Introduction
On 7 September 2026, the European Commission adopted a delegated regulation adding long-chain perfluorocarboxylic acids (C9–C21 PFCAs), their salts, and related compounds to Annex I of the EU POPs Regulation (EU) 2019/1021.
The new requirements are expected to apply from 16 December 2026. Of the three substances under parallel review, chlorpyrifos and long-chain PFCAs have both been approved. Only MCCPs remain under consideration.
Companies placing products on the EU market should evaluate the potential impact on their products and supply chains.
Why It Matters？
Long-chain PFCAs are a subgroup of PFAS (per- and polyfluoroalkyl substances) known for their persistence, bioaccumulation potential, and adverse effects on human health and the environment. While C9–C14 PFCAs are already restricted under Entry 68 of Annex XVII to the EU REACH Regulation, the new POPs listing extends control to C15–C21 PFCAs.
Chlorpyrifos is an organophosphate insecticide that is no longer approved for use in the EU. Following its listing under the Stockholm Convention, it has now been added to Annex I of the EU POPs Regulation, resulting in a near-complete prohibition with a strict unintentional trace contaminant limit.
Key Compliance Requirements
The new POPs requirements apply to substances, mixtures, and articles.
|
Controlled Substance
|
Limit
|
|---|---|
|
C9–C21 PFCAs and their salts
|
≤ 0.025 mg/kg Sum
|
|
C9–C21 PFCA-related compounds
|
≤ 0.26 mg/kg Sum
|
|
Chlorpyrifos
|
≤ 0.01 mg/kg
|
Key Exemptions
The POPs restriction for long-chain PFCAs includes certain time-limited or sector-specific exemptions, including:
- Fluoropolymers and fluoroelastomers (transitional exemptions until 2030)
- PTFE micropowders for industrial and professional use (transitional exemptions until 2030)
- Certain fire-fighting foam applications
- Specific semiconductor spare-part applications
- Articles already in use before the applicable dates
No specific exemptions have been provided for chlorpyrifos.
What Should Companies Do?
To prepare for the upcoming requirements, companies should:
- Screen products and materials for long-chain PFCAs, other PFAS of concern, and chlorpyrifos.
- Engage suppliers to obtain material declarations and substance information.
- Conduct testing and verification where necessary to support compliance.
- Monitor regulatory developments, including the proposed EU REACH PFAS restriction and future updates to the EU POPs Regulation.
How PFI Can Help？
The EU POPs Regulation continues to expand its scope, while PFAS-related regulatory requirements are becoming increasingly stringent worldwide. Early assessment can help companies identify compliance risks, avoid supply chain disruptions, and maintain access to key markets.
PFI provides comprehensive compliance support for PFAS, POPs, and REACH requirements, including substance screening, laboratory testing, supply chain surveys, and regulatory compliance assessments. Our experts can help you evaluate regulatory obligations and develop practical compliance strategies tailored to your products and supply chain.
Contact us to discuss your compliance needs.
