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Persistent Organic Pollutants (POPs) are tightly regulated under EU Regulation (EU) 2019/1021. But for electronics manufacturers, identifying POPs across complex, multi-tier supply chains isn’t straightforward — especially as new substances like PFHxS, Dechlorane Plus, and UV-328 continue to be added to Annex I.
1 Start with Your Bill of Materials (BOM)
Cross-reference your BOM against the most recent Annex I and Annex IV updates.
- Look for flame retardants (e.g., HBCDD, DecaBDE)
- Check polymers and coatings for UV-328
- Review past use of PFAS compounds like PFHxS
Use structured BOM data—not just PDFs—for effective screening.
2 Engage Tier-1 and Tier-2 Suppliers
Your suppliers hold the key to POPs visibility.
- Request POPs-specific declarations
- Provide them with the updated substance list and thresholds
- Focus on UTC limits (e.g., 0.025 mg/kg for PFHxS)
Pro tip: Use IPC-1752A or IEC 62474 formats to standardize responses.
3 Screen for Unintentional Trace Contaminants (UTCs)
Many POPs restrictions apply even if the substance is not intentionally added.
- HBCDD limit: 75 mg/kg
- PFHxS: 0.025 mg/kg
- UV-328: Phased down to 1 mg/kg over 4 years
Don't just ask “Is it used?” — ask “Is it present?”
4 Assess Waste Streams for Annex IV Compliance
The moment your products become waste, stricter POPs thresholds apply.
- Example: SCCPs threshold dropped from 1500 mg/kg to 420
- Reuse of non-compliant materials is prohibited
This step is critical if you're reprocessing components or working with recyclates.
5 Automate Updates and Monitor Regulatory Change
The POPs list is expanding fast. Manual tracking won’t scale.
- Use regulatory intelligence tools that map Annex changes
- Tag suppliers who have legacy materials flagged in enforcement reports
- Stay aligned with Stockholm Convention updates that may enter EU law
Common Mistakes to Avoid
- Relying on outdated supplier data
- Ignoring UTCs in recycled or legacy stock
- Skipping Tier-2 and Tier-3 supplier engagement
- Not updating waste management SOPs with Annex IV limits
How Acquis Simplifies POPs Compliance
Acquis offers pre-configured workflows for EU POPs that include:
- Full BOM + Material Declaration Screening against Annex I and IV
- Automated Supplier Engagement to request and validate POPs data
- Integrated threshold risk flags for UTC exceedances
- Real-time regulatory updates, mapped to product-level impact
You don’t have to choose between risk and complexity.
Assess your POPs exposure with Acquis today
Contact Acquis today to schedule a free supply chain risk audit or demo of our POPs compliance automation tools.