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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