EU Proposes to Add Chlorpyrifos, MCCPs, and C9-21 PFCAs under POPs Regulation

The European Commission has proposed to add chlorpyrifos, MCCPs and C9-21 PFCAs to Annex I of the EU POPs Regulation, effectively banning their manufacture, placing on the market and use in the EU with defined UTC limits and a few time-limited exemptions for critical applications.

On November 21, 2025, the European Commission published three draft delegated regulations proposing to amend Annex I to Regulation (EU) 2019/1021 (the POPs Regulation) by including Chlorpyrifos, Medium-chain chlorinated paraffins (MCCPs), and Long-chain perfluorocarboxylic acids (C9-21 PFCAs) as substances subject to elimination.

The proposal prohibits the manufacturing, placing on the market, and use of these substances within the European Union, establishing specific Unintentional Trace Contaminant (UTC) limits and time-limited exemptions for critical sectors. A public consultation on these drafts is currently open and will conclude on December 19, 2025.

1. Chlorpyrifos

Requirements: The prohibition on manufacturing, placing on the market, and use applies to concentrations of Chlorpyrifos equal to or above 0.01 mg/kg (0.000001% by weight) when present in substances, mixtures, or articles.
Exemptions: No specific exemptions are listed.

2. Medium-chain Chlorinated Paraffins (MCCPs)

The regulation sets a UTC limit of 1,000 mg/kg (0.1% by weight) for the sum of these substances in substances, mixtures or articles.

Due to the widespread use of MCCPs, the Commission has proposed several time-limited exemptions for specific industrial applications:

Application	Expiry Date
Extreme pressure additive in metalworking fluids	2036.12.31
Polymers and rubbers used in sapre parts and repair of: land-based motor vehicles; agricultural, construction, forestry or landscaping machinery; electric and electronic equipment for medical devices within the scope of Regulation (EU) 2017/745 electric and electronic equipment for in-vitro diagnostic devices within the scope of Regulation (EU) 2017/746; instruments for measurement, analysis, manufacturing, control, monitoring, testing and inspection; aerospace and defence applications.	End of service life or 2041.12.31 (whichever is earlier)
Flexible PVC in wires/cables in medical devices within the scope of Regulation (EU) 2017/745 and in-vitro diagnostic devices within the scope of Regulation (EU) 2017/746	5 years after entry into force
Adhesives, sealants, tapes used for non-structural bonding for aerospace and defence applications	5 years after entry into force
Paints and coatings for ammunition and ammunition markings	5 years after entry into force
Ammunition pyrotechnic defence devices	2041.12.31
Intumescent coating and paint for space and defence equipment and its packaging	2041.12.31
Coating and paint for the repair of, and use in replacement spare parts for, space and defence equipment, where MCCPs were initially used in the production	End of service life

3. Long-chain Perfluorocarboxylic Acids (C9-21 PFCAs)

Concentration Limits (UTC):

C9-21 PFCAs and salts: 0.025 mg/kg (0.0000025%)
Related compounds: 0.26 mg/kg (0.000026%)

Specific Derogations:

Transported Isolated Intermediates: Allowed up to 10 mg/kg (0.001%) strictly for producing fluorochemicals with carbon chains ≤ 6 atoms.
Fluoroplastics/Fluoroelastomers: A limit of 0.1 mg/kg (0.00001%) applies to the sum of C9-21 PFCAs in materials containing perfluoroalkoxy groups (excludes articles).
PTFE Micropowders: Allowed up to 1 mg/kg (0.0001%) provided they are transported/treated to reduce the concentration below the 0.025 mg/kg limit.

Time-Limited Exemption:

The use of these substances in semiconductors used as spare parts for combustion-engine vessels and legacy land-based motor vehicles is permitted until 30 December 2030.

Timeline and Implementation

The final acts are expected to be published in the Official Journal in Q1 2026. The regulations will enter into force on the twentieth day following their publications.