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EU Introduces Stricter Limits for PBDEs under POPs Regulation

The EU has tightened the UTC limits for PBDEs in products to 10 mg/kg but introduced temporary, phased-out derogations for recovered (recycled) materials

On October 28, 2025, The European Union has adopted Commission Delegated Regulation (EU) 2025/1482, which amends the existing Regulation (EU) 2019/1021 on persistent organic pollutants (POPs). This amendment shall enter into force on November 17, 2025.

This update focuses on Polybrominated Diphenyl Ethers (PBDEs), a group of flame retardants now classified as POPs. The regulation addresses the total concentration of five PBDEs: tetra-, penta-, hexa-, hepta-, and decaBDE.  

SubstanceCAS No.EC No.

Tetrabromodiphenyl ether C12H6Br4O

40088-47-9 and others254-787-2 and others
Pentabromodiphenyl ether C12H5Br5O32534-81-9 and others251-084-2 and others
Hexabromodiphenyl ether C12H4Br6O36483-60-0 and others253-058-6 and others
Heptabromodiphenyl ether C12H3Br7O68928-80-3 and others271-031-2 and others
Bis(pentabromophenyl) ether (decabromodiphenyl ether; decaBDE)1163-19-5214-604-9

Pursuant to Article 3(1) of Regulation (EU) 2019/1021, the manufacturing, placing on the market and use, whether on their own, in mixtures or in articles, of PBDEs listed in Annex I to that Regulation are prohibited.

However, listed PBDEs can present as Unintentional Trace Contaminants (UTCs) limit value of 500 mg/kg for the sum in mixtures and articles. 

New Concentration Limits

The core change is the establishment of new, lower concentration limits for the sum of these PBDEs in mixtures and articles:

  • General Limit: The maximum allowed concentration for the sum of PBDEs in new mixtures or articles is now set at 10 mg/kg. This limit applies from November 17, 2025.

Phased-out Derogations for Recovered Materials

Crucially, the new regulation introduces specific derogations for PBDEs to support the circular economy by allowing higher, phased-out limits for materials made from recovered (recycled) waste.

Application/Material TypeLimit as of November 17, 2025Limit as of December 30, 2025Limit as of Year 2027
General Recovered Material500 mg/kg350 mg/kg200 mg/kg (as of December 30)
Recovered Material in Toys (subjec to Directive 2009/48/EC) & Childcare Articles500 mg/kg350 mg/kg10 mg/kg (as of May 17)

The regulation explicitly excludes food contact materials from these derogations, which remain subject to the stricter Regulation (EC) No 1935/2004.

The Regulation (EU) 2025/1482 can be accessed here

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