Background

As early as 2009, PBDEs were classified in Annex A of the Stockholm Convention for worldwide elimination because to their toxicity, persistence, and propensity for bioaccumulation. PBDEs are still present in new products (such as furniture and textiles) made from recycled materials, even though the EU has phased out their manufacture. According to current laws, PBDEs in mixtures or articles can have an Unintentional Trace Contaminant (UTC) of 500 mg/kg.

To improve environmental and human health protections, the European Commission updated the limitations for five polybrominated diphenyl ethers (PBDEs) under the EU Persistent Organic Pollutants Regulation (EU 2019/1021) on July 24, 2025. With a focus on toys, childcare products, and household items created from recycled materials, the new regulations suggest gradually lowering the residual limits for these compounds in products made from recycled materials.

Key Updates

The amendment drastically tightens Unintentional Trace Contaminant (UTC) for tetra-, penta-, hexa-, hepta-, and Deca-BDE (collectively PBDEs) in mixtures or articles:

· General products: PBDEs must not exceed 10 mg/kg (10 ppm) from the regulation’s effective date.

· Products containing recycled materials: ◦ Before December 30, 2025: Limit remains at 500 mg/kg; ◦ From December 30, 2025: Reduced to 350 mg/kg; ◦ From December 30, 2027: Further tightened to 200 mg/kg.

· Toys and childcare articles (with recycled content): ◦ Before December 30, 2025: Limit remains at 500 mg/kg; ◦ From December 30, 2025: Lowered to 350 mg/kg; ◦ 18 months post-enactment: Final limit of 10 mg/kg.

Due to the more stringent standards of the Food Contact Materials Regulation (EC No 1935/2004), food contact materials are exempt.

Next Steps

The European Parliament and Council will evaluate the amendment before it becomes operative 20 days after it is published in the EU Official Journal. After enactment, it will be immediately applicable in member states, putting supply chains for recovered plastics under additional compliance cost pressure.

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