EU POPs Update: Chlorpyrifos Added to Annex I; LC-PFCAs Draft Adopted

On 10 September 2026, the European Union published Commission Delegated Regulation (EU) 2026/1423, adding chlorpyrifos to Part A of Annex I to Regulation (EU) 2019/1021 on persistent organic pollutants. The amendment enters into force on 30 September 2026. Separately, on 7 September 2026, the European Commission adopted draft delegated regulation C(2026) 6059 final to add long-chain perfluorocarboxylic acids (C9–C21 PFCAs), their salts and related compounds to the same Annex.

The LC-PFCAs text is at the Commission-adopted stage and remains subject to the subsequent procedure and publication in the Official Journal. It would enter into force on the twentieth day after publication and would apply from 16 December 2026. The final published text should be consulted for the definitive requirements.

1. Chlorpyrifos

For chlorpyrifos (CAS No. 2921-88-2; EC No. 220-864-4), the unintentional trace contaminant (UTC) limit is ≤0.01 mg/kg in substances, mixtures or articles. Article 4(1)(b) of the POPs Regulation applies at or below this concentration. No specific-use exemption is included in the new entry.

2. Scope and general UTC limits for LC-PFCAs

The draft covers linear and branched PFCAs with the formula CₙF₂ₙ₊₁COOH, where 8≤n≤20, their salts, and related compounds that can degrade or be transformed into C9–C21 PFCAs. Certain compounds meeting the structures specified in the entry, and PFOA-related compounds already covered by the PFOA entry, are excluded.

The proposed general UTC limits in substances, mixtures or articles are ≤0.025 mg/kg for the sum of C9–C21 PFCAs and their salts, and ≤0.26 mg/kg for the sum of C9–C21 PFCA-related compounds.

3. Proposed specific limits exemptions and continued-use arrangements

Transported isolated intermediates

A limit of ≤10 mg/kg for the sum of C9–C21 PFCAs, their salts and related compounds would apply only to substances intended for use as transported isolated intermediates as defined in Article 3(15)(c) of REACH, meeting the strictly controlled conditions in Article 18(4), first subparagraph, points (a) to (f), and used to manufacture fluorochemicals with a perfluorinated carbon chain of no more than six atoms.

Fluoroplastics and fluoroelastomers containing perfluoroalkoxy groups

Until 16 December 2030, the limits would be ≤0.1 mg/kg for the sum of C9–C14 PFCAs and ≤15 mg/kg for the sum of C15–C21 PFCAs. From 17 December 2030, the limit would be ≤0.1 mg/kg for the sum of C9–C21 PFCAs. Emissions of unintentionally formed C9–C21 PFCAs during manufacture and use must be avoided or, where this is not possible, reduced as far as technically and practically feasible.

PTFE micropowders and industrial or professional-use mixtures and articles containing them

For PTFE micropowders produced by ionising irradiation or thermal degradation, the limits until 16 December 2030 would be ≤1 mg/kg for the sum of C9–C14 PFCAs and their salts, and ≤15 mg/kg for the sum of C15–C21 PFCAs and their salts. From 17 December 2030, the limit would be ≤1 mg/kg for the sum of C9–C21 PFCAs and their salts. Emissions of unintentionally formed C9–C21 PFCAs during manufacture and use must be avoided or, where this is not possible, reduced as far as technically and practically feasible.

Firefighting foams already installed in systems

For foams already installed in systems for liquid fuel vapour suppression and liquid fuel fires (Class B fires), limits of ≤1 mg/kg for the sum of C9–C21 PFCAs and their salts and ≤10 mg/kg for related compounds, individually or in combination, would apply until 3 August 2028.

Fluorine-free firefighting foams contaminated by residues in cleaned equipment

A limit of ≤10 mg/kg for the sum of C9–C21 PFCAs, their salts and related compounds would apply only where the contamination originates from firefighting equipment cleaned using best available techniques. No end date is specified for this arrangement in the draft.

C9–C14 PFCAs in semiconductors for electronic equipment spare parts and repair

Placing on the market and use of C9–C14 PFCAs, their salts and related compounds in semiconductors for spare parts and repair of electronic equipment placed on the market before 31 December 2023 would be allowed until 30 December 2030.

C15–C21 PFCAs in semiconductors for spare parts

Placing on the market and use of C15–C21 PFCAs, their salts and related compounds in semiconductors for spare parts would be allowed until 16 December 2031, provided that these substances were originally used in the semiconductors which the spare parts are intended to replace or repair.

Articles already in use in the Union

Articles containing C9–C14 PFCAs, their salts and related compounds already in use in the Union before 31 December 2023 could continue to be used. The corresponding date for articles containing C15–C21 PFCAs, their salts and related compounds would be 17 December 2026. No end date is specified for either continued-use arrangement in the draft.

Implications for exporters

Exporters to the EU should review the use of these substances in product materials and supply chains, prepare for the chlorpyrifos amendment, and monitor the final LC-PFCAs text. For LC-PFCAs, applicable limits and exemptions depend on the intended use and, in some cases, the date of placing on the market or first use. Testing scope, methods and detection capability should be confirmed before testing is arranged.

CTT testing capability

CTT currently has no testing capability for LC-PFCAs or chlorpyrifos.