Persistent Organic Pollutants (POPs) are organic chemicals that resist degradation, are widely distributed through natural processes, accumulate in living organisms, and are toxic to both humans and wildlife over prolonged exposure. They include both intentionally produced pesticides and industrial chemicals, as well as unintentionally formed contaminants.
To manage the environmental and health hazards, POPs are regulated by the Stockholm Convention, an international environmental treaty ratified by over 180 countries, and Regulation (EU) 2019/1021, which implements the treaty within the EU.1 This article summarizes the main obligations imposed by the Regulation on product manufacturers and waste sector operators, with a primary focus on compliance testing.
Restrictions on placing POP-containing products on the market
The Stockholm Convention requires signatories to eliminate or restrict the use and trade of POPs, while still allowing exemptions in specific circumstances where replacements are not available. The treaty groups the substances into three broad categories:
Intentionally produced POPs to be eliminated are listed in Annex A.
Intentionally produced POPs to be restricted are listed in Annex B.
Unintentionally produced (byproduct) POPs to be reduced or eliminated are listed in Annex C.
Some substances may be produced intentionally and as byproducts, therefore falling into more than one category.
Annexes I and III of the EU POPs Regulation largely correspond to Annexes A and C of the Convention, respectively, but Annex I provides additional detail on exemptions and acceptable trace contamination levels in products brought to market in the EU. The Regulation also imposes stricter restrictions on some substances, notably PFOS and DDT, which are subject to elimination in the EU despite being listed in Annex B to the Convention.
Table 1: Restricted substances and substance groups under the EU POPs Regulation
Substance/substance group | Max. trace contamination level | POPs Regulation Annex | Stockholm Convention Annex |
PBDEs: tetra-, penta-, hexa-, hepta-, and decabromodiphenyl ether | 10 mg/kg per compound in substances 10 mg/kg for the sum of PBDEs in mixtures and articles* | I | A |
Perfluorooctane sulfonic acid (PFOS), its salts, and related compounds | 0.025 mg/kg for PFOS and its salts 1 mg/kg for the sum of PFOS-related compounds | I | B |
Organochlorine pesticides: aldrin, chlordane, chlordecone, DDT, dicofol, dieldrin, endosulfan, endrin, heptachlor, mirex, toxaphene, and hexachlorocyclohexanes, including lindane | – | I | A for all except DDT B for DDT |
Hexachlorobutadiene | – | I & III | A & C |
Hexachlorobenzene | 10 mg/kg | I & III | A & C |
Pentachlorobenzene | – | I & III | A & C |
Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF) | – | III | C |
Polychlorinated biphenyls (PCB) | –** | I & III | A & C |
Hexabromobiphenyl | – | I | A |
Hexabromocyclododecane (HBCDD) | 75 mg/kg 100 mg/kg in EPS and XPS insulation materials | I | A |
Pentachlorophenol and its salts and esters | 5 mg/kg | I | A |
Polychlorinated naphthalenes | – | I & III | A & C |
Short-chain chlorinated paraffins (SCCPs) | 1% in substances and mixtures 0.15% in articles | I | A |
Perfluorooctanoic acid (PFOA), its salts, and related compounds | 0.025 mg/kg for PFOA and its salts*** 1 mg/kg for the sum of PFOA-related compounds | I | A |
Perfluorohexane sulfonic acid (PFHxS), its salts, and related compounds | 0.025 mg/kg for PFHxS and its salts 1 mg/kg for the sum of PFHxS-related compounds | I | A |
Methoxychlor | 0.01 mg/kg | I | A |
UV-328 | 100 mg/kg**** 10 mg/kg from 4 August 2027 1 mg/kg from 4 August 2029 | I | A |
Dechlorane plus | 1,000 mg/kg***** 1 mg/kg from 15 April 2028 | I | A |
Polycyclic aromatic hydrocarbons (PAH)****** | – | III | – |
* The limit does not apply to food contact materials, because they must not contain BDEs in the first place. Higher limits apply to products containing recovered material, and to toys and childcare articles until May 2027. Electronics are exempted; the max limit for the sum of PBDEs in electrical and electronic equipment is 0.1% (1,000 mg/kg) as per the RoHS Directive 2011/65/EU.
** No general trace contamination limit, but equipment containing PCBs in excess of 0.005% must be identified and removed from use.
*** Higher limits apply to firefighting foams until August 2028.
**** Several derogations until August 2030, including motor vehicles, industrial coatings, photographic paper, and certain spare parts.
***** Several derogations until February 2030, including aerospace and defense applications, medical imaging, radiotherapy devices, and certain spare parts.
****** PAH compounds are not restricted under the Stockholm Convention, but rather the Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution on Persistent Organic Pollutants, which is why they are included in the EU POPs Regulation.
Addition of new substances
The Stockholm Convention and the EU POPs Regulation both include a mechanism for adding new substances, and pollutants added to the Convention are typically incorporated into the Regulation within one to two and a half years.2 Recent additions to the Convention include chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids (LC-PFCAs), which are expected to be incorporated into the Regulation during 2026.3
How are target substances selected for POP testing?
Compliance with the EU POPs Regulation can be demonstrated by screening the product for regulated compounds that are likely to be present based on material composition and typical contamination sources. The following are examples of products that have repeatedly been found to violate POP limits during market surveillance in EU member states.4 Similar products should be screened for the same compounds to avoid recalls and border rejections:
Cables, wires, and cords in electrical appliances and equipment are often found to contain SCCPs in excess of the 0.15% trace contamination limit.
SCCPs are also a typical contaminant in other plastic and rubber-containing products, such as toys, childcare articles, hand tools, and sports equipment.
Synthetic textiles, such as water-resistant jackets and bags, have been found to contain PFOA-related compounds and LC-PFCAs.
Cosmetic products, including eyeliners, lip liners, and hair products, often contain the PFOA-related compound perfluorononyl dimethicone.
Food products, particularly herbs, spices, fruit, and vegetables, are still occasionally found to contain pesticides identified as POPs in the original Stockholm Convention list from 2004, including DDT and hexachlorobenzene. Chlorpyrifos, which awaits incorporation into the POPs Regulation, is a more common finding.5
Waste classification and management in accordance with the EU POPs Regulation
Article 7 of the POPs Regulation requires companies that generate or handle waste to take “all reasonable efforts” to avoid the contamination of the waste with POPs. If the concentration limits specified in Annex IV to the Regulation are exceeded, the waste must be treated so that the POP content is “destroyed or irreversibly transformed”. This typically means incineration or physico-chemical treatment, making POP-containing waste effectively non-recyclable in the vast majority of cases.6
Table 2: Concentration limits for identification of POP-containing waste
Substance/substance group | Classification limit (Annex IV)* | Permanent storage limit (Annex V)** |
Dioxins and furans (PCDD/PCDF) and dioxin-like PCBs | 5 µg/kg | 5 mg/kg |
PFOA, its salts, and related compounds | 1 mg/kg for PFOA and its salts 40 mg/kg for related compounds | 50 mg/kg for PFOA and its salts 2,000 mg/kg for related compounds |
PFHxS, its salts, and related compounds | 1 mg/kg for PFHxS and its salts 40 mg/kg for related compounds | 50 mg/kg for PFHxS and its salts 2,000 mg/kg for related compounds |
Polychlorinated naphthalenes | 10 mg/kg | 1,000 mg/kg |
PFOS and its derivatives | 50 mg/kg | 50 mg/kg |
Polychlorinated biphenyls (PCB) | 50 mg/kg | 50 mg/kg |
Pesticides: aldrin, chlordane, chlordecone, DDT, dicofol, dieldrin, endosulfan, endrin, heptachlor, mirex, and toxaphene | 50 mg/kg per compound | 5,000 mg/kg per compound |
Hexachlorobenzene | 50 mg/kg | 5,000 mg/kg |
Hexachlorocyclohexanes, including lindane | 50 mg/kg | 5,000 mg/kg |
Hexabromobiphenyl | 50 mg/kg | 5,000 mg/kg |
Pentachlorobenzene | 50 mg/kg | 5,000 mg/kg |
Hexachlorobutadiene | 100 mg/kg | 1,000 mg/kg |
Pentachlorophenol, its salts and esters | 100 mg/kg | 1,000 mg/kg |
PBDEs: sum of tetra-, penta-, hexa-, hepta-, and decabromodiphenyl ether | 350 mg/kg 200 mg/kg from December 30, 2027 | 10,000 mg/kg |
Hexabromocyclododecane (HBCDD) | 500 mg/kg | 1,000 mg/kg |
Short-chain chlorinated paraffins (SCCPs) | 1,500 mg/kg | 10,000 mg/kg |
* Exceeding these limits specified in Annex IV triggers the obligation to destroy or irreversibly transform POP content. If these limits are exceeded but the Annex V limits are not, deposit in a hazardous waste landfill may be authorized under exceptional circumstances.
** If the limits specified in Annex V are exceeded, deposit in a hazardous waste landfill is not permitted, but permanent underground storage may be authorized under exceptional circumstances.
Waste sector operators are responsible for identifying POP-containing waste to ensure that it is treated accordingly. This means that waste that is likely to contain or be contaminated with POPs should be screened for substances known to occur in that waste stream. The following are examples of typical contaminants in selected high-risk waste streams:7
Construction and demolition waste: PCBs and SCCPs in sealants; HBCDD in EPS and XPS insulation; PBDEs, HBCDD, and SCCPs in plastic components
Waste electrical and electronic equipment (WEEE): BDEs, HBCDD, and SCCPs in plastic components; PBDEs, HBCDD, PFOA, PFHxS, and related compounds in printed circuit boards and other semiconductor components
Scrap vehicles: decaBDE, HBCDD, and PFOS in textiles; SCCPs and PFOS in leather; PBDEs, HBCDD, and PFOA-related compounds in plastic parts
Textile waste: PBDEs and HBCDD in upholstery, polyurethane and polystyrene fillings, curtains, and bedding for use in public spaces; decaBDE, SCCPs, and pentachlorophenol in military tents
Firefighting foams: PFOS, PFOA, PFHxS, and their salts and related compounds
Analytical methods
Several test methods are available for POP analysis, depending on the target compounds and the sample matrix. To show that the acceptable trace contamination levels are not exceeded, the required detection limit is typically in the parts per million (ppm) and sometimes in the parts per billion (ppb) range. Methods capable of reaching this level include high-resolution variations of gas chromatography-mass spectrometry (GC-MS) and liquid chromatography-mass spectrometry (LC-MS).
One partner for all your POP testing needs
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Full analysis package covering all compounds listed in the EU POPs Regulation and the Stockholm Convention up until the 2025 revision
Targeted analysis package for WEEE and other plastics, covering the most common contaminants
Dioxins and furans (PCDD/PCDF) in plastics, food and feed, and environmental samples
Pesticide residues in non-perishable food, feed, and supplements
PFAS compounds in practically any matrix, from water, food, and packaging materials to industrial chemicals
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References:
1 The Stockholm Convention on Persistent Organic Pollutants and Regulation (EU) 2019/1021 (consolidated to 01/01/2026.
2 Examples of substances identified as POPs in recent years include methoxychlor (Convention: May 2023, Regulation: October 2024), UV-328 (Convention: May 2023, Regulation: August 2025), and Dechlorane Plus (Convention: May 2023, Regulation: October 2025).
3 European Commission initiatives on adding chlorpyrifos, MCCPs, and LC-PFCAs to Regulation (EU) 2019/1021 on the Have your say portal. The planned Commission adoption dates are Q1 2026 for chlorpyrifos and LC-PFCAs and Q2 2026 for MCCPs, although the Q1 deadlines have already passed without publication.
4 The examples are based on the European Commission's Safety Gate and RASFF portals, to which EU member states’ market surveillance and customs authorities report dangerous non-food and food products, respectively.
5 Chlorpyrifos is currently restricted under Regulation (EC) No 396/2005 on pesticide residues and has a maximum residue level (MRL) of 0.01 mg/kg in all product groups.
6 An exception applies to recycling and reclamation of metals in certain iron- and steel-making processes. See Part 1 of Annex V to Regulation (EU) 2019/1021 for details.
7 The examples are based on the Finnish Ministry of the Environment’s 2023 guide for the identification of POPs waste (in Finnish). The risk for POP presence is higher in materials that were brought to market before the respective compounds were prohibited under the POP Regulation.