EU regulation

POPs Regulation – Substances, Articles, and Waste

Published: Last fact-checked:

Overview

Short answer

The POPs Regulation prohibits or restricts persistent organic pollutants in substances, mixtures, and articles and also sets specific waste rules. Companies must check the current consolidated annex for each relevant substance; there is no single universal concentration limit for every POP.

Legal status

Law in force

Regulation (EU) 2019/1021 is in force and its annexes are amended over time. The assessment is based on the consolidated version current on 29 July 2026.

Part 1

What the POPs Regulation controls

The Regulation implements EU obligations under the Stockholm Convention and controls manufacturing, placing on the market, use, stockpiles, and waste for listed substances. Annexes I and II are central to product prohibitions and restrictions. Annexes IV and V govern POP-containing waste. An article can therefore be relevant both when sold and later when it becomes waste.

Part 2

Which companies need an assessment?

Manufacturers, importers, and distributors need to understand whether listed substances occur in materials, components, or recycled content. An importer cannot assume that a non-EU declaration uses the EU list or correct limit. Waste operators have separate duties, but product companies should understand end-of-life implications during design and sourcing.

Part 3

Read the substance entry, not only the name

Each entry may have its own scope, unintentional trace contaminant limit, derogations, and dates. Record the CAS or EC number, material or article, annex version, and any exemption relied on. A generic statement that a product is “POPs compliant” does not establish what was checked.

Part 4

Evidence that withstands review

A robust chain combines material specifications, supplier declarations, an FMD, or targeted analysis where risk warrants it. Test reports must identify the sample, method, and detection limit. Recycled material often needs closer control because legacy content may be unknown. Record positive evidence and unresolved gaps.

Part 5

A traceable POPs workflow

  1. Match BOM materials to plausible POP uses.
  2. Prioritise high-risk materials and recycled content.
  3. Request substance-specific supplier data.
  4. Check the current annex and derogations.
  5. Escalate gaps to testing or design decisions.
  6. Lock the assessment to the product and BOM version.
  7. Monitor annex amendments.

The approved conclusion should identify the exact substance entry, annex version, affected BOM revision, and evidence supporting the decision.

Part 6

Common mistakes

Common failures include conflating REACH and POPs, using an old substance list, assuming RoHS testing covers POPs, or applying a waste limit as a product limit. Teams may also assess only bulk material and miss coatings, flame retardants, plasticisers, or a small component that remains an article in the finished product.

Checklist

Key takeaways

  • Assess against the current substance entry and correct annex.
  • Product restrictions and waste limits are separate legal questions.
  • Supplier evidence must identify the product, material, substance, and assessment date.
  • A changed BOM, recycled material, or annex version must trigger reassessment.

Questions and answers

Frequently asked questions

Are all POPs banned in every product?

No. Scope, limits, and derogations are defined in each substance entry and the current annex.

Is a REACH declaration sufficient?

Not automatically. REACH and POPs are separate frameworks, and the declaration must explicitly cover the relevant POP requirements.

When is laboratory testing needed?

When risk is material and documentation does not provide sufficient confidence. Testing should target the correct material and detection limit.

Must recycled material be checked?

Yes where it enters a relevant product or waste stream. Unknown legacy content can make supplier and testing controls particularly important.

Further reading

Official sources

How Verca helps

How Verca can support the process

Verca can connect materials, components, supplier documents, and assessment status to the correct product version. It provides structure and traceability but does not replace laboratory analysis or the company’s legal assessment of a substance entry.

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