EU POPs Chlorpyrifos Compliance Guide for Products

The EU is moving to add chlorpyrifos to the list of substances controlled under the EU Persistent Organic Pollutants Regulation, also known as the EU POPs Regulation. For product compliance teams, this is not only a pesticide issue. It is a supply chain, material data, supplier evidence and market access issue.

The attached European Commission draft delegated regulation proposes to amend Regulation (EU) 2019/1021 by adding chlorpyrifos to Part A of Annex I, the section covering substances subject to elimination under the EU POPs framework. The draft document is clearly marked as not yet adopted or endorsed by the European Commission, which means companies should treat it as a regulatory readiness signal and monitor the final published regulation before making final legal conclusions.

This guide explains what is changing, why it matters, which teams should prepare and how to build a practical compliance workflow before the requirement becomes a market access problem.

What Is Chlorpyrifos?

Chlorpyrifos is an insecticide historically used to control pests on a range of crops. The European Commission notes that chlorpyrifos and chlorpyrifos-methyl were previously used as insecticides, and EU Member States voted in 2019 not to renew their approvals. The Commission formally adopted the non-renewal regulations on 10 January 2020, after which Member States had to withdraw authorisations for plant protection products containing those active substances.

The new issue is different. The proposed POPs listing would move chlorpyrifos into a broader product compliance context because the EU POPs Regulation applies to substances, mixtures and articles listed in its annexes.

Why This Matters for Product Compliance Teams

The EU POPs Regulation aims to protect human health and the environment from persistent organic pollutants by prohibiting, phasing out or restricting the manufacturing, placing on the market and use of substances covered by the Stockholm Convention and related POPs rules.

Under Article 3 of Regulation (EU) 2019/1021, the manufacturing, placing on the market and use of substances listed in Annex I are prohibited, whether the substance is on its own, in mixtures or in articles, subject to Article 4 exemptions.

For businesses, this means the compliance question is not only:

“Do we intentionally use chlorpyrifos?”

It becomes:

“Can we prove that chlorpyrifos is not present above the applicable trace limit in our products, mixtures, materials or supplier inputs?”

That is why companies selling into the EU should prepare structured evidence, supplier declarations, testing logic and internal controls before enforcement risk appears.

What Is Changing Under the Draft EU POPs Update?

At the twelfth meeting of the Conference of the Parties to the Stockholm Convention, held from 28 April to 9 May 2025, chlorpyrifos was listed in Annex A to the Convention under decision SC-12/9. The Stockholm Convention page confirms that chlorpyrifos was one of the chemicals added to Annex A at COP-12.

The attached EU draft delegated regulation aims to reflect that international decision in EU law by adding chlorpyrifos to Annex I of Regulation (EU) 2019/1021.

The attached annex proposes the following entry:

The attached annex states that Article 4(1), point (b), would apply where chlorpyrifos is present at concentrations equal to or below 0.01 mg/kg, equivalent to 0.000001% by weight, in substances, mixtures or articles.

This proposed limit is extremely low. Companies should not rely only on general supplier statements. They need structured documentation that is specific, traceable and connected to the actual materials, products and suppliers in scope.

When Would the Requirement Apply?

The draft regulation states that it would enter into force on the twentieth day following publication in the Official Journal of the European Union. However, because the attached document is still a draft, companies should not present this as an already adopted legal deadline.

The practical approach is to prepare now while continuing to monitor the final version. Once adopted and published, businesses may have limited time to update supplier evidence, product compliance files, purchasing specifications and internal restricted substance lists.

Who Should Prepare?

This update is relevant for companies that place products, materials, mixtures or articles on the EU market, especially where product compliance depends on supplier-controlled materials or complex global supply chains.

The teams most likely to be involved include:

Even if chlorpyrifos is not intentionally used in a product, compliance teams should still consider contamination risk, supplier data gaps and undocumented material inputs.

Practical Compliance Checklist for Chlorpyrifos

A strong readiness plan should connect regulatory monitoring, product data, supplier communication and evidence management.

1. Confirm the Regulatory Status

Start by tracking the draft delegated regulation until the final text is published. The current document is a draft, so the final legal wording may still need to be verified before publication.

Your compliance team should monitor:

2. Update the Restricted Substance List

Add chlorpyrifos to your internal restricted substance list as a monitored substance. The entry should include:

• Substance name: Chlorpyrifos
• CAS No.: 2921-88-2
• EC No.: 220-864-4
• Regulatory framework: EU POPs Regulation
• Proposed limit: 0.01 mg/kg
• Scope: substances, mixtures and articles
• Status: draft / pending final adoption until published

This helps procurement, suppliers and internal product teams work from the same compliance baseline.

3. Map Products, Materials and Suppliers

Companies should identify where chlorpyrifos risk could enter the supply chain. This does not mean assuming chlorpyrifos is present. It means identifying where the company lacks enough evidence to prove compliance.

Focus on:

4. Request Supplier Declarations

Supplier declarations should be clear, substance-specific and linked to the product or material supplied. A vague statement such as “compliant with EU law” is usually not strong enough for a product compliance file.

A practical chlorpyrifos supplier declaration should include:

5. Decide When Testing Is Needed

Testing is not always necessary for every product, but it may be needed when supplier information is incomplete, outdated or not reliable enough.

Consider testing when:

• The supplier cannot provide a substance-specific declaration
• The supply chain is complex or poorly documented
• Materials have a plausible contamination risk
• There is a history of non-compliance or weak supplier controls
• The product is high-volume or high-risk for EU market access
• The supplier changes materials, processes or manufacturing locations

Because the proposed trace contaminant limit is 0.01 mg/kg, companies should confirm that any selected laboratory method is suitable for the required detection level.

6. Keep Evidence in a Product Compliance File

Compliance evidence should be organised by product, material and supplier. This is especially important when requirements apply to articles, mixtures and substances across a product portfolio.

A strong compliance file may include:

Common Compliance Mistakes to Avoid

Mistake 1: Treating Chlorpyrifos as Only a Pesticide Issue

Chlorpyrifos is historically known as an insecticide, but the proposed EU POPs listing affects the broader regulatory treatment of the substance in substances, mixtures and articles. Companies should avoid limiting their review only to agricultural products.

Mistake 2: Relying on Generic Supplier Statements

Statements like “our products are compliant” do not always provide enough evidence. Compliance teams need substance-specific, product-specific and dated documentation.

Mistake 3: Ignoring Articles and Components

The POPs Regulation is not limited to pure substances. Annex I prohibitions can apply to listed substances in articles and mixtures as well.

Mistake 4: Not Controlling Supplier Changes

A product may be compliant today but become risky after a supplier changes a formulation, source material, process or manufacturing site. Supplier change notification should be part of the compliance workflow.

Mistake 5: Waiting Until the Final Regulation Is Published

Since the draft proposes a very low trace limit, companies may need time to collect declarations, assess risk, update specifications and test selected materials. Waiting until publication can create unnecessary pressure.

Practical Readiness Matrix

Step-by-Step Action Plan for Businesses

Step 1: Create a Regulatory Watch Task

Assign responsibility to monitor the final delegated regulation, Official Journal publication and final Annex I wording.

Step 2: Add Chlorpyrifos to Internal Compliance Controls

Update restricted substance lists, supplier requirements, purchasing specifications and product compliance checklists.

Step 3: Identify Products and Suppliers in Scope

Map products placed on the EU market and identify suppliers providing substances, mixtures, articles, packaging, treatments or materials where additional evidence is needed.

Step 4: Request Updated Supplier Evidence

Ask suppliers for chlorpyrifos-specific declarations using CAS No. 2921-88-2 and the proposed limit of 0.01 mg/kg.

Step 5: Apply Risk-Based Testing

Use testing where supplier data is missing, where materials are high risk or where compliance evidence must be strengthened for customers or authorities.

Step 6: Centralise Documentation

Store declarations, SDSs, material data, test reports and change records in one controlled system.

Step 7: Review Product Marketability

Confirm whether each product has sufficient evidence to support EU market access under the POPs compliance framework.

Why This Update Is a Data Management Challenge

For many companies, the most difficult part of chemical compliance is not understanding the regulation. It is collecting, structuring and maintaining evidence across many products and suppliers.

Chlorpyrifos compliance requires answers to practical questions:

• Which products are sold into the EU?
• Which suppliers provide the materials?
• Which declarations are current?
• Which products still have missing data?
• Which materials require testing?
• Who approved the evidence?
• What happens if a supplier changes a formulation?
• Can the company prove compliance quickly during a customer or authority request?

Without a structured system, these answers are often spread across emails, spreadsheets, local folders and supplier portals. That creates risk, especially when a restriction has a very low trace threshold.

How ComplyMarket Can Support EU POPs Chlorpyrifos Compliance

ComplyMarket helps companies manage product, material and supplier compliance in a structured and traceable way. Its platform supports product compliance, material compliance, supplier communication, documentation management and regulatory readiness for companies managing complex supply chains.

ComplyMarket lists EU POP Regulation 2019/1021 Compliance: Products & POP Waste among its compliance service areas, alongside REACH, SCIP, RoHS, PFAS, packaging, battery and product compliance services.

For chlorpyrifos readiness, ComplyMarket can support companies by helping them:

ComplyMarket’s product compliance software is designed to help companies manage compliance documentation, global market readiness, supplier collaboration and product compliance evidence in one platform. The company states that its platform allows teams to assign tasks, request documentation and collaborate with suppliers, while also helping businesses reduce risk, improve transparency and act decisively.

For companies preparing for the proposed chlorpyrifos listing, the key advantage is control. Instead of reacting to each new restriction manually, businesses can build a repeatable compliance process that connects regulatory obligations, supplier evidence, product data and documentation.