Product Compliance Resources provided by ProductIP

2025-07-25

Persistent Organic Pollutants (POP)

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

What are POPs?

POP is the acronym of Persistent Organic Pollutants. It is a group of chemicals that persist in the environment, bioaccumulate through the food web, and pose a severe risk to human health and the environment. Exposure to POPs can lead to cancer, endocrine disruption, reproductive and immune dysfunction, and neurobehavioral and developmental disorders.

POP’s, PBT’s and vPvB’s

There are three groups of persistent substances mentioned in regulations:
* POP, Persistent Organic Pollutants
* PBT, Persistent, Bio-accumulative and Toxic substances
* vPvB, very Persistent and very Bio-accumulative substances

Persistent means that these substances will not (bio)degrade. Because of this, they persist for a (very) long time in the environment, travel across the whole world via water and air and jeopardise human health and environment. They are also known as "forever chemicals".
Bio-accumulation occurs when humans or animals absorb a toxic substance faster than that it can lose it.
A fish swimming in polluted water will contain more and more toxins in its body because it is not able to get rid of the pollutant by itself. The accumulation continues when a predator eats the fish.

Historical background

The risks of POPs are known for many decades; in 1978, the EU prohibited eight pesticides. Many POPs were used as pesticides, for instance, DDT, but they are also involved in industrial processes and used in solvents, plastics, flame retardants and more. They are created intentionally but also as unwanted by-products.

The EU, and also Canada and the USA, are signatories to the United Nations Environmental Programme (UNEP).
UNEP is the global environmental authority that strives for a healthy planet for all of us. Their work includes worldwide bans of hazardous chemicals and waste, including persistent organic pollutants. During several Conventions (e.g. Stockholm, Basel, Rotterdam and Geneva) provisions have been established.

In 2004 the EU published Regulation (EC) 850/2004 based on the UN provisions. It has been amended 12 times since. In 2019, further measures were found necessary. As a result, the EU has recast the first POP regulation. POP Regulation (EU) 2019/1021 entered into force on July 15, 2019.

Relation between REACH and POP regulations

The EU has legislated the Registration, Evaluation and Authorisation of Chemicals in the REACh Regulation (EC) 1907/2006. REACh has a broader scope and more objectives than the POP regulations, but they share one goal: the ban or restriction of dangerous chemical substances. The restrictions in Annex XVII of REACH are very similar to those in Annex I of the POP regulation.

A proposal on a POP, accepted as part of the UNEP conventions and protocols, is added to the POP regulation.
A POP already listed in Annex XVII of REACH will move to the POP regulation.

Second POP Regulation (EU) 2019/1021

The main objective of the POP Regulations is to prohibit (or severely restrict) the production, placing on the market and use of persistent organic pollutants.

The first POP regulation (EC) 850/2004 was published in 2004, two years before the REACh Regulation (EC) 1907/2006 was released and four years before the Waste Directive 2008/98/EC. The definitions and terminology of the second POP Regulation have been aligned with the REACh legislation.

The main changes of POP Regulation (EU) 2019/1021 were:

  • Deca-BDE is added to Annex I. Deca-BDE was already prohibited for use because it was listed as entry #67 in Annex XVII of the REACH Regulation.
  • Pentachlorophenol (PCP) and its salts and esters were added to Annex I. These substances were also already prohibited because they were listed as entry #22 in REACH Annex XVII.
  • Hexachlorobutadiene (HCBD) and polychlorinated naphthalenes (PCN) were already listed in Annex I of the POP Regulation. They were added to Annex III as well.

Amendments

The European Chemical Agency (ECHA) keeps a list of substances proposed as POPs.

Echa also provides a list of substances currently subject to the POP Regulation.

Prohibited chemicals listed in Annex I of the POP Regulation (May 2025)

Name

CAS#

EC#

Use

Tetrabromodiphenyl ether (group) 1)

40088-47-9 a.o

254-787-2 a.o

Flame-retardant, enclosures, circuit boards

Pentabromodiphenyl ether (group) 1)

32534-81-9 a.o

251-084-2 a.o

Flame-retardant, enclosures, circuit boards; industrial

Hexabromodiphenyl ether (group) 1)

36483-60-0 a.o

253-058-6 a.o

Flame-retardant, enclosures, circuit boards

Heptabromodiphenyl ether (group) 1)

68928-80-3 a.o

273-031-2 a.o

Flame-retardant, enclosures, circuit boards; industrial

Bis(pentabromophenyl) ether

1163-19-5

214-604-9

Flame-retardant, enclosures, televisions, textiles, carpets

erfluorooctane sulfonic acid (PFOS), its salts and PFOS-related compounds

Several

Several

Many applications; printed circuit boards, water repellant /stain resistant coatings, textiles, leather, carpet, coatings and paint, adhesives, paper(board) and fire fighting foams

DDT (Clofenotane)

50-29-3

200-024-3

Pesticide

Chlordane

57-74-9

200-349-0

Pesticide, insecticide

Hexachlorocyclohexanes (HCH) including lindane

-

-

Pesticide, insecticide; unintentional by-product

Dieldrin

60-57-1

200-484-5

Agricultural; Pesticide

Endrin

72-20-8

200-775-7

Pesticide

Heptachlor

76-44-8

200-962-3

Pesticide, termiticide, wood treatment, underground cable boxes

Endosulfan

several

204-079-4

Pesticide, insecticide

Hexachlorobenzene (HCB)

118-74-1

204-273-9

Solvent in pesticides, fungicide, fireworks, by-product industrial processes

Chlordecone

143-50-0

205-601-3

Pesticide

Aldrin

309-00-2

206-215-8

Pesticide, insecticide

Pentachlorobenzene

608-93-5

210-172-0

Industrial; fire-retardant; unintentional by-product

Polychlorinated biphenyls (PCB)

1336-36-3 a.o.

215-648-1 a.o.

Industrial; paints, kits, oils, electrical equipment, coolant fluids, insulating fluids, plasticisers

Mirex

2385-85-5

219-196-6

Insecticide, termiticide , flame-retardant

Toxaphene

8001-35-2

232-283-3

Pesticide

Hexabromobiphenyl (HBB) 1)

36355-01-8

252-994-2

Industrial, flame-retardant, electronic equipment

Hexabromocyclododecane (HBCDD)

several

several

Flame-retardant, most commonly used for extended polystyrene (EPS)

Hexachlorobutadiene (HCBD)

87-68-3

201-765-5

Industrial (by-product); solvents, synthetic rubbers

Pentachlorophenol (PCP) and its salts and esters

87-86-5 a.o.

201-778-6 a.o.

Insecticide, herbicide, fungicides, leather and wood preservative. Residues can be found in textiles, leather, wood and paper in products.

Polychlorinated naphthalenes (PCN)

 

70776-03-3 a.o.

274-864-4 a.o.

Many industrial applications; capacitors, additives, cable insulators, preservatives

Alkanes C10-C13, chloro (short-chain chlorinated paraffins) (SCCPs)

85535-84-8

287-476-5

Many applications; lubricants, metalworking, (artificial) leather, flame-retardants, softeners, plasticisers, sealants, coolants, paints, coatings

Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds

335-67-1 a.o.

206-397-9 a.o.

Many applications for heat resistance and  water/oil/dirt repellency; applied in textiles, fabrics, apparel, carpets, sealants, paper, cookware.

Dicofol

115-32-2

204-082-0

Pesticide

Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds

355-46-4 a.o.

206-587-1 a.o.

Firefighting foam; metal plating; textiles, leather and upholstery; electronics and semiconductors; pesticides; flame retardants; paper and packaging; oil industry, and hydraulic fluids.
PFHxS has been used as a replacement for PFOS.

Methoxychlor

72-43-5

200-779-9

Pesticide, insecticide.

‘2-(2H-benzotriazol-2-yl)-4,6-di-tert-pentylphenol

(UV-328)

25973-55-1

247-384-8

Additive in many articles; applications in leather and textiles; automotive indsutry; Ultra-violet (UV) absorber; printing inks and adhesives in food packaging.

 

  1. Poly-brominated biphenyls (PBB) and poly-brominated diphenyl ethers (PBDE) are restricted for electrical and electronic equipment (EEE) via RoHS Directive 2011/65/EU, therefore the POP Regulation does not apply to these EEE products.

 

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