On July 24, 2026, the European Commission published a draft delegated regulation proposing amendments to (EU) No 649/2012 (the Regulation on the import and export of hazardous chemicals), updating Annex I (list of chemicals subject to prior informed consent) and Annex V (list of chemicals prohibited from export). CIRS provides the following interpretation based on the draft content.
Main Revisions
1. Annex I (List of Chemicals Subject to Prior Informed Consent/PIC Procedure)
- Addition of multiple chemicals: including pesticides (Flufenacet, Acibenzolar-S-methyl, MBIT, etc.) and industrial chemicals (boric acid, lead chromate, various phthalates, bisphenol A, cobalt compounds, N,N-dimethylformamide, etc.).
- Removal of Chlorpyrifos: as it will be included in the export ban under Annex V, separate control in Annex I is no longer required.
- Amendment of the "lead and its compounds" entry: lead chromate is listed separately, with strict restrictions clarified for its use by the general public and professionals as an industrial chemical.
2. Annex V (Export Ban List)
- Addition of a batch of persistent organic pollutants (POPs): Chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), long-chain perfluorocarboxylic acids (C9-21 PFCAs), etc. These substances have been brought under control by the Stockholm Convention.
- Update of existing entries: technical adjustments to exemption conditions and trace limit values for substances such as PFOS, PFOA, PFHxS, decabromodiphenyl ether, and hexabromocyclododecane, aligning with (EU) 2019/1021 (POPs Regulation).
ChemRadar Insights
The draft is currently in the public feedback stage, with a feedback deadline of August 21, 2026. The draft is expected to be adopted by the European Commission in Q3 2026, and will enter into force on the 20th day following its publication in the Official Journal of the European Union. It will apply from 2 months after entry into force or April 1, 2027, whichever is later. Once this regulatory revision is officially implemented, compliance pressure will increase significantly for enterprises in China and other countries exporting relevant chemicals and chemical-containing products to the EU. CIRS will continue to monitor developments in the relevant regulations and provide timely compliance information support to enterprises.
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