Executive Summary At a Glance

The European Commission has published Regulation (EU) 2026/1423, adding chlorpyrifos to Part A of Annex I of the EU POPs Regulation (limit: 0.01 mg/kg), and has adopted a draft amendment listing LC-PFCAs (C9–C21), their salts and related compounds (limits: 0.025 mg/kg and 0.26 mg/kg respectively), which will apply from 16 December 2026. Companies exporting to the EU should monitor these developments and prepare for compliance in advance.

The European Commission has recently issued a series of amendments to Annex I of Regulation (EU) 2019/1021 on persistent organic pollutants (the “EU POPs Regulation”), further tightening the control and management of POPs. Companies exporting to the EU should closely monitor these regulatory developments and make compliance preparations in advance.

Chlorpyrifos: Amendment Regulation Officially Published

On 10 September 2026, the European Commission officially published Regulation (EU) 2026/1423, adding chlorpyrifos to Part A of Annex I of the EU POPs Regulation. The Regulation enters into force on the twentieth day following its publication.

Control requirement: For chlorpyrifos present in substances, mixtures or articles, the concentration shall not exceed 0.01 mg/kg.

LC-PFCAs (C9–C21): Amendment Draft Adopted

On 7 September 2026, the European Commission adopted a draft amendment to list LC-PFCAs (C9–C21 perfluorocarboxylic acids, their salts and related compounds) in Part A of Annex I of the EU POPs Regulation. As the next step, the European Union will formally publish the amendment regulation, which will apply from 16 December 2026.

The main contents of the draft amendment are as follows:

• For the purposes of this entry, Article 4(1)(b) shall apply where the sum of concentrations of C9–C21 PFCAs and their salts present in a substance, mixture or article is ≤ 0.025 mg/kg.
• For the purposes of this entry, Article 4(1)(b) shall apply where the sum of concentrations of C9–C21 PFCA-related compounds present in a substance, mixture or article is ≤ 0.26 mg/kg.
• By way of derogation from points 1 and 2, for the purposes of this entry, Article 4(1)(b) shall apply where the sum of concentrations of C9–C21 PFCAs, their salts and related compounds is ≤ 10 mg/kg in substances intended to be used as transport-isolated intermediates within the meaning of point (c) of Article 3(15) of Regulation (EC) No 1907/2006, that comply with the strictly controlled conditions set out in points (a) to (f) of the first subparagraph of Article 18(4) of that Regulation, and that are used for the manufacture of fluorinated compounds with a perfluorinated carbon chain length of six atoms or fewer.
• By way of derogation from point 1, for the purposes of this entry, Article 4(1)(b) shall apply to the use of fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups where:
  • the sum of concentrations of C9–C14 PFCAs is ≤ 0.1 mg/kg (applicable until 16 December 2030);
  • the sum of concentrations of C15–C21 PFCAs is ≤ 15 mg/kg (applicable until 16 December 2030);
  • the sum of concentrations of C9–C21 PFCAs is ≤ 0.1 mg/kg (applicable from 17 December 2030).
• All releases of unintentionally formed C9–C21 PFCAs during the production and use of fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups shall be avoided, and where they cannot be avoided, shall be minimised as far as technically and practically practicable.
• By way of derogation from point 1, for the purposes of this entry, Article 4(1)(b) shall apply to the use of polytetrafluoroethylene (PTFE) micropowders produced by ionising irradiation or thermal degradation, and of industrial and professional mixtures and articles containing PTFE micropowders, where:
  • the sum of concentrations of C9–C14 PFCAs and their salts is ≤ 1 mg/kg (applicable until 16 December 2030);
  • the sum of concentrations of C15–C21 PFCAs is ≤ 15 mg/kg (applicable until 16 December 2030);
  • the sum of concentrations of C9–C21 PFCAs and their salts is ≤ 1 mg/kg (applicable from 17 December 2030).
• All releases of unintentionally formed C9–C21 PFCAs during the production and use of PTFE micropowders shall be avoided, and where they cannot be avoided, shall be minimised as far as technically and practically practicable.
• By way of derogation from points 1 and 2, for the purposes of this entry, Article 4(1)(b) shall apply to the use of fire-fighting foams already installed in systems for the suppression of vapour of flammable liquids and the extinguishing of liquid fuel fires (Class B fires) where:
  • the sum of concentrations of C9–C21 PFCAs or any of their salts is ≤ 1 mg/kg (applicable until 3 August 2028);
  • the concentration of C9–C21 PFCA-related compounds, individually or in combination, is ≤ 10 mg/kg (applicable until 3 August 2028).
• By way of derogation from points 1 and 2, for the purposes of this entry, Article 4(1)(b) shall apply where the sum of concentrations of C9–C21 PFCAs, their salts and related compounds originating from fire-fighting equipment that has been cleaned in accordance with best available techniques is ≤ 10 mg/kg in fluorine-free fire-fighting foams.
• Until 30 December 2030, the placing on the market and use of C9–C14 PFCAs, their salts and related compounds in semiconductors used for spare parts and the repair of electronic devices placed on the market before 31 December 2023 shall be permitted.
• Until 16 December 2031, the placing on the market of C15–C21 PFCAs, their salts and related compounds in semiconductors used for spare parts shall be permitted, provided that C15–C21 PFCAs, their salts and related compounds were originally used in the semiconductor that is to be replaced or repaired by the spare part.
• Articles containing C9–C14 PFCAs, their salts and related compounds that were already in use in the EU before 31 December 2023 may continue to be used.
• Articles containing C15–C21 PFCAs, their salts and related compounds that were already in use in the EU before 17 December 2026 may continue to be used.

CIRS Testing Highlights

Why this matters

LC-PFCAs belong to the PFAS family and are mainly used as plasticisers, flame retardants and lubricants. The EU POPs Regulation has already brought PFOA, PFOS and PFHxS (their salts and related compounds) under control. The addition of LC-PFCAs marks yet another step by the EU to tighten PFAS restrictions. Companies should continue to follow global regulatory developments on PFAS and carry out risk screening in a timely manner.

Background: The EU POPs Regulation

The EU POPs Regulation is a mandatory regulation of the European Union. The substances it controls are derived from the Stockholm Convention on Persistent Organic Pollutants, to which nearly 200 countries and regions worldwide — including China — are parties.

How CIRS Testing Can Help

CIRS Testing provides one-stop compliance solutions for the EU POPs Regulation. For substances controlled under the Stockholm Convention and under similar POPs regulations worldwide, CIRS Testing offers testing, consulting and training services to help you ensure that your products meet the latest control requirements and avoid trade risks.

Similar POPs-style regulations worldwide include:

About CIRS Testing

CIRS Testing is a professional third-party testing organisation providing one-stop compliance solutions for chemical and product regulations worldwide. With an extensive service network, experienced technical teams and localised laboratories, CIRS Testing delivers a comprehensive range of services covering green compliance and chemical risk management, testing and certification, consulting and training.

Our service portfolio covers major regulatory frameworks including RoHS, REACH, POPs, PFAS and food contact materials (FCM), helping companies meet the latest regulatory requirements and mitigate trade risks on the road to sustainable development.

Note: This article is for informational purposes only and does not constitute legal advice. Regulatory texts cited: Regulation (EU) 2026/1423; Commission draft amendment on LC-PFCAs (C9–C21) to Regulation (EU) 2019/1021.