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EU Proposes Limit for PCP Under POP Recast

SafeGuardSHardgoods, Softlines, Softlines, Softlines, Hardgoods, Softlines, Electrical & ElectronicsSeptember 09, 2020

The European Commission has published a draft Regulation to set a limit for PCP, its salts and esters, under the POP Recast Regulation. The draft law is proposed to be adopted in Q4 of 2020.

In June 2019, the European Union (EU) published Regulation (EU) 2019/1021 on persistent organic pollutants (recast) – ‘the POP Recast Regulation’. Since its publication, Annex I to Part A of POP recast has been amended on several occasions. These include:

  • Adding perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds (SafeGuardS 96/20)
  • Replacing an existing derogation on perfluorooctane sulfonic acid and its derivatives (PFOS) as a mist suppressant for non-decorative hard chromium (VI) plating in closed loop systems (Regulation (EU) 2020/1203)
  • Adding dicofol – a pesticide (Regulation (EU) 2020/1204)

When the POP Recast Regulation was published, pentachlorophenol (PCP) and its salts and esters were listed in Annex I to the legislation without an Unintentional Trace Contaminant (UTC) limit value. Since that publication, the European Commission (EC) has determined these substances are an impurity in some articles, including imported textiles and recovered wood chips for the manufacture of wood panels. 

Since the beginning of September 2020, the EC website has made available a draft Regulation to set a limit of no more than 5 mg/kg for PCP and its salts and esters in Part A to Annex I of the POP Recast Regulation. This defined limit would facilitate enforcements and allow the continuation of recycling of wood chips.

Comments on the draft legislation will be accepted until September 29, 2020.

According to the EC website, the draft Regulation is proposed to be adopted in Q4 of 2020 and will enter into force on the twentieth day following its publication in the Official Journal of the EU (OJEU).

Highlights of PCP and its salts and esters in the draft legislation and a comparison with the POP Recast Regulation  are summarized in Table 1.

Part A to Annex I of Regulation (EU) 2019/1021
Substances listed in the Convention and in the Protocol as well as substances listed only in the Convention 

Draft Regulation to amend Part A to Annex I of Regulation ((EU) 2019/1021
Part A to Annex I of Regulation (EU) 2019/1021
PCP and its salts and esters
(CAS 87-86-5 and others)
PCP and its salts and esters
(CAS 87-86-5 and others)
Specific exemption on intermediate use or other specification
5 mg/kg for constituent of substances, in mixtures or articles
Effective Date
20th day after publication in the OJEU
(potentially late 2020 or early 2021)
July 2019

Table 1

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