PRODUCT STEWARDSHIP Scientific rigour. Practical assurance.
EXPERTISE · POPS

POPs — Persistent Organic Pollutants

Regulation restricting chemicals that persist in the environment and bioaccumulate.

Screening for restricted persistent organic pollutants.

The POPs Regulation restricts or prohibits chemicals that persist in the environment, bioaccumulate and pose a risk to human health, implementing international commitments under the Stockholm Convention.
We help organisations screen materials and products for POPs-restricted substances and understand the practical implications for formulation, sourcing and waste.
Material and product screening for restricted POPs
Formulation and sourcing risk reviews
Waste and end-of-life implications
Supply chain evidence requests and reviews
HOW SUBSTANCES ARE CONTROLLED

Three ways a substance can be listed.

The POPs Regulation controls persistent organic pollutants through three different mechanisms, depending on how the substance arises and whether any continuing use can be justified.

Elimination (Annex I)
Substances subject to a prohibition on manufacture, use, and placing on the market, with only a small number of narrowly defined exemptions listed against specific substances.
Restriction (Annex II)
Substances that may still be manufactured, used or placed on the market, but only for specific purposes and subject to conditions set out against that substance.
Release reduction (Annex III)
Substances that arise unintentionally as by-products of combustion or industrial processes, where the requirement is to reduce releases through action plans and reporting, rather than eliminate a deliberate use.
POPS IN WASTE

Waste containing POPs has its own rules.

Where a material or waste stream contains a POP substance above the concentration limit set out for it, standard waste disposal or recovery routes are not available. The POP content has to be destroyed or irreversibly transformed before the waste can be managed — it cannot simply be landfilled or exported without that treatment.

This has direct implications for long-life equipment and legacy materials, where components or coatings specified decades ago can turn out to contain a substance later added to the POPs Annexes, only becoming apparent at overhaul, refit or decommissioning.

POPs screening for legacy materials, components and waste streams
Concentration testing against current Annex IV limits
Treatment and disposal route planning for POPs-containing waste
Evidence and reporting to support compliant disposal
GB & EU DIVERGENCE

The UK and EU POPs lists do not always move together.

Both regimes trace back to the same Stockholm Convention obligations, but they have diverged since EU Exit. A substance, exemption or concentration limit can differ between the two regimes at any given time, so a position that is correct for one market is not automatically correct for the other.

UK POPs Regulation
Retained in domestic law after EU Exit and enforced by the environment agencies in England, Scotland, Wales and Northern Ireland. New substances and revised limits are added through UK-specific statutory instruments, on the UK’s own timetable.
EU POPs Regulation
Implemented and enforced across EU member states, with new substances and limits added through EU-level amending regulations, on a timetable set by the European Commission and Council.
PFAS

One substance group, several routes of regulation.

Per- and polyfluoroalkyl substances (PFAS) are a very large group of substances, and they are being addressed through several different mechanisms at once rather than a single regulation. Some individual PFAS, including PFOA and PFHxS, are already listed under the POPs Regulation. Others fall within REACH restrictions for specific applications, and a broader REACH restriction proposal covering PFAS as a group is working its way through the EU process.

That overlapping picture makes PFAS one of the harder substance groups to get a clear position on — a single product can be affected by more than one regime at once, and the position can shift as restriction proposals and POPs listings move forward.

Identification of PFAS within products, materials and bills of materials
Tracking PFAS-specific developments across REACH, POPs and RoHS
Alternatives analysis where a PFAS substance needs to be substituted
Building a defensible, evidenced PFAS position ahead of regulatory change
HOW WE HELP

Keeping a POPs position current across GB and EU markets.

POPs lists do not stand still, and a substance that was unregulated when a material or product was specified can be added to Annex I, II or III years later, sometimes at different times in the UK and the EU.
We help screen products, materials and waste streams against the current UK and EU POPs Annexes, track upcoming listing decisions relevant to your sector, and plan compliant treatment and disposal routes when a POP is found in a legacy material or waste stream.
POPs applicability screening for products, materials and waste
Annex I, II and III status tracking across UK and EU regimes
Waste treatment and disposal route planning for POPs-containing materials
Alignment with REACH, RoHS and defence material assurance work
Next: EXPERTISE
DSEAR

Ready to talk through your requirement?

Tell us where the uncertainty sits. We will help you define the requirement and the right level of support.
Product Stewardship

Need help with REACH, CLP or material compliance?

Get specialist regulatory and material assurance support across the UK, EU, industry and defence sectors — REACH, CLP, BPR, DSEAR and the evidence to back it up.

Call 07584 073 768 Contact Us
Email queries: support@ps-ltd.co.uk

Product Stewardship Ltd provides specialist regulatory support, material assurance and compliance training for organisations operating across the UK, EU, industry and defence sectors.

Coverage: UK, EU & Defence sectors
Regulators: HSE & ECHA
Contact & Help

Speak to us about REACH, CLP, defence material assurance, training or workplace compliance.

© 2026 Product Stewardship Ltd
Product Stewardship Ltd · Registered in England & Wales, Company No. 12143264 · Registered office: 140 Lee Lane, Horwich, BL6 7AF · VAT No. GB430 9538 93