Amendments to the POPs Regulation on UV-328, PFOA and PFOS

In May 2025, the European Commission adopted three delegated regulations amending Annex I of Regulation (EU) 2019/1021 on persistent organic pollutants (POPs). These legislative updates address the management and use of substances such as UV-328, PFOA, and PFOS, affecting various industrial sectors including manufacturing, environmental protection, and fire safety.

The main regulatory developments are outlined below:

• Inclusion of UV-328 in Annex I of the POPs Regulation
  UV-328, an anti-UV additive already listed as an SVHC under the REACH Regulation Candidate List, has now been formally included among the banned persistent organic pollutants. This measure introduces a general restriction on the manufacture and use of the substance, with only limited exemptions for specific and well-justified applications.
• Extension of the transitional period for PFOA in firefighting foams
  Although restrictions are already in force, an additional transitional period has been granted for the use of PFOA, its salts and related compounds in firefighting foams. The aim is to ensure operational safety while allowing sufficient time to switch to compliant alternatives.
• Alignment of limits for PFOS and related substances
  The third regulatory update concerns PFOS, its salts and related compounds. Concentration limits have been significantly lowered and aligned with those already applied to other regulated PFAS. Specifically:
  • 0.025 mg/kg for PFOS and salts in substances and mixtures (previously 10 mg/kg),
  • 0.025% by weight in articles (previously 0.1%),
  • 1 mg/kg for the sum of related compounds.
    This measure aims to harmonise contamination thresholds for high-concern fluorinated substances, promoting a more consistent and stringent chemical risk management approach across the EU.

The adoption of these regulations, between April and May 2025, anticipates their publication in the Official Journal of the European Union. Companies affected by the changes are advised to assess the impact on their product portfolios, with particular focus on substitution requirements and existing stock management.

To support companies in complying with the POPs Regulation, Normachem provides expert consultancy on:

• substance assessment in products;
• management of exemptions and transitional periods;
• substitution strategies and supply chain communication.