[Regulation]Regulation update: EU POPs Amendment (PBDE requirements revised)
23 Nov 2025
On 28 October 2025, the EU Commission published an amendment to Annex I (Prohibited substances list) of the POPs Regulation, revising the UTC (Unintentional Trace Contaminant) maximum allowable limits for the five PBDEs by product type. ※ PBDE (Polybrominated Diphenyl Ethers) ※ UTC (Unintentional Trace Contaminant)
POPs (Persistent Organic Pollutants): Substances that, once released into the environment, can accumulate and cause significant harm to ecosystems and human health.
Categories of Chemicals Classified as POPs
Pesticides e.g., DDT – a chlorinated pesticide that was widely used in agriculture and public health applications in the past.
Industrial chemicals e.g., PCBs – synthetic organic compounds formerly used in various applications such as flame retardants and electrical insulation.
Unintentionally produced by-products e.g., dioxins and furans – formed during industrial processes, thermal degradation, or combustion.
Key Changes
The UTC limits for the five PBDEs listed under Annex I (Prohibited Substances List) of the EU POPs Regulation have been revised. PBDEs were widely used in the past as flame retardants, but due to extensive regulatory measures, their new use is now largely prohibited. Nevertheless, PBDEs continue to be detected in certain products through the use of recycled materials. In particular, for consumer products with high potential exposure - such as childcare articles and toys - it was deemed necessary to establish separate UTC thresholds. Consequently, the amendment introduces differentiated UTC limits for products made with recycled materials and those that are not.
On 28 October 2025, the EU Commission published an amendment to Annex I (Prohibited substances list) of the POPs Regulation, revising the UTC (Unintentional Trace Contaminant) maximum allowable limits for the five PBDEs by product type.
※ PBDE (Polybrominated Diphenyl Ethers)
※ UTC (Unintentional Trace Contaminant)
Regulation Overview
The EU POPs (Persistent Organic Pollutants, 2019/1021) is based on the Stockholm Convention and establishes requirements for the prohibition, restriction, reduction of emissions, and waste management of persistent organic pollutants.
POPs (Persistent Organic Pollutants): Substances that, once released into the environment, can accumulate and cause significant harm to ecosystems and human health.
Categories of Chemicals Classified as POPs
Pesticides
e.g., DDT – a chlorinated pesticide that was widely used in agriculture and public health applications in the past.
Industrial chemicals
e.g., PCBs – synthetic organic compounds formerly used in various applications such as flame retardants and electrical insulation.
Unintentionally produced by-products
e.g., dioxins and furans – formed during industrial processes, thermal degradation, or combustion.
Key Changes
The UTC limits for the five PBDEs listed under Annex I (Prohibited Substances List) of the EU POPs Regulation have been revised. PBDEs were widely used in the past as flame retardants, but due to extensive regulatory measures, their new use is now largely prohibited. Nevertheless, PBDEs continue to be detected in certain products through the use of recycled materials. In particular, for consumer products with high potential exposure - such as childcare articles and toys - it was deemed necessary to establish separate UTC thresholds. Consequently, the amendment introduces differentiated UTC limits for products made with recycled materials and those that are not.
Commission Delegated Regulation (EU) 2025/1482
Official Journal: October 28, 2025
Entry into Force: November 17, 2025
Details of the Amendment: Revision of the maximum allowable limits for the sum of the five PBDEs in mixtures and articles (see table below).
TetraBDE
40088-47-9 and others
500 mg/kg
(a) Products without recovered materials
- 10 mg/kg (from November 17, 2025)
(b) Products containing recovered materials
- 500 mg/kg (from November 17, 2025)
- 350 mg/kg (from December 30, 2025)
- 200 mg/kg (from December 30, 2027)
(c) Toys, childcare articles, and children's products containing recovered materials
- 500 mg/kg (from November 17, 2025)
- 350 mg/kg (from December 30, 2025)
- 10 mg/kg (from December 30, 2027)
* Excluding food contact materials (FCMs)
PentaBDE
32534-81-9 and others
HexaBDE
36483-60-0 and others
HeptaBDE
68928-80-3 and others
DecaBDE
1163-19-5