Balford Declaration of Compliance with EU POPs Regulation (EU) 2019/1021

1. Introduction

Persistent Organic Pollutants (POPs) are organic compounds that resist environmental degradation, bioaccumulate in living tissue, and present real hazards to both human health and ecosystems. Because they travel long distances via air, water, and migratory species, they are a global issue, not a local one. The EU POPs Regulation (EU) 2019/1021 enforces the Stockholm Convention on Persistent Organic Pollutants across the EU, banning, phasing out, or restricting the manufacture and use of these substances.Stockholm Convention on Persistent Organic PollutantsAt Balford, we take environmental compliance seriously. We are fully committed to meeting all applicable regulations, including the EU POPs Regulation. This declaration spells out our compliance position, the specific substances we track, and our ongoing approach to responsible manufacturing and supply chain oversight.

2. Our Commitment to POPs ComplianceBalfordBalford hereby declares, under our sole responsibility, that all products, components, materials, and packaging we supply 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:

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 productscontain no intentionally added substanceslisted in Annex I (Part A or Part B) or Annex II of the EU POPs Regulation;
• Any unintentional trace contaminants (UTC) found in our products arekept well below the concentration limitsset out in the Regulation;
• We track regulatory changes on an ongoing basis and adjust our processes as needed to stay fully compliant.

3. Key POPs Substances We Control

The EU POPs Regulation covers a broad list of persistent organic pollutants. Below are the main substance groups relevant to our type of manufacturing that we monitor and control closely:

3.1 Polybrominated Diphenyl Ethers (PBDEs)

PBDEs are brominated flame retardants historically used in plastics, electronics, and textiles. The EU has tightened limits significantly on five PBDEs — tetraBDE, pentaBDE, hexaBDE, heptaBDE, and decaBDE. Under Delegated Regulation (EU) 2025/1482, effective 17 November 2025:

• General limit: For these five substances in mixtures or articles, theindividual and total concentrations must be ≤ 10 mg/kg;
• Recycled materials: Staged limits apply — ≤ 500 mg/kg (upon entry into force), ≤ 350 mg/kg (from 30 December 2025), and ≤ 200 mg/kg (from 30 December 2027);
• Children's products: Toys and childcare articles face even tighter phased limits, ultimately reaching ≤ 10 mg/kg.

Balfordmakes sure all our parts meet or beat these requirements, with extra scrutiny on material coming from recycled sources.

3.2 Perfluorooctane Sulfonic Acid (PFOS) and Its Derivatives

PFOS is a persistent organic pollutant that shows up in a range of industrial and consumer products.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. actively monitors our supply chain to ensure PFOS and its derivatives are either eliminated or maintained well below these thresholds.

3.3 Dechlorane Plus

::

Until 15 April 2028: ≤
• 1,000 mg/kg;;
From 15 April 2028 onwards: ≤
• 1 mg/kg..

..

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 under Regulation (EU) 2025/843, effective 4 August 2025. The concentration limit is 100 mg/kg. UV-328 is a common light stabilizer used in coatings, plastics, and rubber.. The concentration limit is Balford has implemented testing protocols to verify our products stay below the prescribed UV-328 limit.. UV-328 is commonly used as a light stabilizer in coatings, plastics, and rubber3.5 Chlorpyrifos

On 30 June 2026, the European Commission 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. 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 RegulationThe European Commission has proposed adding the following substances to Annex I of the EU POPs Regulation:0.01 mg/kgSubstanceProposed LimitMedium-Chain Chlorinated Paraffins (MCCPs)

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 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

At Balford, we understand that POPs compliance doesn't stop at our own shop floor—it runs through the entire supply chain, from raw material to finished part.manufacturingThat's why we've built a compliance program that covers every step of our sourcing and production process. Here's how we manage it:fullsupply chain visibility and accountability. Specifically, we've put the following controls in place:

• Supplier declarations: Every supplier must submit a Declaration of Compliance confirming their materials and components stay below the prescribed POPs thresholds. We don't accept verbal assurances—we want it in writing.: 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 keep detailed records on the chemical makeup of all raw materials and components we bring in. This gives us a clear paper trail for every lot we run.
• Material composition declarationsRegular testing: We run periodic tests on both incoming raw material and finished parts to verify they meet the required limits. This isn't a one-time check—it's an ongoing part of our QC routine.
• Regulatory tracking: We stay on top of changes to the EU POPs Regulation, including new substance listings and revised limits, and we pass that information down to our suppliers so everyone's working from the same updated spec.;
• Corrective actions: If we ever find a non-compliance issue, we act immediately—investigate the root cause, put corrective measures in place, and notify any affected customers without delay.: 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;
5. Basis of This Declaration
• Corrective actionsThis declaration is grounded in the following sources:

Information we've gathered from our suppliers, including their certifications and material composition declarations;

Our own internal testing and quality control procedures, which we apply consistently across all production runs;

The current list of substances regulated under the EU POPs Regulation, as published by the European Chemicals Agency (ECHA).
• Information available to Balford from our suppliers, including supplier certifications and material composition declarations;
• We're making this declaration in good faith, based on the best information available to us at this time.
• 6. Commitment to Continuous Improvement

We declare this to the best of our knowledge and belief.

6. Commitment to Continuous Improvement

Sustainability and regulatory compliance aren't one-time milestones—they're ongoing commitments. At Balford, we stay focused on:

• Continuous improvement in our environmental and compliance performance;
• Investing in new technologies that support safer, cleaner manufacturing operations;
• Training our employees on chemical management and regulatory best practices;
• Engaging with our supply chain partners to ensure our shared commitment to sustainability and compliance runs through the entire value chain.

7. Conclusion

Balford is a responsible manufacturer and supplier, fully committed to protecting human health and the environment by complying with the EU POPs Regulation (EU) 2019/1021. We invite our clients, partners, and communities to join us—because a cleaner, safer world benefits everyone.

Issued by:

Balford
[MAY 2, 2016]
[shawn@balford.net]

This declaration is reviewed periodically and will be updated as the EU POPs Regulation changes or new information comes to light.