On June 30, 2026, the European Commission adopted a delegated regulation formally listing chlorpyrifos (CAS No.: 2921-88-2) in Part A of Annex I to the Persistent Organic Pollutants (POPs) Regulation ((EU) 2019/1021), and establishing a limit value of 0.01 mg/kg (0.000001% by weight) for its presence as an unintentional trace contaminant in substances, mixtures, and articles. CIRS provides the following interpretation based on the adopted regulation and its annex.
Background
Chlorpyrifos has long been closely monitored by the global environmental and health communities due to its persistence, bioaccumulation potential, and long-range environmental transport capabilities. This legislative action aims to implement the decision of the 12th meeting of the Conference of the Parties (COP12) to the Stockholm Convention, held from April 28 to May 9, 2025, in Geneva, Switzerland, where parties unanimously agreed to list chlorpyrifos in Annex A with specific exemptions. Additionally, a public consultation conducted through the feedback mechanism from November 21 to December 19, 2025, demonstrated widespread support for the inclusion of chlorpyrifos in Annex I.
Core Control Measures
- Listing in the Control List: Chlorpyrifos is newly added to Part A of Annex I to Regulation (EU) 2019/1021, which covers substances listed under the Convention and its protocols.
- No Specific Exemptions: Given that chlorpyrifos is not approved as an active substance in the EU under the Plant Protection Products Regulation ((EC) No 1107/2009) and the Biocidal Products Regulation ((EU) No 528/2012), this listing does not include specific exemptions.
- Trace Limit Value: To strengthen regulatory enforcement, the concentration limit for chlorpyrifos as an unintentional trace contaminant in substances, mixtures, or articles is clearly set at 0.01 mg/kg (i.e., 0.000001% by weight). Cases below this limit value are subject to the relevant provisions of Article 4(1)(b) of the Regulation.
ChemRadar Insights
This delegated regulation will enter into force on the 20th day following its publication in the Official Journal of the European Union and will be directly binding on all Member States. Any products exported to the EU (including chemical raw materials, plastic products, textiles, electrical and electronic equipment, packaging materials, etc.) that exceed the threshold value for chlorpyrifos will no longer be eligible for the exemption treatment for unintentional trace contaminants under Article 4(1)(b), and such products will face compliance risks / risks of being prohibited from being placed on the EU market. Since chlorpyrifos is no longer approved for use in plant protection products and biocidal products in the EU, this listing under the POPs Regulation does not include specific exemptions. This means that companies cannot apply for a "transition period" or "special use authorization" to continue using or selling products containing chlorpyrifos.
