and consequence.
- POPs is about elimination → You cannot use or place on market above UTC thresholds.
- REACH is about risk management → You might be allowed to use the chemical but must justify and communicate risk.
Think of POPs as “absolute bans” and REACH as “regulated use with obligations.”
Keeping Track of Amendments
The EU updates POPs and REACH independently. Here’s how:
- POPs: Based on decisions from the Stockholm Convention (UN-level), often followed by ECHA’s proposal and Commission amendments.
- REACH: SVHCs can be added anytime through Annex XV dossiers submitted by Member States or ECHA.
Recent POPs Additions (2023–2025):
- PFHxS and related compounds
- Methoxychlor
- UV-328
- Dechlorane Plus
Recent REACH SVHC Updates (June 2025):
- 1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane
- Textile dyes and cosmetics ingredients flagged as vPvB
Compliance Best Practices
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Screen for both REACH and POPs lists → Use tools that support dual compliance.
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Track updates regularly → Candidate List (SVHC) for REACH, Annex I for POPs.
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Engage suppliers → Get material declarations that cover both regulatory scopes.
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Verify waste streams → Ensure Annex IV POPs thresholds are not exceeded for reuse or landfill.
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Redesign products if needed → Some POPs allow no substitutes—plan ahead.
Acquis Helps You Manage REACH + POPs in One Platform
At Acquis, we simplify multi-regulation compliance with: