EU Revises Persistent Organic Pollutants (POPs) Regulation to Strengthen Controls on Perfluorooctane Sulfonic Acid (PFOS)

On June 27, 2025, the EU Commission adopted Regulation (EU) 2025/718, updating the Persistent Organic Pollutants (POPs) Regulation 2019/1021. The amendments enhance controls on PFOS through tightened UTC limits, updated terminology, and removal of exemptions.

Background

Regulation (EU) 2019/1021 implements the EU’s international commitments on POPs. Annex I of the regulation originally set the Unintentional Trace Contaminant (UTC) limits for PFOS. As one of the first per- and polyfluoroalkyl substances (PFAS) regulated in the EU, PFOS’s UTC limits were established earlier. In recent years, perfluorooctanoic acid (PFOA), a similar compound with comparable uses, was added to Annex I of Regulation (EU) 2019/1021, with its UTC limits significantly lower than those for PFOS. This indicates that achieving lower PFOS contamination levels is now technically feasible. Consequently, the EU Commission has adjusted PFOS’s UTC limits to align with PFOA standards.

Key Revisions

1. Tightened UTC Limits

• Concentrations of PFOS or any of its salts present in substances, mixtures, or articles: UTC limits reduced from 10 mg/kg to 0.025 mg/kg (0.0000025%), aligning with PFOA’s thresholds.
• The sum of concentrations of all PFOS-related compounds: Limits lowered to 1 mg/kg (0.0001%).

2. Terminology Updates

The definition of PFOS in Annex I is revised from "perfluorooctane sulfonic acid and its derivatives (PFOS)" to "Perfluorooctane sulfonic acid (PFOS), its salts and PFOS-related compounds C8F17SO2X (X = OH, Metal salt (O-M+), halide, amide, and other related compounds including polymers)" This harmonizes PFOS’s regulatory language with PFOA and ensures broader coverage of related substances.

3. Removal of PFOS Exemption for Hard Chromium (VI) Plating Inhibitors

The exemption allowing PFOS use in hard chromium (VI) plating inhibitors has been deleted, reflecting the availability of alternatives across the EU.

Implementation Timeline

The revised regulation will enter into force 20 days after publication in the Official Journal and will be binding and directly applicable in all EU member states. Key provisions, including updated limits and the removal of exemptions, will take effect from December 3, 2025, allowing industries (e.g., chemicals, electroplating) and member states time to ensure compliance. Affected sectors must adjust production processes to meet the new PFOS standards.

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Further Information

Official Journal