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EU POPs regulation plans to add three substances: MCCPs, chlorpyrifos, and LC-PFCAs

Time：

2025-11-26

The European Commission plans to include three major categories of persistent organic pollutants, namely chlorpyrifos, medium chain chlorinated paraffins (MCCP), and long-chain perfluorocarboxylic acids (C9-21 PFCAs), in Annex I, Part A of the EU POPs Regulation (EU) 2019/1021, with a complete ban on their production, circulation, and use within the EU, and only a few industries granted transitional exemptions. The current draft has entered public consultation, and the deadline for feedback is December 19, 2025.

On November 21, 2025, the European Commission released three drafts, planning to include three major categories of persistent organic pollutants (POPs) - chlorpyrifos, medium chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids (C9-21 PFCAs) - in Part A of Annex I of the EU POPs Regulation (EU) 2019/1021, completely prohibiting their production, circulation, and use within the EU, and only granting transitional exemptions to a very small number of industries.

01. Chlorpyrifos

CAS number: 2921-88-2
EC number: 220-864-4

Specific exemptions for intermediate use or other specifications

For the purpose of this provision, Article 4, Paragraph 1 (b) shall apply to cases where the concentration of chlorpyrifos present in a substance, mixture, or article is equal to or less than 0.01 mg/kg (0.000001% by weight).

02. Medium chain chlorinated paraffins (MCCPs)

Definition: Medium chain chlorinated paraffins or "MCCPs" refer to substances or mixtures containing any of the following linear C14-17 chlorinated alkanes, with the following molecular formula:

C14H(30−y)Cly where y ≥ 5;

C15H(32−y)Cly where y ≥ 5;

C16H(34−y)Cly where y ≥ 6;

C17H(36−y)Cly where y ≥ 6.

CAS number: 85535-85-9198840-65-21372804-76-6, etc
EC number: 287-477-0 and others

Specific exemptions for intermediate use or other specifications

For the purposes of this provision, Article 4 (1) (b) shall apply to the sum of the concentrations of linear C14-17 chlorinated alkanes represented by the following molecular formulas:

C14H(30−y)Cly where y ≥ 5;

C15H(32−y)Cly where y ≥ 5;

C16H(34−y)Cly where y ≥ 6;

C17H(36−y)Cly where y ≥ 6.

When present in a substance, mixture, or item, its content should be equal to or less than 1000mg/kg (0.1% by weight).

2. As an exception, it is allowed to manufacture, place on the market, and use MCCPs for the following purposes:

a) Extreme pressure additives in metalworking fluids used in professional or industrial environments for "heavy" metalworking operations and equipped with collection systems, with a lifespan extended to December 31, 2036

b) Polymers and rubber used for spare parts and maintenance of any of the following items:

i) Land based motor vehicles;

Ii) Mechanical equipment used for agriculture, construction, forestry, or landscape beautification;

Iii) Electrical and electronic equipment applicable to medical devices, whose scope of application covers EU Regulation EU 2017/745;

Iv) Electrical and electronic equipment applicable to in vitro diagnostic devices, whose scope of application covers EU Regulation EU 2017/746;

v) Measurement, analysis, manufacturing, control, monitoring, testing, and inspection instruments

VI) Aerospace and Defense Applications;

The equipment that initially uses MCCP in the production process until its service life ends or 2041.12.31, whichever is earlier;

c) Flexible polyvinyl chloride in wires and cables used in medical devices within the scope of EU 2017/745 and in vitro diagnostic devices within the scope of EU 2017/746, until... [insert date: five years after the effective date of the amendment to Annex A];

d) Adhesives, sealants, and tapes used for non structural bonding in the aerospace and defense fields, until... [OP: Please insert date: five years after the effective date of the amendment to Annex A];

e) The paint and coating used for ammunition and ammunition marking, until... [insert date: five years after the effective date of the amendment to Annex A];

f) Ammunition, fireworks, and defense devices to achieve specific effects until November 31, 2041.12.31;

g) Expansion type coatings and paints used for aerospace and defense equipment and their packaging to withstand extreme temperatures, with an expiration date of 2041.12.31;

h) Coatings and paints used for repairing space and defense equipment, as well as for spare parts of the equipment, provided that MCCPs are initially used in the production process until the equipment reaches the end of its service life.

When manufacturing and using MCCPs within the exemption scope listed in point 2 for industrial and professional purposes, MCCPs should be avoided from being released into the environment; If it cannot be avoided, it should be reduced to the lowest level. Workers' exposure should be minimized to the greatest extent possible.

4. Articles containing MCCPs that have been used within the Union on or before the expiration of the exemptions specified in paragraphs 2 (b) to (g) may continue to be used.

5. Allow spare parts containing MCCPs as described in paragraph 2 (b) and (h) that existed within the European Union before January 1, 2042.01 to enter the market and be used.

Manufacturers, suppliers, and importers of chlorinated paraffins who place substances or mixtures containing chlorinated alkanes as described in point 1 on the market shall provide downstream users and customers with the following information in the safety data sheet referred to in Article 31 of EC 1907/2006:

i) The total concentration of chlorinated alkanes listed in paragraph 1 (if any);

When the total amount mentioned in point (i) exceeds 0.1% (weight percentage), appropriate risk management measures and operating conditions should be taken to minimize release and exposure.

7. Manufacturers, suppliers, and importers of chlorinated paraffins shall use representative batches of chlorinated paraffins produced by the same manufacturer according to the same technical specifications to determine the total sum as described in point 6 (i). This level should be determined using validated analytical methods. At the request of the competent authority, a description of the analytical method used and the determination results used to obtain the sum mentioned in point 6 (i) must be provided.

03. Long chain perfluorocarboxylic acids, their salts, and related compounds (C9-21 PFCAs)

Definition: Long chain perfluorocarboxylic acids (C9-21PFCAs), their salts, and related compounds "refer to the following substances: straight chain and branched perfluorocarboxylic acids that comply with the CnF2n+1COOH formula, where 8 ≤ n ≤ 20 (C9-21 perfluorocarboxylic acids); Its salts; Compounds related to C9-21 perfluoroalkyl compounds, including any substance that may degrade or transform into C9-21 perfluoroalkyl compounds, including any substance containing the perfluoroalkyl group CnF2n+1 (where 8 ≤ n ≤ 20) as one of the structural elements. The following compounds are not related to C9-21 perfluoroalkyl compounds: CnF2n+1X, where X=F, Cl, or Br.
CAS numbers: 375-95-1, 335-76-2, 2058-94-8, 307-55-1, 2629-94-8, 376-06-7, 41074-63-7, 67905-19-5, 57475-95-3, 16517-11-6, 133921-38-7, 68310-12-3 and others
EC numbers: 206-801-3, 206-400-3, 218-165-4, 206-203-2, 276-745-2, 206-803-4, 267-638-1, 240-582-5, 269-701-9 and other

Specific exemptions for intermediate use or other specifications

For the purpose of this article, Article 4, paragraph 1 (b) shall apply to situations where the total concentration of C9-21 perfluoroalkyl compounds and their salts present in a substance, mixture or article is equal to or less than 0.025mg/kg (0.0000025% by weight).

2. For the purposes of this article, Article 4, paragraph 1 (b) shall apply to substances, mixtures, or articles where the total concentration of C9-21 perfluoroalkyl compound related compounds is equal to or less than 0.26mg/kg (0.000026% by weight).

3. As an exception to paragraphs 1 and 2, for the purposes of this Article, paragraph 1 (b) of Article 4 shall apply to the total concentration of C9-21 perfluoroalkyl compounds, their salts, and related compounds, when present in a substance used as a transport isolation intermediate (as defined in paragraph 15 (c) of Article 3) and at a concentration equal to or less than 10mg/kg (0.001% by weight), while meeting the strict control conditions specified in Article 18, paragraph 4, item 1 (a) to (f) of the Regulation for the production of fluorinated chemicals with a perfluorocarbon chain equal to or shorter than 6 atoms, as defined in paragraph 15 (c) of Article 3, and meeting the transport isolation intermediate requirements of EC 1907/2006,

4. For the purposes of this article, Article 4, paragraph 1 (b) shall apply to substances, mixtures, or articles where the total concentration of C9-21 perfluoroalkyl compound related compounds is equal to or less than 0.26mg/kg (0.000026% by weight).

During the production and use of fluoroplastics and fluororubbers containing perfluoroalkoxy groups, any unintentional emission of C9-21 perfluoroalkoxy compounds should be avoided; If unavoidable, emissions should be minimized as much as possible within the scope of technology and practical feasibility.

5. As an exception to paragraph 1, Article 4, paragraph 1 (b) shall apply to the total concentration of C9-21 perfluoroalkyl compounds and their salts when the total concentration is equal to or less than 1mg/kg (0.0001% by weight), provided that these substances are present in polytetrafluoroethylene micro powders and the purpose of transportation or processing of the micro powders is to reduce the total concentration of C9-21 perfluoroalkyl compounds and their salts to a limit below 0.025mg/kg (0.0000025% by weight).

6. Allow the use of C9-21 perfluoroalkyl compounds, their salts, and related compounds in semiconductors for the following purposes until 2030.12.30 for spare parts and maintenance of the following equipment:

a) Electronic equipment for internal combustion engine powered ships that will be put on the market before December 31, 2023;

b) Electronic devices launched on the market before December 31, 2023 are applicable to land-based motor vehicles that have ceased mass production.

7. Articles containing C9-C21 perfluoroalkyl compounds (PFCA), their salts, and related compounds, if used within the European Union before December 31, 2023, may continue to be used.

04. Compliance Suggestions

At present, the draft has entered the public consultation period, and relevant stakeholders can submit feedback on the revised draft through the official website of the European Commission. The deadline for feedback is December 19, 2025. The three newly proposed substances are expected to be officially approved and implemented in 2026, and will become new compliance thresholds that must be focused on for exporting EU products.

In recent years, the EU's POPs regulations have been updated frequently and enforcement efforts have been continuously strengthened. There have also been more and more cases of Chinese products being reported for violating POPs regulations when exporting to the EU. Enterprises should pay timely attention to regulatory developments, respond to adjustment strategies, ensure that products comply with new regulatory requirements, and reduce the risk of violations.

As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CPSC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed according to standards, equipped with advanced instruments and equipment, and has a skilled professional technical team with rich industry service experience and strong testing technology capabilities. It is proficient in various regulatory standards and specializes in providing customized testing services for POPs substances and global environmental protection regulatory testing consulting services for electronic and electrical products, food contact materials, toys, and children's products. We provide you with a comprehensive and perfect one-stop testing and certification solution. Welcome to contact us at 400-9269-886!