EU Strengthens POPs Regulation: Significantly Tightens Concentration Limits for PBDEs

On July 24, 2025, the European Commission adopted an amendment to update limits for five polybrominated diphenyl ethers (PBDEs) under the EU Persistent Organic Pollutants Regulation (EU 2019/1021), enhancing protections for human health and the environment. The new rules propose phased reductions in residual limits for these substances in recycled-material products, particularly targeting toys, childcare articles, and household items made from recycled materials.

Background

PBDEs, recognized for their persistence, bioaccumulation potential, and toxicity, were listed in Annex A of the Stockholm Convention for global elimination as early as 2009. While the EU has phased out their production, PBDEs persist in new products (e.g., furniture, textiles) through recycled materials. Current regulations allow a Unintentional Trace Contaminant (UTC) of 500 mg/kg for PBDEs in mixtures or articles.

Key Updates

The amendment drastically tightens Unintentional Trace Contaminant (UTC) for tetra-, penta-, hexa-, hepta-, and deca-BDE (collectively PBDEs) in mixtures or articles:

• General products: PBDEs must not exceed 10 mg/kg (10 ppm) from the regulation’s effective date.
• Products containing recycled materials:
  ◦ Before December 30, 2025: Limit remains at 500 mg/kg;
  ◦ From December 30, 2025: Reduced to 350 mg/kg;
  ◦ From December 30, 2027: Further tightened to 200 mg/kg.
• Toys and childcare articles (with recycled content):
  ◦ Before December 30, 2025: Limit remains at 500 mg/kg;
  ◦ From December 30, 2025: Lowered to 350 mg/kg;
  ◦ 18 months post-enactment: Final limit of 10 mg/kg.
  

Note: Food contact materials are exempt, as stricter requirements under the Food Contact Materials Regulation (EC No 1935/2004) apply.

Next Steps

The amendment will undergo review by the European Parliament and the Council, and will enter into force 20 days after publication in the EU Official Journal. Once enacted, it will be directly applicable in member states, placing renewed compliance cost pressures on recycled plastics supply chains.

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Further Information

Amendment