Policy paper

Responses received and government response

Updated 22 July 2025

Defra recently invited comments on the draft indicative list of long chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds. In addition, feedback was also sought on the indicative lists for perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds, as well as for perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds. 

This call for comment aimed to gather additional information and insights to support the ongoing work of the Stockholm Convention’s intersessional working group responsible for developing and refining these indicative lists as part of their broader consultation process. 

Number of responses 

We received 2 responses relating to the draft indicative list for LC-PFCAs from: 

• AGC Chemicals Europe Ltd, a global manufacturer and distributor of fluorinated chemicals 

• The Chemical Industries Association (CIA), a trade association for chemical and pharmaceutical businesses in the UK 

Government response  

Information received in these responses were incorporated into the UK’s submission of comments to the Stockholm Convention’s POPs Review Committee (POPRC).  

The Stockholm Convention website includes more information about POPRC’s calls for information.   

Full responses 

These responses from UK stakeholders represent their perspectives and do not necessarily reflect the views of Defra or the government. 

AGC Chemicals Europe Ltd 

AGC Chemicals Europe, Ltd. welcomes the opportunity to submit a response to this call for comments on the indicative lists for long-chain PFCAs, PFOA and PFHxS, their salts and related compounds.  

Our comments specifically relate to the Perfluoro compounds, C5-18 (CAS: 86508-42-1) included in the draft indicative list of long chain perfluorocarboxylic acids, their salts and related compound. AGC Chemicals Europe, Ltd. would like to propose addition of the following text in bold below to the footnote 4:  

Existing text of footnote 4:  

“Substances described by this CAS number could include perfluorinated amines and ether compounds with fluorocarbon chains that meet the definition of compounds related to long-chain PFCAs. However, as indicated in the addendum to the risk management evaluation (UNEP/POPS/POPRC.20/10/Add.3), some commercial products described by this CAS number were determined not to include compounds meeting this definition.”  

Additional text proposed to be added to footnote 4:  

“Consequently, to ensure effective risk management measures related to the use of these substances, Parties should assess the chemical composition of products described by this CAS number as part of their National Implementation Plan. It can be referenced from the analytical methods described in the documents submitted to the POPRC.”  

As noted by POPRC some commercial products described by this CAS number do not include compounds meeting the definition of compounds related to long-chain PFCAs. Those might be used to aid critical applications such as medical devices or electronics and semiconductors sectors in the UK and in the EU.  

While the list of related compounds might be indicative, legal measures are left to the discretion of each Party. We are therefore concerned that without an addition of proposed wording, substances could be regulated without proper evaluation in the UK and globally. This could have an unintended impact on UK and global industry. The addition of the above text to the existing footnote 4 will encourage each Party to perform careful evaluation of the chemical composition of products designated by this CAS number as part of their national implementation plans.  

We kindly request that DEFRA considers submission of comments supporting addition of this text and, as part of national implementation plan in consultation with stakeholders, performs such evaluation to ensure appropriate regulation in the UK. 

The Chemical Industries Association (CIA) 

The Chemical Industries Association (CIA) would like to submit a comment for consideration on the draft indicative lists for long-chain PFCAs, PFOA and PFHxS, their salts and related compounds, following feedback received from our membership. 

With regards to the long-chain PFCAs indicative list, additional information should be given for the CAS Number 86508-42-1 in the Excel spreadsheet so that any substance(s) (under this CAS number) not meeting the definition of related-compounds are not inadvertently captured by any potential regulation should a Party decide on this route. Whilst the comment is for this CAS number, it is also applicable to CAS numbers describing a range of compound(s) on any indicative list that may include substance(s) not related to a listed POP. 

For CAS Number 86508-42-1, we suggest the text in bold below be added to the end of the existing Footnote [1]. The addition of this will hopefully encourage each Party to undertake a careful evaluation of the chemical composition of products designated by a CAS number as part of their national implementation plans. 

Proposed additional text: “Consequently, to ensure effective risk management measures related to the use of these substances, Parties should assess the chemical composition of products described by this CAS number as part of their National Implementation Plan. It can be referenced from the analytical methods described in the documents submitted to the POPRC.” 

The existing text reads as: “Substances described by this CAS number could include perfluorinated amines and ether compounds with fluorocarbon chains that meet the definition of compounds related to long-chain PFCAs. However, as indicated in the addendum to the risk management evaluation (UNEP/POPS/POPRC.20/10/Add.3), some commercial products described by this CAS number were determined not to include compounds meeting this definition.”

We thank you for taking this into consideration and remain at your disposal should you need any clarification.