On June 9, 2026, the European Commission published a draft delegated regulation to amend the chemical lists in Annexes I and V of Regulation (EU) No 649/2012 (Regulation on the import and export of hazardous chemicals). This revision adds dozens of industrial chemicals and pesticide active ingredients to the control list, involving multiple measures including export bans, Prior Informed Consent (PIC) procedures, and controls on severely hazardous pesticide formulations. The new regulations will officially apply on October 1, 2026. In response to this revision of the control list, CIRS Group provides the following analysis.
Background of the Revision
This revision is primarily based on the latest developments in international environmental conventions and updates to multiple chemical regulatory regulations within the EU. At the 12th Conference of the Parties to the Rotterdam Convention held in April–May 2025, carbosulfan and fenthion at specific concentrations were added to Annex III, triggering the EU's Prior Informed Consent (PIC) procedure. Meanwhile, the 11th meeting of the Stockholm Convention in 2023 decided to list Dechlorane Plus, methoxychlor, and UV-328 as Persistent Organic Pollutants (POPs), and these substances have also been simultaneously incorporated into the EU control system.
Key Revision Measures
1. Amendments to Annex I
Part 1 Amendments (Export Prohibition List, Part 1)
- New entries: More than 20 chemical substances, including UV absorbers, chromium compounds, phthalates, trichloroethylene, MOCA, Dechlorane Plus, various pesticides, etc.
- Updated existing entries: Carbendazim (expanded subcategories), carbosulfan (updated to reflect its move to Part 3)
Part 2 Amendments (PIC Procedure List, Part 2)
- New entries: UV absorbers, Dechlorane Plus, carbendazim, various pesticides (dodine, fenpyrazamine, etc.), PHMB, RP-HP, DOTE/MOTE reaction mixture, tritosulfuron, etc.
- Deleted entries: Carbosulfan (moved to Part 3)
Part 3 Amendments (Severely Hazardous Pesticide Formulations, Part 3)
- New entries:
- Carbosulfan (CAS: 55285-14-8, HS Code: 2932.99/3808.91)
- Fenthion (ultra-low volume formulations ≥640 g a.i./L, CAS: 55-38-9, HS Code: 2930.90/3808.91)
2. Amendments to Annex V (Export Prohibition List)
|
Substance |
Exemption Conditions |
|
UV-328 |
Not applicable to: ① Articles meeting the exemption conditions set out in point 2 of the UV-328 entry in Annex I to Regulation (EU) No 2019/1021; ② Concentrations equal to or below the limit values set out in point 1 of Annex I to that Regulation (for the purposes of Article 4(1)(b)) |
|
Dechlorane Plus |
Not applicable to: ① Articles meeting the exemption conditions set out in point 2 of the Dechlorane Plus entry in Annex I to Regulation (EU) No 2019/1021; ② Concentrations equal to or below the limit values set out in point 1 of Annex I to that Regulation |
|
Methoxychlor |
Not applicable to concentrations equal to or below the limit values set out in the methoxychlor entry in Annex I to Regulation (EU) No 2019/1021 |
ChemRadar Insights
The regulation will enter into force 20 days after its publication in the Official Journal and will officially apply on October 1, 2026. Enterprises in the pesticide, chemical import/export, and biocide industries need to verify their product lists as soon as possible, adjust their supply chains, and ensure compliance with the new control requirements. Substances listed in the PIC list must fulfill Prior Informed Consent procedures; substances listed in the export prohibition list must confirm the applicability of exemption conditions.
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