Impact assessment

Request to inform substance Risk Management Evaluations (Annex F of the Stockholm Convention)

Updated 15 August 2023

The UK is a party to the Stockholm Convention on persistent organic pollutants (POPs), which are substances that persist in the environment, accumulate in living organisms and pose a risk to our health and the environment.

They can be transported by air, water or migratory species across international borders, reaching regions where they have never been produced or used.

Substances listed in the convention are generally prohibited from production, marketing or use unless specific exemptions apply or acceptable purposes have been agreed.

There is a process for parties to propose a substance for listing if they have gathered evidence that suggests it may be a POP. The POPs Review Committee (POPRC), the technical scientific committee of the Stockholm Convention, then considers and further develops the evidence that the substance demonstrates POP characteristics.

If there is evidence that it is a POP, they then consider the socio and economic impacts of a ban or restriction and make recommendations to the Stockholm Convention Conference of Parties, which is held every 2 years.

Risk Management Evaluations, as specified in Annex F (Information on Socioeconomic Considerations) of the Stockholm Convention

In September 2022, the POPRC agreed to the Risk Profiles (as specified in Annex E of the Stockholm Convention) for the following substances:

  1. long-chain perfluorocarboxylic acids (PFCAs), their salts and related compounds.
  2. chlorinated paraffins with carbon chain lengths in the range C14 to C17 and with chlorination levels at or exceeding 45 percent chlorine by weight (commonly referred to as medium chain chlorinated paraffins, or MCCPs, in Europe, North America, and Australia).

The POPRC is now developing the Risk Management Evaluations for these substances (as specified in Annex F of the Stockholm Convention), to provide information on the social and economic impacts of any control measures under consideration.

Information is therefore requested on production, use, emissions, monitoring, alternatives, impacts on society, efficiency and efficacy of proposed control measures, costs and waste disposal.

Long-chain perfluorocarboxylic acids (PFCAs), their salts and related compounds are members of the per- and polyfluoroalkyl substances (PFAS) chemical class. Long-chain PFCAs, with carbon chain lengths from 9 to 21, and their salts, are infrequently used in products.

However, there are reported limited uses including surfactant application and the production of fluoropolymers, and related compounds have been used in a range of applications, including in coating products, fabric and carpet protectors, textile impregnation agents and firefighting foams.

PFCAs with carbon chain lengths from 9 to 14, their salts and/or related compounds, may also be unintentionally produced during the manufacturing of PFAS, including those containing a carbon chain of less than nine carbon atoms, and in other industrial processes.

As a result, long-chain PFCAs may be present in certain products and articles as impurities.

Chlorinated paraffins with carbon chain lengths in the range C14 to C17 and chlorination levels at or exceeding 45 percent chlorine by weight

Chlorinated paraffins (CPs) are manufactured substances consisting of predominantly linear chloroalkanes, with different degrees of chlorination and chain length distributions depending on application and feedstock.

This proposal is for any CP product that has constituents with carbon chain lengths of 14 to 17 atoms (C14 to C17) and a chlorination level at or exceeding 45% chlorine by weight (Cl wt.).

These congeners are the principal constituents of substances called ‘medium-chain chlorinated paraffins’ (MCCPs) in Europe, North America and Australia, and major constituents of several products manufactured in Asia (for example, CP-52).

The UK have led the review process for chlorinated paraffins with carbon chain lengths in the range C14 to C17 and with chlorination levels at or exceeding 45 percent chlorine by weight (‘MCCPs’ hereafter) and have contracted an external contractor to gather relevant information and draft the Risk Management Evaluation document for MCCPs ahead of the next POPRC meeting.

As part of this work, the contractors are sending out a targeted questionnaire to certain UK industry stakeholders and you may have already been contacted about this or received a questionnaire.

If you have already been contacted about a separate questionnaire on the socio-economic impacts of MCCPs, then you do not have to duplicate your responses as part of this general call for information. However, you may submit answers to both if you wish.

If you wish to share relevant information on MCCPs but have not yet been contacted separately about our targeted MCCPs questionnaire, then provide your information by responding to this general call for information.

Alternatively, you can contact us at POPs@defra.gov.uk if you think you should have received a separate questionnaire on MCCPs.”