EU Adds C9–C21 Long-Chain Perfluorocarboxylic Acids (PFCAs) to POPs Regulation Controls

On September 7, 2026, the European Commission adopted a Delegated Regulation amending the Persistent Organic Pollutants Regulation (Regulation (EU) 2019/1021, the "POPs Regulation") to list long-chain perfluorocarboxylic acids (C9–C21 PFCAs), their salts, and related compounds in Annex I, thereby prohibiting their manufacture, placing on the market, and use. The Regulation will enter into force on the 20th day following its publication in the Official Journal of the European Union and will apply from December 16, 2026.

Scope of the Controls

The controls cover linear and branched C9–C21 PFCAs (general formula CnF2n+1COOH, where 8 ≤ n ≤ 20), their salts, and related compounds that may degrade or transform into C9–C21 PFCAs. However, CnF2n+1X (where X = F, Cl, Br) and PFOA-related compounds already covered by the PFOA entry are not included again.

Specific Exemptions

• C9–C21 PFCAs and their salts present as unintentional trace contaminants (UTC) in substances, mixtures, or articles, with a total concentration ≤ 0.025 mg/kg;
• C9–C21 PFCA-related compounds present as unintentional trace contaminants in substances, mixtures, or articles, with a total concentration ≤ 0.26 mg/kg.

• After 2030: The more stringent C9–C14 standards (0.1 mg/kg or 1 mg/kg) will apply uniformly to the total C9–C21 PFCA content in the above products.
• Decontaminated fire systems: The total C9–C21 content in fluorinated firefighting foam shall be ≤ 10 mg/kg.
• Semiconductor spare parts: C9–C14 compounds used in spare parts for electronic equipment placed on the market before the end of 2023 are exempted until December 30, 2030; C15–C21 compounds used in semiconductor spare parts that originally used the substance are exempted until December 16, 2031.
• Articles already in use: Articles containing C9–C14 compounds that were already in use before the end of 2023, and articles containing C15–C21 compounds already in use before December 17, 2026, may continue to be used.

CIRS Insights

Companies in the fluorine-containing materials sector should immediately initiate supply chain investigations to determine whether their products and raw materials involve C9–C21 PFCAs, and ensure that impurities remain within the exempted limits. In addition, companies should monitor the compliance timelines to avoid losing access to the EU market. CIRS will closely follow developments under the POPs Regulation and provide companies with the latest updates.

Why Choose CIRS

CIRS Group is a leading provider of comprehensive regulatory compliance services and solutions for chemicals, cosmetics, food and food-related products, agrochemicals, and medical devices. Its chemical team consists of experts with extensive knowledge in chemistry, toxicology, environmental science, and related fields. They are well-versed in various international regulations, including but not limited to CSCL, EU REACH, CLP, GHS, TSCA, and K-REACH. 

CIRS operates a subsidiary in the European Union. By leveraging the expertise of CIRS EU and the international team, CIRS can provide enterprises with various chemical services in the EU, including but not limited to:

• EU REACH Registration (including OR services);
• EU REACH Evaluation Compliance Services;
• SVHC Testing;
• PPWR Compliance Services;
• EU CLP Compliance;
• EU Poison Center Notification;  
• EU BPR Compliance;
• EU PoPs Compliance;
• PFAS Testing
• Global GHS compliance

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