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Regulation (EU) 2019/102: Limits of PFOS as a contaminant
- Daniel Jiménez
- 3 days ago
- 3 min read
On 14 April 2025, the Commission adopted a Delegated Regulation amending the entry for perfluorooctane sulfonic acid (PFOS), its salts and related compounds in Annex I to Regulation (EU) 2019/1021 (POP Regulation).
The reform reduces the limit for PFOS present as an unintentional trace contaminant (UTC) in substances and mixtures by 40 times and harmonizes the permitted values with those previously set for PFOA.
The text is subject to a two-month scrutiny period by the European Parliament and the Council; if they raise no objections, it will be published in the Official Journal and enter into force twenty days later, while the new values will apply from December 3, 2025.
Table of contents
1. Regulatory context
Regulation (EU) 2019/1021 transposes the commitments of the Stockholm Convention on Persistent Organic Pollutants into Union law, prohibiting the manufacture, placing on the market, and use of substances included in Annex I to the Convention, except for limited exemptions. Although PFOS was the first per- and polyfluoroalkyl substance to be regulated in the EU, the current UTC limits (10 mg kg⁻¹ for substances/mixtures and 0.1% w/w for articles) were more than a decade old and were far from the demonstrated achievable technical levels for other PFAS, such as PFOA.
2. Main technical modifications
Aspect | Previous situation | New delegated text |
Identification of the substance | “Perfluorooctane sulfonic acid and its derivatives (PFOS)” | “Perfluorooctane sulfonic acid (PFOS), its salts, and PFOS-related compounds” |
UTC in substances or mixtures | ≤ 10 mg kg⁻¹ (0.001% w/w) PFOS | ≤ 0.025 mg kg⁻¹ (2.5 × 10⁻⁶ % w/w) of PFOS or any of its salts |
UTC in articles | < 0.1% w/w PFOS in parts containing it or 1 µg m⁻² in coated material | ≤ 1 mg kg⁻¹ (0.0001 % w/w) for the sum of concentrations of all PFOS-related compounds |
Specific exemptions | Point 4: Use as a mist suppressor in hard chrome plating (Cr VI) | Eliminated, as PFOS has been replaced for that use in the EU |
Reference to analytical methods (point 5) | Included | Eliminated |
3. Implementation schedule
14 Apr 2025 : adoption by the Commission.
14 June 2025 (maximum): Deadline for Parliament and Council to submit objections.
≈ Jul‑Aug 2025 : publication planned in the OJEU and entry into force twenty days later.
December 3, 2025 : date of application of the new UTC limits (items 1 and 2 of the annex).
4. Industrial repercussions
Raw materials and formulations
Manufacturers of fluorinated substances must demonstrate that residual PFOS is <0.025 mg kg⁻¹. The new value is close to the limit of quantification (LOQ) of current chromatographic methods, so laboratory validation becomes crucial.
Articles and coatings
Sectors such as metal coatings, technical textiles and optical films will have to adapt specifications to guarantee ≤ 1 mg kg⁻¹ of PFOS-related in the final product.
Elimination of the exemption on hard chrome plating
Electroplating workshops that still use PFOS-based mist suppressants must migrate to alternatives (e.g., polyalkylsulfonate polymers) and update their emissions permits.
Analysis and supply chain
Hosting PFOS above the new threshold will automatically render the substance, mixture, or article “non-compliant,” requiring removal and treatment as POP waste.
5. Compliance Recommendations (Belab Services)
Priority action | Recommended deadline |
Mapping PFAS inventories and determining residual PFOS levels by LC‑MS/MS (LOQ ≤ 5 µg kg⁻¹) | < Q3‑2025 |
Negotiate contractual clauses on < 0.025 mg kg⁻¹ with suppliers of fluorinated raw materials | Immediate |
Replace PFOS-based mist suppressants and update environmental permits | Before Q4‑2025 |
Review REACH declarations and safety data sheets to reflect the new UTC limits | After publication in DOUE |
Establish control analysis on reception and on finished product according to EN 17308:2021 | Continuous |
Conclusions
The updated UTC values for PFOS mark a decisive step in European PFAS reduction policy, aligning the limits with those already applicable to PFOA and incentivizing the adoption of low-impact alternatives.
Companies that manage residual PFOS have less than a year to re-evaluate their processes, demonstrate analytical compliance, and, where appropriate, implement substitutions.
Continued monitoring of new delegated acts on other PFAS will be essential to maintain competitiveness and regulatory compliance.
Official references
European Commission. C(2025) 2189 final – Delegated Regulation amending Regulation (EU) 2019/1021 as regards PFOS (adoption 14 April 2025). EUR-Lex
European Commission. Initiative sheet Ares(2023)8264517 – Persistent organic pollutants – Annex I amendment (public consultation December 2023). EUR-Lex
European Parliament and Council. Regulation (EU) 2019/1021 on persistent organic pollutants (consolidated version 17‑Oct‑2024) . EUR-Lex
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