What is the EU POPs Regulation and do I need to be concerned about it as a product developer?

Many consumer products have been recalled in Europe in recent months do to non-compliance with the EU POPs Regulation. Many of these for containing SCCPs.

(EU) 2019/1021
What are POPs?
POPs (Persistent organic pollutants), are substances that persist in the environment and accumulate in living organisms, posing a risk to our health.

How are they regulated?
POPs are regulated globally by the Stockholm Convention and the Aarhus Protocol. These treaties are implemented in the EU by the POPs Regulation.

What does the regulation do?
The Regulation prohibits or severely restricts the production, the placing on the market and use of POPs. The use of around 30 different substances and their derivatives or salts are prohibited.

Could there be POPs in my products?
This is a list of some of the most commonly found POPs and in what products they can often be found:

Polychlorinated Biphenyls (PCBs)
Older transformers, capacitors, industrial oils, hydraulic fluids, some paints, sealants, adhesives

Polybrominated Diphenyl Ethers (PBDEs) (DecaBDE, PentaBDE, OctaBDE)
Electronics (circuit boards, casings), upholstered furniture, mattresses, car seats, textiles, children’s toys

Hexabromocyclododecane (HBCDD)
Insulation foams, building materials, upholstered furniture, textiles, automotive parts

Short-Chain Chlorinated Paraffins (SCCPs)
PVC cables, wiring insulation, electronic casings, lubricants, adhesives, industrial metalworking fluids

Perfluorooctane Sulfonic Acid (PFOS) & Perfluorooctanoic Acid (PFOA)
Stain-resistant and waterproof textiles, non-stick cookware, food packaging (fast-food wrappers, popcorn bags), firefighting foams, coatings

Per- and polyfluoroalkyl substances (PFAS, broader group)
Cosmetics (waterproof mascaras, eyeliners), automotive coatings, food packaging, firefighting foams

Pentachlorophenol (PCP)
Wood preservatives, treated lumber, agricultural pesticides (historically used)

Lindane, Chlordane, DDT, Mirex (Legacy Pesticides)
Insecticides, termite treatments, soil and grain treatments (historical use, some legacy contamination)

How is this regulation being enforced?
In recent months there have been a spate of product recalls across Europe related to POPs. The most common of these has been from the use of SCCPs (short-chain chlorinated paraffins) in everything from electronic cables such as USB cables, toys and children’s products, stationery and sports equipment and games.

What other countries have regulations around POPs?
Most other countries have regulations that include bans or restrictions on POPs.

What should I be doing?
Make sure your supply chain is aware of these bans, and for any soft plastics you have on your products, ensure you or your supplier has tested them for SCCPs.

If you are yet to put together a robust strategy for managing materials compliance within your business, I can help.

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