EU Proposes Revision of Hazardous Chemical Import and Export Regulations

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 POPs Regulation.

CIRS 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 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.

What CIRS Can Do for You

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 EU REACH, CLP, GHS, TSCA, and K-REACH. Our chemical compliance services in the EU cover:

CIRS Services

• 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

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further information

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