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PFOS Regulatory Limits Are Tightened by the EU Under the POPs Regulation

Introduction

· The amendment eliminates exemptions for PFOS used as a mist suppressant for non-decorative hard chromium (VI) plating and increases the regulatory limits for PFOS, its salts, and related chemicals.

· Regarding perfluoro octane sulfonic acid and its derivatives, the European Commission published Commission Delegated Regulation (EU) 2025/718 of 14 April 2025 in the Official Journal of the European Union on June 27, 2025, amending Regulation (EU) 2019/1021 of the European Parliament and of the Council.

· With the implementation of more stringent unintended trace contaminant (UTC) limit values for PFOS and the elimination of certain exemptions for PFOS, this rule modifies some provisions for perfluoro octane sulfonic acid and its derivatives (PFOS) under the EU’s POPs Act.

Limits of UTC

· The updated UTC (unintentional trace contaminant) limits for PFOS have been revised to align with those established for another PFAS group perfluorooctanoic acid (PFOA), its salts, and PFOA related compounds which were previously added to Annex I of Regulation (EU) 2019/1021 with significantly lower threshold values.

· This alignment demonstrates that it is technically feasible to regulate these substances at reduced levels. Consequently, the UTC limits for PFOS have been amended as follows:

(1) ≤ 0.025 mg/kg (0.0000025% by weight) for PFOS or any of its salts present as UTC in substances, mixtures, or articles.

(2) ≤ 1 mg/kg (0.0001% by weight) for the total concentration of all PFOS related compounds present as UTC in substances, mixtures, or articles.

· Additionally, to ensure consistency with the entries for PFOS and PFOA, the description in the first column for PFOS has been revised to read: “Perfluoro octane sulfonic acid (PFOS), its salts and PFOS-related compounds.”

· The UTC restriction provisions will go into effect on December 3, 2025. On July 17, 2025, additional modifications will take effect.

Exclusions

· The exception for using PFOS as a mist suppressor for non-decorative hard chromium (VI) plating is eliminated by the amendment on PFOS has been employed in place of

Mist suppressants in hard chromium plating in the Union, according to data gathered at the Member State level about those compounds.

· Additionally, the PFOS entry about the availability of analytical methods has been removed.

Outline

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