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Kimball Electronics
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Industrial Scientific
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roboception
FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
By Abhishek Shetty | Thu Jun 26 2025 | 2 min read

Table of Contents

The EU POPs Regulation (EU) 2019/1021 plays a critical role in eliminating or restricting Persistent Organic Pollutants (POPs) across the European market. With recent amendments in 2023, 2024, and 2025, manufacturers, importers, and waste handlers must align with new thresholds and substance listings under Annex I (substance restrictions) and Annex IV (waste limits).

What Are EU POPs Annexes?

eu pops annex.png

Latest Annex I Additions and Updates (2023–2025)

  • 1 Methoxychlor
  • Added: September 2024
  • Used in: Agricultural pesticides
  • Limit: 0.01 mg/kg (trace level)
  • Impact: Agrochemicals and legacy waste
  • 2 PFHxS, Its Salts, and Related Compounds
  • Added: August 2023
  • Includes: Branched isomers, salts, degradation products (C6F13S-)
  • Limit: 0.025 mg/kg
  • Use Cases: Electronics, textiles, firefighting foams
  • 3 UV-328
  • Added: May 2025
  • Used in: Plastics, rubber, coatings
  • Limit:
    • 100 mg/kg (immediate)
    • 10 mg/kg (after 2 years)
    • 1 mg/kg (after 4 years)
  • Note: Arctic environmental risk
  • 4 Dechlorane Plus
  • Added: May 2025
  • Used in: Flame retardant for electronics
  • Limit:
    • 1000 mg/kg (first 30 months)
    • 1 mg/kg after
  • Exemptions: Aerospace, critical safety applications
  • 5 Hexabromocyclododecane (HBCDD)
  • Updated: September 2024
  • New Limit: 75 mg/kg (was 100 mg/kg)
  • Exception: Recycled EPS/XPS in construction may use up to 100 mg/kg

Annex IV Waste Thresholds (2025 Enforcement)

If these thresholds are exceeded, destruction via Annex V methods is mandatory. Reuse or recycling is prohibited.

Annex IV Waste Thresholds.PNG

Why These Changes Matter

  • Tightened Controls

Lower thresholds reflect increased regulatory scrutiny and improved detection methods, especially for substances with long-range environmental mobility.

  • Circular Economy vs. Safety

While HBCDD can still be used in recycled polystyrene, controls are strict. It’s a balancing act between material reuse and public health.

  • Global Harmonization

The EU continues to align with the Stockholm Convention, adding PFHxS, Methoxychlor, and UV-328 in sync with global chemical management efforts.

Who’s Affected?

Who’s Affected substance of concern eu pops.png

How to Stay Compliant with Annex I & IV

  1. Screen products and BOMs against the latest Annex I listings
  2. Verify waste materials meet Annex IV thresholds
  3. Engage suppliers for full disclosure and safer substitutions
  4. Redesign products where phase-outs are unavoidable
  5. Maintain disposal documentation aligned with Annex V

Acquis POPs Compliance Program

At Acquis, we help manufacturers simplify EU POPs compliance with:

  • Real-time BOM screening
  • Annex IV waste-level checks
  • Supplier declaration automation
  • Lifecycle and phase-out tracking for POPs

Need help with UV-328, PFHxS, or Methoxychlor regulations? Contact us for a free compliance readiness assessment and stay ahead of EU enforcement.

Topics

POPs

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Understanding EU POPs Annexes: Updated Substance Limits, Waste Thresholds & Industry Impact

The EU POPs Regulation (EU) 2019/1021 organizes persistent organic pollutants into four annexes each dictating different controls: Annex I: Prohibited substances Annex II: Restricted substances Annex III: Release reduction obligations Annex IV: Waste management thresholds These categories guide usage, disposal, and monitoring obligations.
Recent additions include UV‑328 and Dechlorane Plus , bringing forward new prohibition controls with specific exemption windows and time-bound thresholds.
Annex IV defines low concentration limits for POPs in waste determining whether material must be destroyed or can be recycled.
Companies that manufacture, import, or sell chemicals, mixtures, or articles within the EU must ensure compliance, including screening BOMs and managing supply chain POP presence.
Use or placing on the market of substances in Annex I is strictly prohibited unless a narrow exemption applies. Finding such substances can lead to regulatory enforcement, requiring product recall or redesign.
Yes, under specific conditions. Some exceptions allow trace levels (e.g., ≤ 1 mg/kg) if they meet exemption rules or if the substance is unintentionally present.
Use real‑time BOM screening , supplier declarations, lifecycle tracking, and regulated threshold checks especially for updates like UV-328 and PFHxS, to stay compliant.