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

Persistent Organic Pollutants (POPs) are tightly regulated under EU Regulation (EU) 2019/1021. But for electronics manufacturers, identifying POPs across complex, multi-tier supply chains isn’t straightforward — especially as new substances like PFHxS, Dechlorane Plus, and UV-328 continue to be added to Annex I.

1 Start with Your Bill of Materials (BOM)

Cross-reference your BOM against the most recent Annex I and Annex IV updates.

  • Look for flame retardants (e.g., HBCDD, DecaBDE)
  • Check polymers and coatings for UV-328
  • Review past use of PFAS compounds like PFHxS

Use structured BOM data—not just PDFs—for effective screening.

2 Engage Tier-1 and Tier-2 Suppliers

Your suppliers hold the key to POPs visibility.

  • Request POPs-specific declarations
  • Provide them with the updated substance list and thresholds
  • Focus on UTC limits (e.g., 0.025 mg/kg for PFHxS)

Pro tip: Use IPC-1752A or IEC 62474 formats to standardize responses.

3 Screen for Unintentional Trace Contaminants (UTCs)

Many POPs restrictions apply even if the substance is not intentionally added.

  • HBCDD limit: 75 mg/kg
  • PFHxS: 0.025 mg/kg
  • UV-328: Phased down to 1 mg/kg over 4 years

Don't just ask “Is it used?” — ask “Is it present?”

4 Assess Waste Streams for Annex IV Compliance

The moment your products become waste, stricter POPs thresholds apply.

  • Example: SCCPs threshold dropped from 1500 mg/kg to 420
  • Reuse of non-compliant materials is prohibited

This step is critical if you're reprocessing components or working with recyclates.

5 Automate Updates and Monitor Regulatory Change

The POPs list is expanding fast. Manual tracking won’t scale.

  • Use regulatory intelligence tools that map Annex changes
  • Tag suppliers who have legacy materials flagged in enforcement reports
  • Stay aligned with Stockholm Convention updates that may enter EU law

Common Mistakes to Avoid

  • Relying on outdated supplier data
  • Ignoring UTCs in recycled or legacy stock
  • Skipping Tier-2 and Tier-3 supplier engagement
  • Not updating waste management SOPs with Annex IV limits

How Acquis Simplifies POPs Compliance

Acquis offers pre-configured workflows for EU POPs that include:

  • Full BOM + Material Declaration Screening against Annex I and IV
  • Automated Supplier Engagement to request and validate POPs data
  • Integrated threshold risk flags for UTC exceedances
  • Real-time regulatory updates, mapped to product-level impact

You don’t have to choose between risk and complexity.

Assess your POPs exposure with Acquis today

Contact Acquis today to schedule a free supply chain risk audit or demo of our POPs compliance automation tools.

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How to Identify POPs in Your Supply Chain

Annex I lists substances that are banned or severely restricted in the EU, while Annex IV defines concentration thresholds in waste—if exceeded, the waste must be destroyed.
New additions include Methoxychlor, PFHxS and its related compounds, UV-328, and Dechlorane Plus. Each has specific limits and implementation timelines.
The threshold for HBCDD in waste was reduced to 75 mg/kg. However, recycled polystyrene for construction may still contain up to 100 mg/kg.
UV-328 is a long-range pollutant affecting Arctic ecosystems. Its phased restriction (100 → 10 → 1 mg/kg) gives industries time to adapt while reducing risk.
Electronics manufacturers, textile and furniture companies, agriculture producers, and the construction sector are directly impacted by these changes.
Manufacturers should screen materials using up-to-date BOM tools, collect supplier declarations, and ensure waste testing aligns with Annex IV limits.
Yes, many of the updates mirror the Stockholm Convention’s listings, enhancing regulatory harmonization and global environmental protection efforts.