CDX Platform Updated: EU Adds Dechlorane Plus to POPs Regulation

Compliance Data eXchange (CDX) has been updated to include the latest regulatory changes regarding Dechlorane Plus under the EU Persistent Organic Pollutants (POPs) Regulation.

Following the European Commission's publication of Commission Delegated Regulation (EU) 2025/1930 on September 25, 2025, Dechlorane Plus and its isomers have been officially added to Annex I of the POPs Regulation (EU) 2019/1021. The regulation entered into force on October 15, 2025, implementing the EU's commitments under the Stockholm Convention, which listed Dechlorane Plus for global elimination in May 2023.

What is Dechlorane Plus?

Dechlorane Plus (CAS No. 13560-89-9, including syn-isomer CAS 135821-03-3 and anti-isomer CAS 135821-74-8) is a chlorinated flame retardant that has been widely used since the 1960s in various applications including:

• Electronics (wire and cable coatings, computer monitors, TV connectors)
• Automotive plastics and components
• Construction materials (plastic roofing)
• Industrial equipment and appliances

The substance has been designated as a persistent organic pollutant due to its long-lasting, bioaccumulative, and toxic properties. Scientific evidence has linked Dechlorane Plus to neurodevelopmental toxicity, oxidative damage, and potential endocrine disruption, with detections in environmental samples across the globe despite localized production.

Key Regulatory Requirements
Prohibition:

The regulation prohibits the manufacture, placing on the market, and use of Dechlorane Plus in the EU, except under specified exemptions.

Unintentional Trace Contaminant (UTC) Limits
The regulation establishes a two-stage approach for UTC limits to allow laboratories time to improve analysis accuracy:

• Until April 15, 2028: Maximum concentration of 1,000 mg/kg (0.1% by weight) in substances, mixtures, or articles
• After April 15, 2028: Maximum concentration reduced to 1 mg/kg (0.0001% by weight)

Industry Exemptions
Time-Limited Exemptions (until February 26, 2030):

• Aerospace, space, and defense applications
• Medical imaging applications
• Radiotherapy devices and installations

Extended Exemptions for Spare Parts:
Spare parts and repairs for products where Dechlorane Plus was originally used during production are permitted until December 31, 2043 or the end of their service life, whichever comes earlier, for:

• Land motor vehicles
• Fixed industrial machinery for agriculture, forestry, and construction
• Marine, garden, forestry, and outdoor power equipment
• Aerospace and defense applications
• Instruments for analysis, measurement, control, monitoring, testing, production, and inspection

For medical devices and in vitro diagnostic medical devices, spare parts may be used until the end of their service life without a specific date restriction.

Compliance Review
The European Commission will review the need for extending these exemptions by April 1, 2028, ahead of the next Stockholm Convention review.

Impact on Supply Chain Management
With Dechlorane Plus now officially restricted under the POPs Regulation, companies must:

• Update material declarations and compliance documentation
• Screen suppliers and components for Dechlorane Plus content
• Identify alternative flame retardants for new product development
• Manage existing inventory and spare parts within the exemption framework
• Ensure compliance with the phased UTC limits
   

Next Steps for Companies

Organizations using CDX should:

• Review current product portfolio for potential Dechlorane Plus presence, particularly in electronics, automotive components, and industrial equipment
• Contact suppliers to request updated Full Material Declarations (FMD) confirming Dechlorane Plus status
• Update internal compliance procedures to account for the new POPs restriction
• Plan for alternative materials if Dechlorane Plus is currently used in products outside exemption categories
•  Monitor regulatory updates as the Commission reviews exemptions in 2028

Additional Resources
The full text of Commission Delegated Regulation (EU) 2025/1930 is available on EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202501930