Consultation outcome

Summary of responses and government response

Updated 10 September 2026

Introduction

This document provides a summary of responses that the Department for Environment, Food and Rural Affairs (Defra) received to its consultation on potential amendments to the assimilated Persistent Organic Pollutants (POPs) Regulation, the government’s response and next steps. The consultation exercise ran for 8 weeks from 18 March to 13 May 2026.

There were 42 questions in the consultation document. Eight of these were background questions about the respondents, providing important contextual information. This summary is a high-level overview of the main messages from the consultation responses, reflecting the views offered. The summaries are presented in the same order as the consultation document and a government response to each section is provided at the end of the document.

Defra is grateful to everyone who took the time and effort to respond. The responses have been analysed by Defra staff dealing with the consultation proposals.

Purpose of the consultation

The main purpose of this consultation was to gather views on a number of government proposals and policy options to amend Annex I of the assimilated Persistent Organic Pollutants Regulation (the POPs Regulation) in upcoming or future legislation, including as set out in a draft Statutory Instrument (SI).

Most of the proposals relate to recent additions of new POPs to the list of prohibited substances under the Stockholm Convention which the UK, as Party to the Convention, must implement at a national level. Although Parties can opt out of such amendments, the UK has a long-standing policy of implementing agreed international commitments on chemicals, and we therefore consulted on how these new listings should be implemented in Great Britain (GB).

The consultation also provided an opportunity for respondents to share evidence regarding related amendments adopted or proposed by the EU, including their potential suitability for GB and any implications for the functioning of the UK internal markets, particularly where different requirements may apply in Northern Ireland under the Windsor Framework.

Overview

The Stockholm Convention is a global treaty which lists chemical substances known as Persistent Organic Pollutants (POPs). POPs have four main criteria: they are persistent, toxic, bio-accumulative, and have potential for environmental transport far away from sources of emissions, including across international borders. The Convention aims to protect human health and the environment by prohibiting, eliminating or restricting the global production and use of POPs.

As a Party to the Stockholm Convention, the UK has an obligation to implement amendments to the Convention through domestic legislation. In Great Britain, the assimilated POPs Regulation regulates the production, placing on the market, and use of POPs which are banned or restricted under the Convention.

There are time-limited exemptions or derogations available and listed in the Convention and the POPs Regulation. These allow the use of certain POPs in specific circumstances as users transition away to safer alternative substances.

The consultation included an accompanying draft SI which included our proposals to add the 5 newest POPs agreed to be listed for global prohibition under the Convention: medium-chain chlorinated paraffins (MCCPs), long-chain perfluorocarboxylic acids (LC-PFCAs), UV-328, dechlorane plus and chlorpyrifos. The consultation and draft SI also included a proposal to amend the existing perfluorooctane sulfonic acid (PFOS) entry in the POPs Regulation.

Beyond the proposals included in the SI, we also provided an opportunity for respondents to consider equivalent EU proposals, and to  present evidence on potential implications of making amendments that the EU has recently made with respect to a group of POPs called polybrominated diphenyl ethers (PBDEs). We also provided an opportunity to comment on the Stockholm Convention POPs Review Committee (POPRC)’s evaluation processes, evidence generation, and engagement regarding substances that are being considered as potential new future POPs.

Analysis methodology

A qualitative thematic analysis of the open-ended questions was undertaken, which identified key issues raised. Where feasible, a numerical estimate of those in support and against each proposal has been provided.

The consultation was published on the online digital platform Citizen Space which recorded responses through a questionnaire. Responses were also received via email. Email responses which directly responded to individual questions were entered into Citizen Space manually and were treated in the same way as other responses on that platform.

All responses received within the consultation deadline were counted and the views presented were included in the analysis. All responses were read individually except closed-ended responses (for example, yes or no responses) received through Citizen Space, which were analysed using automated methods.

Summary of respondents

A total of 25 consultation responses were received with 19 responses received through the Citizen Space portal, and 6 responses received by email. Some respondents who used Citizen Space also sent in additional comments by email and post. These additional comments were considered but not counted twice.

Some respondents did not answer all questions, therefore the responses to each question may not sum to 25.

All respondents were required to identify the basis on which they were responding for us to understand if their response represented the views of an individual, a single business in industry, a group representing multiple business entities, a public sector body, or another type of organisation.

It is important to note that respondents self-identified as belonging to these groups, and that no verification on this has been conducted. The following table shows the number of responses received for each respondent type.

Type of organisation responding	Number
Government body	0
Non-governmental organisation (NGO)	1
Local authority	1
Charity	0
Consultancy	0
Small or micro business (Less than 50 employees, including global operations)	0
Medium business (50 – 249 employees, including global operations)	0
Large business (250 or more employees, including global operations)	9
Industry association	11
Other	3
Not applicable, responded as an individual	0
Not answered	0
Total	25

The 3 organisations classed as ‘other’ were an NHS organisation, a professional membership association and an independent regulator.

Respondents were asked where their organisations are based and in operation. They were able to select more than 1 option for each. The following tables show how respondents answered these questions.

Where individual or organisation based	Number of responses
England	16
Wales	2
Scotland	6
Northern Ireland	2
Outside the UK (EU)	6
Outside the UK (non-EU)	4
Other	0
Not answered	0

Where organisations are in operation
England	19
Wales	14
Scotland	14
Northern Ireland	11
Outside the UK (EU)	10
Outside the UK (non-EU)	8
Other (please specify)	2
Not applicable, I am responding as an individual	0
Not answered	0

The 2 organisations that classed where they are in operation as ‘other’ did not specify where.

Closed text responses (that is where there was a limited range of answers to select from or multiple choice) were analysed by question. To process and summarise all the ideas submitted in the open-text responses, inductive (open) coding was used, whereby themes were developed as they arose directly from the responses. Open coding involved reading each response line-by-line and capturing the points covered.

This summary of responses is not an exhaustive list of all ideas provided by respondents but summarises the most common concerns and opinions.

A list of organisations that responded can be found listed in Annex A.

Summary of consultation responses by policy area

A total of 42 questions were asked in the consultation, relating to different substances and / or areas. This included a mixture of closed and open questions, and some closed questions provided the opportunity to supplement answers with evidence.

This section provides a summary of responses and comments received, broken down by policy area and by different substances.

There were some similar comments and general themes that were raised across more than one policy area. Some of these were general comments and not specific to a given policy area: those comments can be found in the ‘Any other comments’ section, as many were also raised in answer to questions in that section. Where recurring themes remained specific to a given policy area, these comments are still incorporated in the relevant section relating to that policy area.

On proposals to prohibit 5 new POPs

Where consultation questions related to proposals to prohibit new POP substances, several overarching factors were highlighted for respondents to consider when answering:

1. Whether there is an on-going need for the use of the substance.
2. Where the substance enters supply chains including stage of use and the country of origin or introduction.
3. What quantities of the substance are being used and how this has changed over time and is expected to change in the future.
4. How many companies currently use the substance and whether these are micro, small, or medium sized businesses.
5. Whether alternatives to the substance have been identified, and when these alternatives will be ready for implementation.
6. What the expected transition time is away from the use of the substance to alternatives.
7. What the costs of transition might be (including but not limited to: administrative and familiarisation costs, regulatory compliance, testing, reformulation, and price impacts of alternatives).
8. Potential environmental and human health impacts.
9. Potential implications for the functioning of the UK internal market.
10. What benefits or costs to GB businesses might arise if the EU POPs prohibitions referred to in this consultation were implemented in GB in the same way they have been proposed or implemented in the EU.

On proposals for medium-chain chlorinated paraffins (MCCPs)

We proposed to add MCCPs to Annex I of the assimilated POPs Regulation following this group of substances being agreed for global prohibition under Annex A of the Stockholm Convention. Alongside the prohibition we also proposed including the following, with details set out in the draft SI:

• All the time-limited specific-use exemptions for MCCPs available under the Convention, with the exemption expiry dates as agreed under the Convention, to allow critical sectors time to transition to safer alternative substances.
• Unintentional Trace Contaminant (UTC) limits, which define the maximum concentration at which MCCPs can be unintentionally but lawfully present in substances, mixtures, or articles. MCCPs are the only POP in this consultation for which the Convention specified an upper threshold and which we proposed as a UTC for substances and mixtures.

Respondents were asked to what extent they agree with the proposals to add MCCPs to Annex I of the assimilated POPs Regulation with specific use exemptions and UTC limits as set out in the draft SI. The following responses were received:

MCCPs – to what extent do you agree or disagree with our proposals?	Proposed prohibition as drafted in the SI	Proposed specific exemption approach	Proposed UTC limit approach
Agree or strongly agree	10	8	9
Disagree or strongly disagree	0	3	2
Neither agree nor disagree or don’t know or prefer not to say	6	4	5
Not answered	9	10	9

Respondents were also asked whether the EU’s proposed approaches to the definition of MCCPs and UTC limits would be suitable for implementing in GB. The following responses were received:

MCCPs – would the following be suitable for equivalent implementation in GB?	EU’s proposed definition approach	EU’s proposed UTC limits approach
Yes	9	5
No	5	7
Don’t know or prefer not to say	1	2
Not answered	10	11

Sixteen respondents answered the question about the prohibition of MCCPs in general. Of these, 10 agreed with the proposal, no respondents disagreed, and 6 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’. Some reasons for support included reducing the risk to the environment and human health, preventing long-term environmental damage, supporting long-term health outcomes, contributing to environmental sustainability and reducing future pressures on public services.

There were some requests to match the EU’s approach, or to be no stricter than the EU Regulation. Some respondents highlighted that matching the EU’s approach would create a simpler regime, reduce trade barriers (or else companies might just use the stricter of either regulation), and could reduce regulatory and compliance issues. Some highlighted wanting international consistency among Parties within the Stockholm Convention. In contrast, there were also requests to not match the EU’s proposals. Reasons given included that their proposed approach was believed to not be enforceable, and was not in line with the Stockholm Convention-agreed approach, or doesn’t provide sufficient transition time.

A response from an industry association focused on the prohibition and specifically on the importance of the UK as a supplier of MCCPs internationally, and strongly urged Defra to permit on-going manufacture of MCCPs in the UK and export of MCCPs.

Support for the proposed specific-use exemptions was varied among the 15 respondents, 8 of which agreed with the proposed exemptions, with 3 disagreeing and 4 who selected one of ‘neither agree nor disagree or don’t know or prefer not to say’. Some respondents replied with requests for exemptions beyond those agreed by and available from the Stockholm Convention, including from the sectors for medical technology, aerospace, defence, semiconductor manufacturing and engine manufacturing. These requests included varying levels of detail on potential uses of MCCPs that should be exempted, but none of these respondents provided detail regarding where the substance is used, at what concentrations or in what quantities, or any quantifiable costs of proceeding with the proposed amendments.

For the question about the proposed MCCPs UTC limits for GB, there were 16 respondents with 9 who agreed, 2 who disagreed and 5 who answered one of ‘neither agree nor disagree or don’t know or prefer not to say’. In addition, of the 14 respondents who answered the question about the suitability of the EU’s proposed UTC limits approach for GB, 5 answered that it would be suitable for GB, 7 said it would not be suitable for GB, and 2 answered one of ‘don’t know or prefer not to say’.

Some respondents highlighted being in support of lower UTC limits, including to match the EU’s proposed limits, to maximise environmental protection, but only if detectable and enforceable and if the functionality of the substances, mixtures or articles would remain acceptable. Some respondents were in support of alignment with the EU to simplify EU-GB and NI-GB divergence, to avoid administrative and compliance issues and costs within the EU and GB markets, and to encourage global consistency, but they warned that UTC limits should be seen as transitional and not over generous.

Reasons provided by respondents who showed support for our proposed UTC limits included comments that the proposals represent a balanced and pragmatic approach that protects the environment while also enabling resource recovery, particularly in the construction sector, and avoiding unnecessary classification of materials as hazardous waste. They also suggested that the proposed EU limits would not adequately reflect the technical realities of complex industrial supply chains and that the proposed UTC limits should be implemented in parallel with specific-use exemptions where elimination of MCCPs is not yet technically feasible, to represent a more pragmatic and proportionate approach.

In addition, a respondent replied to say that they were in strong agreement with the proposed UTC limits and that based on their analytical experience, MCCPs analysis can only be performed at a limited number of analytical laboratories and even within these facilities there are challenges with repeatability, accuracy and interpretation of results. They concluded that, from a practical and enforceability perspective, it would be appropriate to initially set the limits at the highest values that can be reliably measured and which are aligned with the Convention, but which could be progressively lowered over time, in line with developments in analytical methodologies, laboratory capability, and overall data quality.

Of the 15 who responded when asked about our proposed use of the Convention-agreed definition of MCCPs, 9 were in agreement, 5 were in disagreement and 1 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’. In addition, of the 15 respondents who answered about the potential suitability of the EU’s proposed MCCPs definition, 9 answered that it would be suitable for implementation in GB, 5 said it would not be suitable for implementation in GB, and 1 answered one of ‘don’t know or prefer not to say’.

Reasons given for why the EU’s proposed MCCPs definition would be suitable for GB included that using an aligned definition would support regulatory clarity, scientific consistency, and effective enforcement, and would help minimise any unnecessary divergence between GB or NI or EU regulatory regimes which is important for compliance, supply chain management, and for reducing potential compliance costs for manufacturers importers and downstream users operating across multiple jurisdictions. One respondent commented that the EU’s definition is scientifically robust, clearly scoped, and compatible with regulatory and market realities.

Reasons given for why the EU’s proposed definition would not be suitable for GB included that this would create an unnecessarily complicated approach to defining MCCPs while providing no regulatory benefit, and that regulation of chlorinated paraffins should be based on the commercial definition with a Carbon chain-length range (for example C14-C17) and the resulting chlorination by weight (for example 52% Cl by weight) as it can be easily controlled by manufacturers and verified by national authorities that regulate them. One respondent commented that they have found that congener group analysis can only be performed reliably by a limited number of highly specialised laboratories and even with these facilities, challenges remain in terms of repeatability, accuracy, and interpretation of results linked to analytical limitations such as limits of detection. For these technical reasons, the respondent did not agree with aligning with the EU on their proposed definition for MCCPs.

Overall, those who agreed that the EU’s definition of MCCPs would be suitable predominantly felt that alignment was beneficial and provided clarity to industry.

Another point raised was that an approach using CAS numbers for MCCPs rather than molecular structure definitions could help avoid discrepancies in interpretation.

On proposals for long-chain perfluorocarboxylic acids (LC-PFCAs)

We proposed to add LC-PFCAs to Annex I of the assimilated POPs Regulation following this group of substances being agreed for global prohibition under Annex A of the Stockholm Convention. Alongside the prohibition we also proposed the following, with details set out in the draft SI:

• All the time-limited specific-use exemptions for LC-PFCAs available under the Convention, with exemption expiry dates as agreed by the Convention, to allow critical sectors time to transition to safer alternative substances.
• Unintentional Trace Contaminant (UTC) limits, which define the maximum concentration at which LC-PFCAs can be unintentionally but lawfully present in substances, mixtures, or articles.

Respondents were asked to what extent they agree with the proposals to add LC-PFCAs to Annex I of the assimilated POPs Regulation with specific use exemptions and UTC limits as set out in the draft SI. The following responses were received:

LC-PFCAs– to what extent do you agree or disagree with our proposals?	Proposed prohibition as drafted in the SI	Proposed specific exemption approach
Agree or strongly agree	11	7
Disagree or strongly disagree	1	1
Neither agree nor disagree or don’t know or prefer not to say	5	9
Not answered	8	8

LC-PFCAs– to what extent do you agree or disagree with our proposals?	Proposed generic UTC limits	Proposed UTC limit for PTFE micro-powders	Proposed UTC limit for fluoropolymers
Agree or strongly agree	8	7	6
Disagree or strongly disagree	4	4	4
Neither agree nor disagree or don’t know or prefer not to say	6	5	6
Not answered	7	9	9

LC-PFCAs – would the following be suitable for equivalent implementation in GB?	EU’s proposed UTC limits approach
Yes	4
No	6
Don’t know or prefer not to say	5
Not answered	10

Of the 17 respondents who answered the question about prohibiting LC-PFCAs, 11 were in agreement, 1 disagreed, and 5 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’. Reasons for support of the prohibition included reducing risk to the environment and human health, so preventing long-term environmental damage and supporting long-term health outcomes. A respondent from the water sector commented that reduction of LC-PFCAs in sewage will reduce potential requirement for enhanced treatment, reducing the risk of potential increase in costs to customers, greenhouse gas emissions, and finite resource utilisation.

Two respondents asked for clarity on CAS numbers, requesting that all relevant CAS numbers be contained within the legislation and are updated as new numbers come into scope and that these numbers are globally applied (that is by the Convention and other parties to it).

On the specific use exemption approach, 17 respondents answered the question: 7 agreed, 1 disagreed and 9 answered one of ‘neither agree nor disagree or don’t know or prefer not to say’.

Some respondents replied with requests for specific use exemptions that are beyond those agreed by the Stockholm Convention, however the respondents didn’t provide any details regarding their requests, or any quantifiable costs of proceeding with the proposed amendments. Respondents also requested that Defra takes a pragmatic approach for potentially over-looked uses as there could be a possibility of missed uses where supply chain information is not fully visible.

Of those who responded on UTC limits, there was slightly more support than opposition for each of the UTC limits that we proposed, and slightly more opposition than support regarding suitability of the EU’s UTC limits approach.

On the proposed generic UTC limits for GB, 18 respondents answered, with 8 agreeing, 4 disagreeing, and 6 selecting one of ‘neither agree nor disagree or don’t know or prefer not to say’.

For the question asking how suitable all the EU’s proposed UTC limits would be for GB, 15 responded, with 4 in agreement, 6 disagreeing, and 5 one of ‘don’t know or prefer not to say’.

Comments on support included environmental and public health protection and therefore prevention of long-term environmental damage and chromic population exposure. Another respondent commented that the proposal strikes a reasonable balance between minimising unavoidable trace contamination from legacy presence or analytical constraints, while avoiding continued environmental loading that could undermine the intent of the prohibition.

Respondents who were in support of aligning with the EU’s generic limits provided reasons including some technical reasons relating to analysis of compounds, and that having different limits would create administration and compliance costs within the GB and EU markets.

Respondents who were against the proposals for technical reasons commented that a main issue is with difficulties of testing longer chain length LC-PFCAs, leading to difficulties proving compliance. Three of these respondents proposed a two-tiered UTC limit approach, with the limits split up between C9-14 LC-PFCAs and C15-21 LC-PFCAs due to difficulties they have encountered by trying to analyse the C15-21 fraction of compounds, and recommended the following proposed limits:

• An upper limit of 0.025 mg/kg (0.0000025 % by weight) for the sum of the concentrations of C9-14 PFCAs and any of their salts present in a substance, mixture or article.
• An upper limit of 15 mg/kg (0.0015 % by weight) for the sum of the concentrations of C15-21 PFCAs and any of their salts present in a substance, mixture or article.

On the proposed UTC limit for PTFE micro-powders, 16 respondents answered, 7 agreed, 4 disagreed and 5 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’.

The 3 respondents who proposed splitting the generic UTC limits between shorter and longer chain lengths for LC-PFCAs also proposed the same approach, again for technical reasons, for the UTC limits for PTFE micro-powders as follows:

• An upper limit of 1 mg/kg (0.0001 % by weight) for the sum of concentrations of C9 -14 LC-PFCAs and their salts where they are present in PTFE micro-powders as well as in mixtures and articles for industrial and professional uses containing PTFE micro-powders.
• An upper limit of 15 mg/kg (0.0015 % by weight) for the sum of concentrations of C15-C21 LC-PFCAs and their salts where they are present in PTFE micro-powders as well as in mixtures and articles for industrial and professional uses containing PTFE micro-powders.

Another respondent who disagreed with the proposed UTC limits commented that they do not believe that the process used for PFOA is appropriate for LC-PFCAs as they have different properties.

For the proposed UTC limit for fluoropolymers, 16 respondents answered, of which 6 agreed, 4 disagreed and 6 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’.

The 3 respondents who proposed splitting the UTC limits between shorter and longer chain lengths for LC-PFCAs also proposed the same approach, for technical reasons, for the UTC limits for fluoropolymers as follows:

• An upper limit of 0.1 mg/kg (0.00001 % by weight) for the sum of concentrations of C9 -14 LC-PFCAs and their salts where they are present in fluoroplastics and fluoroelastomers that contain perfluoroalkoxy groups, as well as in mixtures and articles containing fluoroplastics and fluoroelastomers that contain perfluoroalkoxy groups.
• An upper limit of 15 mg/kg (0.0015 % by weight) for the sum of concentrations of C15-21 LC-PFCAs and their salts where they are present in fluoroplastics and fluoroelastomers that contain perfluoroalkoxy groups, as well as in mixtures and articles containing fluoroplastics and fluoroelastomers that contain perfluoroalkoxy groups.

Another respondent who was against the proposal for the UTC limit for fluoropolymers was concerned that the UTC limit doesn’t apply to downstream products. They requested a uniform threshold of 100ppb (0.1 mg/kg) to apply to fluoropolymers with perfluoroalkoxy groups and their downstream products (both mixtures and articles).

On proposals for UV-328

We proposed adding UV-328 to Annex I of the assimilated POPs Regulation following this substance being agreed for global prohibition under Annex A of the Stockholm Convention. Alongside the prohibition we also proposed including the following, as set out in the draft SI:

• All the time-limited specific-use exemptions for UV-328 available under the Convention, with exemption expiry dates as agreed by the Convention, to allow critical sectors time to transition to safer alternative substances.
• Unintentional Trace Contaminant (UTC) limits, which define the maximum concentration at which UV-328 can be unintentionally but lawfully present in substances, mixtures, or articles.

Respondents were asked to what extent they agree with the proposals to add UV-328 to Annex I of the assimilated POPs Regulation with specific use exemptions and a UTC limit as set out in the draft SI. The following responses were received:

UV-328 – to what extent do you agree or disagree with our proposals?	Proposed prohibition as drafted in the SI	Proposed specific exemption approach	Proposed UTC limit approach
Agree or strongly agree	9	6	5
Disagree or strongly disagree	0	1	2
Neither agree nor disagree / don’t know prefer not to say	4	5	6
Not answered	12	13	12

UV-328 – would the following be suitable for equivalent implementation in GB?	EU’s UTC limits approach
(came into force in EU 04/08/2025)
Yes	7
No	0
Don’t know or prefer not to say	6
Not answered	12

Of the 13 respondents who answered the question about the prohibition of UV-328, 9 agreed, 0 disagreed, and 4 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’.

Reasons given for support for the prohibition included meeting international obligations under the Stockholm Convention, supporting the objective of preventing further irreversible chemical pollution, reducing environmental loading of this hazardous substance, contributing to sustained improvements in environmental quality, and maintaining GB’s credibility and consistency within chemicals regulation.

Some respondents raised concerns with the proposed implementation in terms of alignment or divergence with the EU. Reasons given for wanting to see EU alignment included that it would significantly reduce compliance costs and disruption for businesses operating within integrated EU – UK supply chains, and that it would ensure regulatory consistency and minimise potential complexity for operators active across multiple markets.

For the question about the proposed specific exemptions approach, 12 respondents answered this question, with 6 in agreement, 1 who disagreed, and 5 responding with one of ‘Neither agree nor disagree or don’t know prefer not to say’. Two respondents stated that they felt they required the inclusion of specific exemptions which are not available under the Stockholm Convention, though detailed information on these applications was not provided.

Of the 13 respondents who answered the question about the proposed UTC limit, 5 agreed, 2 disagreed and 6 selected one of ‘Neither agree nor disagree or don’t know prefer not to say’. There were also 13 respondents who answered the question asking about the suitability of the EU’s UTC limit for UV-328 in GB, which is already in force in the EU and NI. 7 respondents said it would be suitable for GB, 0 said it wouldn’t, and 6 answered one of ‘don’t know or prefer not to say’.

Some respondents were concerned that the GB proposal for the UTC limit would be temporarily stricter than the EU’s proposed UTC limits. Others asked for alignment with the proposed EU UTC limits with reasons given that divergence could contribute to compliance and supply chain complexity for manufacturers, increase complexity in testing, compliance declarations, material traceability and recycling schemes, potentially leading to additional compliance costs and commercial implications. In addition, comments received in support of EU alignment stated that alignment would allow manufacturers sufficient time for reformulation, testing, validation and certification.

On proposals for dechlorane plus

We proposed adding dechlorane plus to Annex I of the assimilated POPs Regulation following this substance being agreed for global prohibition under Annex A of the Stockholm Convention. Alongside the prohibition we also proposed the following, with details set out in the draft SI:

• All the time-limited specific-use exemptions for dechlorane plus available under the Convention, with exemption expiry dates as agreed by the Convention, to allow critical sectors time to transition to safer alternative substances.
• Unintentional Trace Contaminant (UTC) limits, which define the maximum concentration at which dechlorane plus can be unintentionally but lawfully present in substances, mixtures, or articles.

Respondents were asked to what extent they agree with the proposals to add dechlorane plus to Annex I of the assimilated POPs Regulation with specific use exemptions and a UTC limit as set out in the draft SI. The following responses were received:

Dechlorane plus – to what extent do you agree or disagree with our proposals?	Proposed prohibition as drafted in the SI	Proposed specific exemption approach	Proposed UTC limit approach
Agree or strongly agree	9	8	5
Disagree or strongly disagree	0	0	3
Neither agree nor disagree or don’t know or prefer not to say	4	4	5
Not answered	12	13	12

Dechlorane plus – would the following be suitable for equivalent implementation in GB?	EU’s UTC limits approach
(came into force in EU 15/10/2025)
Yes	7
No	0
Don’t know or prefer not to say	6
Not answered	12

Of the 13 respondents who answered the question about the proposed prohibition, 9 agreed with the proposal, 0 disagreed and 4 selected one of ‘Neither agree nor disagree or don’t know or prefer not to say’.

Reasons given for agreement with the prohibition included meeting international obligations under the Stockholm Convention, preventing further releases of DP to the environment to reduce legacy contamination and on-going exposure.

For the question about specific exemptions, there were 12 respondents, of which 9 agreed with the proposal, 0 disagreed and 4 responded one of ‘Neither agree nor disagree or don’t know or prefer not to say’.

One respondent commented that we should include the words ‘and accessories’ for the replacement parts exemption for medical devices as the EU has and also commented that we need an exemption for ‘articles already in use’ like the EU has.

Respondents from the aerospace, space and defence sector reported that dechlorane plus still plays a crucial role in ensuring safety, reliability and performance of aerospace and defence technologies and that it is still widely used in aerospace and defence applications. They indicated that the proposed exemptions for their sector have an expiry date of February 2030 which they feel is too short a time-frame and would not provide enough time for businesses to identify, replace and re-qualify products and components. They estimated that a viable time-frame is likely to be up to 20 years.

Of the 13 respondents who answered the question about the proposed UTC limit, 5 agreed with the proposal, 3 disagreed and 5 selected one of ‘Neither agree nor disagree or don’t know or prefer not to say’. There were also 13 respondents who answered the question asking about the suitability of the EU’s UTC limit for dechlorane plus in GB, which is already in force in the EU. 7 respondents thought it would be suitable, 0 thought it wouldn’t, and 6 answered one of ‘don’t know or prefer not to say’.

Some respondents were concerned that the GB proposed UTC limit would be temporarily stricter than the EU’s proposal and other respondents asked for alignment with the proposed EU UTC limits as they commented that divergence could contribute to disproportionate compliance burdens and supply chain complexity for manufacturers before the EU reduce their limit. Two respondents commented that the EU’s staged approach to their UTC limits would provide greater regulatory coherence and predictability. Another respondent commented that alignment of limits with the EU approach will aid movement of goods and items at the NI border.

On proposals for chlorpyrifos

We proposed to add chlorpyrifos to Annex I of the assimilated POPs Regulation following this substance being agreed for global prohibition under Annex A of the Stockholm Convention.

Alongside the prohibition we also proposed the following, with details set out in the draft SI:

• Unintentional Trace Contaminant (UTC) limits, which define the maximum concentration at which chlorpyrifos can be unintentionally but lawfully present in substances, mixtures, or articles.
• The proposal does not include any of the specific exemptions available for chlorpyrifos under the Stockholm Convention as evidence indicates that this substance is no longer used in the UK. The full list of the specific exemptions available under the Convention can be found within the Convention text itself.

Respondents were asked to what extent they agree with the proposals to add chlorpyrifos to Annex I of the assimilated POPs Regulation without any specific use exemptions and with a UTC limit as set out in the draft SI. The following responses were received:

Chlorpyrifos – to what extent do you agree or disagree with our proposals?	Proposed prohibition as drafted in the SI	Proposed specific exemption approach	Proposed UTC limit approach
Agree or strongly agree	3	3	4
Disagree or strongly disagree	0	0	0
Neither agree nor disagree or don’t know or prefer not to say	5	4	3
Not answered	17	18	18

Of the 8 respondents who answered the question about the prohibition of chlorpyrifos, 3 were in agreement and 5 answered one of ‘Neither agree nor disagree or don’t know or prefer not to say’.

For the proposal to not include any of the available exemptions available under the Convention, 3 respondents agreed with the proposal, 0 disagreed, and 4 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’.

Those in support referenced the environmental benefits of a prohibition under the POPs Regulation and acknowledged that, as evidence suggests the substance is no longer used in the UK, exemptions were not appropriate or necessary.   

For the proposed UTC limit, there were 7 respondents, with 4 in agreement, 0 in disagreement and 3 who selected one of ‘neither agree nor disagree / don’t know / prefer not to say’. Respondents commented that the proposed UTC limit would be suitably low and appropriate for the substance.

On proposals to amend current entry for an existing POP (PFOS)

We proposed to amend the perfluorooctane sulphonate (PFOS) Annex I entry of the assimilated POPs Regulation by:

• reducing the Unintentional Trace Contaminant (UTC) limits for PFOS, its salts and related compounds, which define the maximum concentration at which these substances can be unintentionally but lawfully present in substances, mixtures, or articles, and to align with the EU’s limits which came into force in July 2025, and
• deleting the reference to standards for analytical methods being adopted by the European Committee for Standardisation (CEN).

Respondents were asked to what extent they agree with the proposals to amend the PFOS Annex I entry of the assimilated POPs Regulation as set out in the draft SI. The following responses were received:

PFOS UTC limits – to what extent do you agree or disagree with our proposals?	Proposed UTC limit reduction for PFOS	Removal of point 5 about reference to CEN standards and analytical test methods
Agree or strongly agree	7	5
Disagree or strongly disagree	0	1
Neither agree nor disagree or don’t know or prefer not to say	5	6
Not answered	13	13

Of the 12 respondents who answered the question about the proposed UTC limit reduction, 7 agreed with the proposal, no respondents disagreed and 5 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’. Reasons given for support included the reduction of PFOS entering waterways, the general strengthening of environmental protection, and alignment with the EU to help ensure regulatory consistency and reduce potential complexity for operators active across multiple markets.

Of the 12 respondents who answered the question about the proposed removal of the reference to standards for analytical methods being adopted by the European Committee for Standardisation (CEN), 5 agreed, 1 disagreed, and 6 selected one of ‘neither agree nor disagree or don’t know or prefer not to say’.

On potential implications of recent EU Amendments to UTC limits for existing POPs (polybrominated diphenyl ethers (PBDEs))

In November 2025 the EU amended their UTC limits for several existing POPs called polybrominated diphenyl ethers (PBDEs), where PBDEs refers collectively to the substances tetrabromodiphenyl ether (tetraBDE), pentabromodiphenyl ether (pentaBDE), hexabromodiphenyl ether (hexaBDE), heptabromodiphenyl ether (heptaBDE) and decabromodiphenyl ether (decaBDE). These amendments were adopted by the EU in July 2025 and they apply to Northern Ireland under the Windsor Framework.

In this consultation, respondents were asked to provide any evidence or information to help identify the potential suitability of the EU’s amended PBDE UTC limits for the equivalent implementation in GB, either in the shorter or longer term. We requested information to help identify potential implications of on-going differing UTC limits between GB and NI for these substances, particularly regarding supply chains, waste management and internal market implications.

In total, 8 respondents provided a view. Of these, 7 agreed that that the UTC limit approach already in force in the EU and NI would be suitable for equivalent implementation in GB; 1 was unsure.

Respondents did not provide many views on the impact of implementing these PBDEs UTC limits specifically, but those who agreed it would be possible for implementing in GB were generally in favour of greater regulatory alignment with the EU. In particular, they felt this would provide certainty and simplicity to businesses and reduces the need administrative burden on industry.  

One respondent asked that any changes to the UTC limits were supported by guidance for operators and regulators; a phased introduction where appropriate and an ongoing review of analytical capability and real-world impact on recycling and supply chains.

On views on information generation and engagement on substances nominated as potential new POPs

During the current intersessional period, the Stockholm Convention’s POPs Review Committee (POPRC) has been considering how its evaluation, engagement and information gathering processes could be improved.

We asked respondents to highlight potential ideas to improve both the Stockholm Convention and UK government’s future evaluation and engagement processes regarding substances that have been nominated as POPs under the Convention. In particular, we wanted to understand – among other things – how to ensure earlier and more effective engagement with relevant stakeholders, gather up-to-date information on uses, supply chains and potential impacts of global prohibition, and better identify socio-economic considerations that may inform global decision making.

The responses to the consultation questions were intended to help inform the UK government’s position in advance of further Convention-level discussions.

In their responses, 3 respondents highlighted concerns with limited availability of data on complex global supply chains, which they say makes it challenging for industry to engage with the POPs listings process in good time.

Respondents highlighted the importance of early engagement with industry, including healthcare technologies, aerospace and waste sectors. It was suggested that early engagement, both at Convention level and in the UK, could help reduce data gaps in the POPs listing process.

One respondent suggested that in order to improve the Stockholm Convention’s future evaluation and engagement processes, the use of group-based substance approaches to listings should continue to be strengthened, where there are clear structural similarities and shared hazardous properties between substances, to help address the issues of regrettable substitution when regulated substances are replaced with closely related substances that may exhibit similar properties, and also to work towards a circular economy approach.

On equality impacts

We asked respondents to provide any information or evidence about whether the proposals in the consultation were likely to have impacts (positive or negative) on people with protected characteristics under the Equality Act 2010.

We only received 2 responses to this question, one of which said they could not identify any specific impacts on people with protected characteristics. The second respondent highlighted that new POPs prohibitions could eventually put more pressure on waste handlers owing to the destruction requirements on waste containing POPs.

Waste limits and waste disposal were not in scope of this consultation, and therefore we have passed on the responses about waste considerations onto other relevant teams.

On administrative burdens

We asked respondents to provide information on any anticipated administrative burdens associated with complying with these proposed amendments to the assimilated POPs Regulation, and how these costs might be minimised.  

6 respondents responded to the questions regarding administrative burdens.

One respondent emphasised that the broad scope of the POPs regulation results in administrative costs and time, particularly linked to supply chain adjustments, regulatory approval processes, identifying suitable expertise, and developing alternatives. Some respondents, in comparison noted that the proposed amendments may introduce short-term administrative burdens for businesses, but considered these largely manageable and transitional, particularly where there is alignment with the Stockholm Convention.

Respondents highlighted a number of measures that could reduce administrative burdens, including the provision of clear and timely sector specific guidance, FAQs, and clarification on how requirements apply to recycled materials and mixtures. Respondents also suggested the support of government to create standardised templates for supply chain declarations, as well as consistent formats for record keeping and compliance evidence, to reduce interpretation time and reliance on external consultancies. One respondent highlighted challenges associated with collecting data across complex global supply chains, noting that this process is time-consuming and would benefit from further coordination between government, OEMs and supply chain actors.

Some respondents emphasised that improved information on material composition would support better waste management and circularity outcomes, although this may increase costs for manufacturers. One respondent highlighted that there should be a single, shared ecotoxicology database to avoid duplication, with the NORMAN Network identified as the most suitable option.

Comments received from a respondent representing local authorities and the waste sector are out of scope of this consultation and have been passed on to the relevant waste teams.

Other comments received

Defra asked consultation respondents to highlight any other potential amendments we should be considering to existing POPs entries in Annex I of the assimilated POPs Regulation, and that these could include amendments to the specific exemptions currently available under the Convention, and / or UTC limit values. Respondents were asked to provide justification and any relevant supporting evidence or information, including on technical feasibility, socio‑economic or financial impacts of issues raised, on any implications for supply chains, recycling or waste management, and for any potential trade or market impacts.

Nine responses were received in this section. Generally, there was strong support for the proposed prohibitions, tightening of measures and for alignment with the EU, also to avoid being stricter than the EU during transitional periods as comments stated that adequate transition periods are essential to allow manufacturers to complete testing, validation and logistics without disrupting supply chains.

Comments received stated the importance of amendments prioritising international alignment, analytical feasibility, and practical implementation while avoiding unintended impacts on supply chains and product availability. This was emphasised for the importance of UTC limits being analytically achievable and consistent with EU approaches as differences between jurisdictions would introduce additional testing requirements and compliance burdens.

Two respondents asked for specific exemptions in Annex I of the POPs Regulation to be kept under review, though for conflicting reasons: one wanted this to ensure industry could keep exemptions it needed, including beyond proposed timelines, and the other respondent suggested this was a way to avoid providing exemptions that aren’t strictly needed, including removing exemptions earlier than proposed timelines. There was a suggestion for a review mechanism for all exemptions of no later than 18 months prior to their expiry dates, to be coordinated by Defra and to include stakeholders with various factors to enable deadlines of exemptions to be extended.

A request was received for the PFOA exemption no.7 for per-fluorooctyl bromide or per-fluorooctyl iodide to be extended to the Convention deadline of 31 December 2036 as this exemption is still required for pharmaceuticals R&D, or alternatively to set a UTC limit instead, with suggested 200ppm and then 2 years later to be reduced to 10ppm. Comments received included that work is on-going to evaluate alternatives to PFOB to produce microporous particles but the timeline for implementation of alternatives is not yet known.

There were comments also received about POPs in waste, which included being supportive of the prohibitions to avoid further generation of POPs waste and less POPs in waste water in future, concerns over POPs waste management in general due to a current lack of disposal sites and high temperature incinerators and therefore concerns that POPs in waste could remain hanging around for many years, and also a suggestion for more engagement with waste disposal sites and companies to highlight and address any concerns, and to include regulators, local authorities and the private sector. As waste is generally out of scope of this consultation, waste-related comments have been passed on to the relevant waste teams.

Government response

The consultation received 25 responses, and respondent types were self-categorised as heavily weighted towards large businesses and industry associations. Not all questions were answered by all respondents. Many of the responses provided qualitative comments, but there were minimal examples of quantitative evidence being shared, such as regarding concentrations of these substances found in relevant products, or costed potential impacts of different prohibition options.

In the consultation, we noted that any upcoming or future legislative changes that we implement into the assimilated POPs Regulation will depend on multiple factors, including:

• Available evidence from a range of sources, including responses to the consultation but also other evidence acquired through additional research and engagement routes.
• The need to protect human health and the environment.
• The potential impacts on businesses, the voluntary sector and the public sector.
• Global context, including international conventions, guidelines, and decisions, such as those of the Stockholm Convention, as well as regulatory decisions made in other trusted jurisdictions.
• Scientific and technical progress.
• Other UK and Defra priorities and commitments, such as those set out in the Environment Improvement Plan (EIP) 2025.

In December 2025, Defra published a revised Environmental Improvement Plan (EIP), outlining a strategic framework for improving England’s natural environment up to 2043 and including new interim targets for existing statutory Environment Act 2021 targets. In addressing Goal 4 to minimise environmental risks from chemicals, the EIP includes commitments and related actions that link to the proposed POPs prohibitions detailed in the draft SI.

Defra committed to ‘implement targets and obligations agreed through multilateral environmental agreements and other forums’, with linked actions including ‘implementing updates to the Stockholm Convention on POPs through legislation in accordance with the deadlines set by the convention in 2025’.  

The Stockholm Convention implementation deadline for MCCPs, LC-PFCAs, and chlorpyrifos has been set as 16 December 2026, and the proposed legislation is intended to implement these updates in GB by that date.

We have tried in this government response to provide clarity regarding how our intended proposals compare with what is already in force in EU and NI, or what is anticipated to be introduced in the EU and NI in parallel. We hope these clarifications help to address general comments regarding potential regulatory complexity between GB and EU/NI.

Overview – adding 5 new POPs 

MCCPs

From those who responded, there was general support for our proposals regarding MCCPs. No respondents opposed our proposal to prohibit MCCPs, and the majority of those who responded supported our proposed approaches for specific use exemptions and UTC limit values. Of those who answered the relevant questions regarding EU equivalent proposals, over half of the respondents answered that the definition of MCCPs that the EU proposed would be suitable for implementation in GB, whereas the majority answered that the EU’s proposed UTC limit values would not be suitable for implementation in GB.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to continue with the proposed prohibition of MCCPs by adding this substance to Annex I of the POPs Regulation with all available exemptions as agreed by the Convention.

Although some responses included requests to introduce new exemptions for the continued use of MCCPs, or to broaden those proposed, Defra does not intend to include  any exemptions that have not been agreed at Convention level. We intend to introduce all of the available specific use exemptions and expiry dates as agreed by the Convention, and as proposed in the consultation. We have engaged with other government departments relevant to these sectors, and they are content with this approach.

We intend to slightly amend the substance definition from that proposed in our draft SI, which will move closer towards the definition in the EU’s latest proposal. While we recognise that some respondents opposed this definition, we believe this approach will retain the full coverage of MCCPs that are listed for global elimination under the Stockholm Convention, and will be  operable.  It is also likely to limit regulatory complexity between GB and EU or NI.

We acknowledge some respondents’ reservations regarding the EU’s proposed general UTC limit of 0.1% for substances, mixtures, and articles.

We intend to continue with the UTC limits proposed by Defra in the consultation, (3% for substances or mixtures, and 0.45% for articles), which aligns with the Convention-agreed threshold. The Convention-agreed threshold for MCCPs is subject to Convention-level review scheduled in 2029, and every 4 years thereafter: as such, the intended UTC limits for MCCPs may subsequently be amended in future, including in response to Convention-level reviews.

We also intend to introduce an additional temporary UTC limit to cover articles produced using recycled material, with the current intention being to apply a limit to these articles at 2% for a transitional period of 2 years – this is likely to align with an equivalent UTC that the EU is anticipated to introduce in parallel ahead of the Convention deadline - and then after which the 0.45% level for articles will apply.

LC-PFCAs

Of those who responded, there was general support for our proposals regarding LC-PFCAs. The majority of those who responded supported our proposal to prohibit this substance through addition to Annex I of the POPs Regulation. Similarly, there was good support for our proposed approach to include all specific use exemptions and expiry dates available under and agreed by the Convention.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to continue with the proposed prohibition of LC-PFCAs by adding this substance to Annex I of the POPs Regulation with all available exemptions as agreed by the Convention.

Although some responses included requests to introduce new exemptions for the continued use of LC-PFCAs, or to broaden those proposed, Defra does not intend to include any exemptions that have not been agreed at Convention level. We intend to introduce all of the available specific use exemptions and expiry dates as agreed by the Convention, and as proposed in the consultation. We have engaged with other government departments relevant to these sectors, and they are content with this approach.

Of those who commented on the proposed UTC limit values, there was greater support than opposition for the proposals, including the specific UTC limits for LC-PFCAs in PTFE micro-powders and fluoropolymers. However, respondents also provided information regarding the  challenges of measuring and treating LC-PFCAs at longer chain lengths (C15-C21). This was highlighted for both our original proposals and the EU’s equivalent proposals.

Having considered all responses and other factors, Defra intends to proceed with broadly the same UTC limits that were initially proposed, but with some refinements as follows:

• For LC-PFCA-related compounds in substances, mixtures and articles, we originally proposed a value of 1mg/kg, but now intend to move forward with a value of 0.26mg/kg. This should align with anticipated equivalents that the EU are seeking to introduce in parallel ahead of the Convention deadline.
• We also intend to introduce additional temporary transitional UTC limits to provide more time for industry to develop testing approaches for longer chain-length LC-PFCAs present in PTFE micro-powders and fluoropolymers, with the current intention being a transitional higher limit of 15ppm for 4 years for LC-PFCAs with carbon chain lengths of C15-C21.
• Where the EU has proposed to introduce an additional UTC limit that we did not originally propose in our draft SI, we now intend to include this: namely, a UTC limit equal to or below 10 mg/kg (0.001% by weight) for the sum of concentrations of C9-21 PFCAs, their salts and related compounds in substances to be used as transported isolated intermediates.

UV-328

From those who responded, there was general support for our proposals regarding UV-328. No respondents opposed our proposal to prohibit UV-328, and the majority of those who responded either supported our proposed approach to include all specific use exemptions and expiry dates available under the Convention, or neither supported nor opposed our proposals. There was also more support than opposition for our proposed UTC limit, but the majority of those who responded also suggested that the UTC limit approach already in force in the EU and NI would be suitable for equivalent implementation in GB.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to continue with the proposed prohibition of UV-328 by adding this substance to Annex I of the POPs Regulation with all available exemptions as agreed by the Convention.

Although some responses included requests to introduce new exemptions for the continued use of UV-328, or to broaden those proposed, Defra does not intend to include any exemptions that have not been agreed at Convention level. We intend to introduce all of the available specific use exemptions and expiry dates as agreed by the Convention, and as proposed in the consultation. We have engaged with other government departments relevant to these sectors, and they are content with this approach.

However, Defra intends to refine our proposed UTC limit to include an initial transitional period at a higher value, before then moving to lower values. This will better align with equivalent values that are already in force in the EU and NI, namely, for presence in substances, mixtures or articles: starting at (a) 100 mg/kg (0.01 % by weight) until 3 August 2027; then falling to (b) 10 mg/kg (0.001 % by weight) from 4 August 2027; and then (c) 1 mg/kg (0.0001 % by weight) from 4 August 2029.

Dechlorane Plus

From those who responded, there was general support for our proposals regarding dechlorane plus. No respondents opposed our proposals to prohibit dechlorane plus, and no respondents opposed our proposed approach to include all specific use exemptions and expiry dates available under the Convention. There was more support than opposition for our proposed UTC limit, but the majority of those who responded also suggested that the UTC limit approach already in force in the EU and NI would be suitable for equivalent implementation in GB.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to continue with the proposed prohibition of dechlorane plus by adding this substance to Annex I of the POPs Regulation with all available exemptions as agreed by the Convention.’

Although consultation responses included requests to broaden two of the proposed exemptions, Defra does not intend to include any details of exemptions that have not been agreed at Convention level. We intend to introduce all of the available specific use exemptions and expiry dates as agreed by the Convention, and as proposed in the consultation. We have engaged with other government departments relevant to these sectors, and they are content with this approach.

However, Defra intends to refine our proposed UTC limit to now include an initial transitional period at a higher value, before then moving to a lower final value. This will better align with equivalent values that are already in force in the EU and NI, namely, for presence in substances, mixtures or articles: starting at (a) equal to or below 1,000 mg/kg (0.1 % by weight) until 15 April 2028; and then falling to (b) equal to or below 1 mg/kg (0.0001 % by weight) after 15 April 2028.

Chlorpyrifos

From those who responded, there was general support for our proposals regarding chlorpyrifos. No respondents opposed our proposals to prohibit chlorpyrifos, and no respondents opposed our proposals to include none of the specific use exemptions available under the Convention. Likewise, no respondents opposed our proposed UTC limit. This matches with our understanding that this substance is no longer used in the UK.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to continue with the proposed prohibition of chlorpyrifos and UTC limit in Annex I of the POPs Regulation as proposed in the draft SI accompanying this consultation.

PFOS

Of those who responded, the majority supported our proposal to reduce the UTC limit for PFOS: no respondents opposed it. The majority of those who responded either supported our proposal to remove the reference to standards for analytical methods, or neither agreed nor disagreed with the proposal.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to to implement the amendments to the PFOS UTC limits and reference to standards for analytical methods, as proposed in the draft SI. This will align with equivalent amendments that are already in force in the EU and NI.

PBDEs

The majority of those who responded suggested that the UTC limit approach already in force in the EU and NI would be suitable for equivalent implementation in GB: no respondents said that it would not be suitable. However, this support was predominantly based on the general benefits of alignment, rather than specific to this substance or circumstance.

Having considered all of the responses, alongside other relevant factors as highlighted at the top of the ‘Government response’ section, we intend to refine our existing PBDE UTC limits to better align with equivalent amendments that are already in force in the EU and NI, namely:

(a) a reduction from 500 mg/kg to 10 mg/kg for the presence of PBDEs in mixtures and articles in general,  

(b) (i) a reduction from 500mg/kg to 350mg/kg until 29 December 2027 and 200mg/kg from 30 December 2027 for presence of PBDEs in mixtures or articles containing or made of recovered materials containing PBDEs,  

(ii) a reduction from 500mg/kg to 350mg/kg until 16 May 2027 and 10 mg/kg from 17 May 2027 for toys and other children’s products containing or made of recovered materials containing PBDEs.

We do not intend for these UTC limits to apply to food contact materials: accordingly, there will be no lawful presence of these substances in food contact materials. 

Information generation and engagement on substances nominated as potential new POPs

We are grateful to all respondents who answered these questions and we will continue to consider how they will help inform the UK government’s position in advance of further Convention-level discussions regarding processes for generating information and engaging stakeholders on nominated substances that are being evaluated as potential POPs.

The 5 new POPs included in this consultation have all previously been through the POPRC evaluation process and subsequent Convention decision-making. These processes involved multiple opportunities for stakeholder engagement, both UKG-led and Convention-led, over multiple years and at different evaluation stages. Further information on the POPRC evaluation process is available on the Stockholm Convention website.

Beyond these POPs, 3 more recently nominated substances or groups of substances, are currently undergoing the Convention-level evaluation process which could lead to eventual adoption as new POPs for global elimination or restriction. These substances are:

• polybrominated dibenzo-p-dioxins and dibenzofurans and mixed polybrominated/chlorinated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs and PBCDD/Fs) – primarily byproducts from thermal processes, including combustion of material containing brominated flame retardants. Nominated in 2024.
• Bis(2-ethylhexyl) tetrabromophthalate (TBPH), covering any of its individual isomers and/or combinations thereof – primarily a brominated flame retardant. Nominated in 2026.
• Decabromodiphenylethane (DBDPE) and its related substance, 1,1’-ethane-1,2-diylbisbenzene, brominated EBP – primarily a brominated flame retardant. Nominated in 2026.

These substances will be discussed by the POPRC in September 2026, some for the first time. Depending on the outcomes of those discussions, calls for information about these substances may be launched on the Stockholm website in Autumn 2026, and on GOV.UK shortly after.

If you would like to find out more about calls for information relating to these substances, visit the Stockholm website, or sign up to receive email alerts when we publish new consultations or calls for comments.

Equality impacts

Defra is grateful for the responses and will continue to consider this information as part of the ongoing legislative process and assessment of potential impacts relating to this legislation. One respondent highlighted points out of scope of the consultation, including about impacts relating to waste controls: we have passed these comments on to the relevant team, where appropriate.

Administrative burdens

Defra is grateful for the responses and will continue to consider this information as part of the ongoing legislative process and assessment of potential impacts relating to this legislation. Two respondents highlighted points out of scope of the consultation, including about impacts relating to waste controls: we have passed these comments on to the relevant team, where appropriate.

Other comments received

Some sectors requested the inclusion of a review mechanism for all exemptions of no less than 18 months prior to expiration, to be led by Defra and including relevant stakeholders, and including assessments of relevant technology advancement, availability of chemical replacements, market viability, safety and mission critical factors, and economic considerations. Reasons given were to ensure industry could keep exemptions if needed, including beyond proposed timelines, and as a way of avoiding providing exemptions that aren’t strictly needed, including removing exemptions earlier than proposed timelines. Defra do not intend to introduce such a review mechanism.

We also received comments in relation to POPs in waste and in other parts of the consultation too. Where these comments were out of scope of this consultation, they have been forwarded to the relevant team.

We also received a request in the additional comments section with regards to a specific use exemption for PFOA – point 7 in its Annex I entry. The request was for the expiry date for this exemption to be extended from the end of 2026, as is currently stated in the POPs Regulation, to 31 December 2036. Having considered this response, and other factors, Defra do not intend to extend this existing exemption expiry date.

Conclusions and next steps

In the consultation, we highlighted that any upcoming or future legislative changes that we implement into the assimilated POPs Regulation will depend on multiple factors and that no single factor in isolation is likely to determine the final legislative changes that we implement into the assimilated POPs Regulation.

Having considered the responses to this consultation, and other factors, Defra still intends to make a Statutory Instrument (SI) to implement these amendments to Annex I of the assimilated POPs Regulation.

We intend for these amendments to be largely the same as the draft proposals contained within the consultation, but with some refinements, as set out in the government response above, and summarised here:

• Additional UTC limits included for MCCPs and LC-PFCAs.
• One slightly adjusted UTC limit for LC-PFCA-related compounds.
• Two adjusted UTC limits to provide transition time for longer chain-length LC-PFCAs present in PTFE micro-powders and fluoropolymers.
• Slightly adjusted UTC limits for UV-328 and dechlorane plus, to provide a transitional period at higher thresholds, but ultimately lower thresholds once the transition period ends.
• A slightly adjusted substance definition for MCCPs.
• Lowering the existing UTC limits for PBDEs.

Defra intends for this SI to be laid in the UK Parliament in October 2026 and for it to come into force in December 2026, though this is subject to Parliamentary availability and approval. We intend for the territorial extent of the proposed changes to be limited to England, Scotland and Wales, subject to consent from the Scottish and Welsh government ministers.

Many of these amendments will align with equivalent amendments that are already in force in the EU and NI; for the most recent POPs, we anticipate that similar amendments will be made to the EU POPs Regulation (which applies in Northern Ireland under the terms of the Windsor Framework) in parallel, with broadly similar intentions, outcomes, and timescales.

Longer term, we will continue to review potential additional amendments to the assimilated POPs Regulation on an on-going basis, with due consideration to our obligations under the Stockholm Convention, and scientific and technical progress, as well as potential impact on UK stakeholders, and our intention to eliminate or restrict the production, use, trade, and emissions of POPs to protect human health and the environment, in line with the aims and objectives of the Stockholm Convention.  

Find out more on the implementation of the assimilated POPs Regulation or get in touch with the relevant regulator:

• Environment Agency in England
• Natural Resources Wales in Wales
• Scottish Environment Protection Agency in Scotland
• Northern Ireland Environment Agency (NIEA) (an executive agency of the Department of Agriculture, Environment and Rural Affairs (DAERA))

Annex - Responding organisations

Organisations who responded:

1. Yorkshire Water
2. Sellafield Limited
3. Public Services Delivery (PSD) Scotland
4. Daikin Chemical Europe GmbH
5. EUROMOT aisbl- The European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers
6. Chlorinated Paraffins Industry Association (CPIA)
7. Japan Auto Parts Industries Association (JAPIA)
8. Association of British HealthTech Industries (ABHI)
9. Fluoropolymers Product Group at Plastics Europe
10. INEOS Inovyn
11. The Chemours Company
12. BASA (Adhesives and Sealants association for UK and Ireland)
13. Fidra (an environmental charity with particular interest in plastic waste and chemical pollution)
14. Resource Management Association Scotland (RMAS)
15. Construction Equipment Association
16. Chartered Institution of Wastes Management (CIWM)
17. ADS Group Ltd (a trade organisation representing the aerospace, defence, security and space industries in the United Kingdom)
18. Society of Motor Manufacturers and Traders (SMMT)
19. Drinking Water Inspectorate (DWI)
20. National Office of Animal Health (NOAH)
21. Tokyo Electron Europe

In addition, there were also 4 organisations who asked for their responses to be considered as confidential.