UK Proposes Amendments to POPs Regulation

On 18 March 2026, the UK Department for Environment, Food & Rural Affairs (Defra) launched an eight-week public consultation on proposed amendments to the UK Persistent Organic Pollutants (POPs) Regulation. Under the proposal, five additional chemical substances would be subject to a full prohibition, and the limit values for perfluorooctane sulfonic acid (PFOS) would be further tightened. The public consultation will close on 13 May 2026. According to the consultation documents and draft legislation currently published, the proposed amendments are intended to take effect on 16 December 2026 and will apply in Great Britain, namely England, Wales and Scotland.

Main Proposed Amendments

The proposed revision to the UK POPs Regulation is mainly focused on two aspects. First, five new chemical substances are proposed to be added to Annex I, which would prohibit their manufacture, use and placing on the market. Second, the control requirements for the existing listed substance PFOS are proposed to be revised.

1. Addition of Five New Chemical Substances to Annex I (Prohibition on Manufacture, Use and Placing on the Market)

The draft amendment proposes to incorporate into UK domestic legislation five POPs that have recently been added under the Stockholm Convention, and to set specific concentration limits for unintentional trace contaminants (UTCs) as well as time-limited exemptions for specific uses. The substances and the proposed requirements are as follows:

Medium-chain chlorinated paraffins (MCCPs)

The proposed UTC limits are ≤3% by weight in substances or mixtures and ≤0.45% by weight in articles. Time-limited specific-use exemptions are proposed for certain applications, including in the construction, aerospace and medical device sectors, until 2031 or later, depending on the application.

Long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds

The proposed UTC limits are ≤0.025 mg/kg for the sum of LC-PFCAs and their salts and ≤1 mg/kg for the sum of related compounds. The proposed exemptions mainly cover specific uses such as semiconductor replacement parts for internal combustion engine-driven vessels or motor vehicles no longer in production.

Dechlorane Plus

The proposed UTC limit is ≤10 mg/kg in substances, mixtures or articles. Specific exemptions with time limits are proposed mainly for replacement parts and repairs in sectors such as aerospace, space, defence and medical imaging equipment.

UV-328

The proposed UTC limit is ≤10 mg/kg in substances, mixtures or articles. Time-limited exemptions are proposed for certain uses, including applications in motor vehicles, industrial coatings and liquid crystal displays.

Chlorpyrifos

The proposed UTC limit is ≤0.01 mg/kg in substances, mixtures or articles. No specific exemption is proposed for this substance.

2. Revision of Restriction Requirements for PFOS, an Already Controlled Substance

The draft amendment also updates the existing entry for PFOS. The proposed changes mainly include the following two aspects.

First, the UTC limits would be further tightened. The proposed limit for PFOS and its salts would be reduced from 10 mg/kg to 0.025 mg/kg (0.0000025% by weight), while the proposed limit for PFOS-related compounds would be set at 1 mg/kg (0.0001% by weight).

Second, certain previous wording in the existing entry would be removed, including the deletion of earlier references to European Committee for Standardization (CEN) standards as analytical test methods.

CTT Reminder

In view of these key proposed amendments to the UK POPs Regulation, companies exporting products to the UK are advised to closely monitor regulatory developments, in particular the proposed inclusion of five new chemical substances in the full prohibition list and the proposed revision of PFOS limits. Businesses should review the use of relevant controlled substances across their supply chains as early as possible and, in light of product applications, fully assess the potential impact of the time-limited exemptions for specific uses on their operations, so as to ensure continued compliance with the regulatory requirements of the UK market.

Based on global regulatory frameworks and chemical control requirements, CTT can provide services including regulatory consulting, product testing, supply chain risk screening and compliance training, helping companies better respond to technical trade barriers. For more information or any testing needs, please feel free to contact us.