1. Introduction
Persistent Organic Pollutants (POPs) are organic substances that persist in the environment, accumulate in living organisms, and pose significant risks to human health and the environment. They can be transported over long distances by air, water, and migratory species, making them a global concern. The EU POPs Regulation (EU) 2019/1021 implements the Stockholm Convention on Persistent Organic Pollutants within the European Union, aiming to protect human health and the environment by prohibiting, phasing out, or restricting the production and use of POPs.
At Balford, we are fully committed to complying with all applicable environmental regulations, including the EU POPs Regulation. This declaration outlines our compliance stance, the substances we monitor, and our ongoing commitment to responsible manufacturing and supply chain management.
2. Our Commitment to POPs Compliance
Balford hereby declares, under our sole responsibility, that all products, components, materials, and packaging supplied by us are in full compliance with Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on Persistent Organic Pollutants (the “EU POPs Regulation”), as amended periodically.
Specifically, we confirm that:
- Our products do not contain any intentionally added substances listed in Annex I (Part A or Part B) or Annex II of the EU POPs Regulation;
- Any unintentional trace contaminants (UTC) present in our products are strictly below the concentration limits specified in the Regulation;
- We continuously monitor regulatory updates and implement necessary changes to maintain ongoing compliance.
3. Key POPs Substances under Our Control
The EU POPs Regulation currently covers a comprehensive list of persistent organic pollutants. Below are some of the key substance groups relevant to our industry that we rigorously monitor and control:
3.1 Polybrominated Diphenyl Ethers (PBDEs)
PBDEs are brominated flame retardants widely used in plastics, electronics, and textiles. The EU has significantly tightened controls on five PBDEs — tetraBDE, pentaBDE, hexaBDE, heptaBDE, and decaBDE. Under Delegated Regulation (EU) 2025/1482, which took effect on 17 November 2025:
- Basic limit: These five substances in mixtures or articles must have individual and total concentrations ≤ 10 mg/kg;
- Recycled materials: Staged limits apply — ≤ 500 mg/kg (effective date), ≤ 350 mg/kg (from 30 December 2025), and ≤ 200 mg/kg (from 30 December 2027);
- Children’s products: Toys and childcare articles are subject to even stricter phased limits, eventually reaching ≤ 10 mg/kg.
Balford ensures that all our products meet or exceed these stringent requirements, with particular attention to materials sourced from recycling streams.
3.2 Perfluorooctane Sulfonic Acid (PFOS) and Its Derivatives
PFOS is a persistent organic pollutant widely used in industrial and consumer applications. Under Delegated Regulation (EU) 2025/718, effective from 17 July 2025 (with limit revisions taking effect from 3 December 2025):
- PFOS and its salts in substances, mixtures, and articles: ≤ 0.025 mg/kg (25 ppb);
- PFOS-related compounds (sum total): ≤ 1 mg/kg.
Balford actively monitors our supply chain to ensure PFOS and its derivatives are either eliminated or maintained well below these thresholds.
3.3 Dechlorane Plus
On 25 September 2025, the European Commission officially added Dechlorane Plus and its isomers to the POPs list via Delegated Regulation (EU) 2025/1930:
Certain exemptions apply for aerospace, defense, medical imaging, radiotherapy equipment, and spare parts for specific products.
Balford is actively working with our suppliers to phase out Dechlorane Plus from our products ahead of the regulatory deadlines.
3.4 UV-328
UV-328 (CAS No. 25973-55-1) was added to the POPs list via Regulation (EU) 2025/843, effective from 4 August 2025. The concentration limit is 100 mg/kg. UV-328 is commonly used as a light stabilizer in coatings, plastics, and rubber.
Balford has implemented testing protocols to ensure our products do not contain UV-328 above the prescribed limit.
3.5 Chlorpyrifos
On 30 June 2026, the European Commission formally added Chlorpyrifos (CAS No. 2921-88-2) to Annex I, Part A of the EU POPs Regulation. The UTC limit is set at 0.01 mg/kg. No specific exemptions apply.
Balford is taking immediate action to trace and eliminate Chlorpyrifos from our supply chain.
3.6 Substances under Proposal (Pending Adoption)
The European Commission has proposed to add the following substances to Annex I of the EU POPs Regulation:
| Substance | Proposed Limit |
|---|---|
| Medium-Chain Chlorinated Paraffins (MCCPs) | ≤ 1,000 mg/kg (0.1%) |
| Long-Chain Perfluorocarboxylic Acids (C9–C21 PFCAs), their salts and related compounds | ≤ 0.025 mg/kg (25 ppb) |
Balford is proactively preparing for these upcoming restrictions by working with our suppliers to identify and eliminate these substances from our products.
4. Supply Chain Management & Continuous Monitoring
Balford recognizes that POPs compliance extends beyond our own manufacturing operations — it requires end-to-end supply chain accountability. We have therefore implemented the following measures:
- Supplier declarations: All our suppliers are required to provide a Declaration of Compliance confirming that their materials and components do not contain POPs above the prescribed thresholds;
- Material composition declarations: We maintain comprehensive material declarations for all raw materials and components;
- Regular testing: We conduct periodic testing of raw materials and finished products to verify compliance;
- Regulatory tracking: We continuously monitor updates to the EU POPs Regulation, including new substance listings and amendments to existing limits, and communicate relevant changes to our supply chain partners;
- Corrective actions: In the event that any non-compliance is identified, we will immediately investigate, implement corrective measures, and notify affected customers.
5. Basis of This Declaration
This declaration is based on:
- Information available to Balford from our suppliers, including supplier certifications and material composition declarations;
- Our own internal testing and quality control procedures;
- The currently valid list of substances subject to the EU POPs Regulation, as published by the European Chemicals Agency (ECHA).
We declare this to the best of our knowledge and belief.
6. Commitment to Continuous Improvement
Sustainability and regulatory compliance are not destinations — they are ongoing journeys. At Balford, we remain dedicated to:
- Continuous improvement in our environmental and compliance performance;
- Investing in new technologies that enable safer, cleaner manufacturing processes;
- Training our employees on best practices in chemical management and regulatory compliance;
- Engaging with our supply chain partners to ensure our shared commitment to sustainability and compliance extends throughout the entire value chain.
7. Conclusion
Balford is proud to be a responsible manufacturer and supplier, committed to protecting human health and the environment by fully complying with the EU POPs Regulation (EU) 2019/1021. We invite our clients, partners, and communities to join us in this mission — because a cleaner, safer world is a better world for everyone.
Issued by:
Balford
[MAY 2, 2016]
[shawn@balford.net]
This declaration is subject to periodic review and will be updated as the EU POPs Regulation is amended or as new information becomes available.
