ROHS Compliance

On March 16, 2026, the New Zealand Environmental Protection Authority (EPA) released a proposal to restrict three newly listed chemicals under the Stockholm Convention on Persistent Organic Pollutants and opened a public consultation on potential exemptions. 

Background 

In May 2025, three additional substances were added to the Stockholm Convention, which aims to eliminate or restrict persistent organic pollutants (POPs). These chemicals are highly toxic, persist in the environment, travel long distances, and bioaccumulate in humans and ecosystems, posing serious health risks. 

As a signatory, New Zealand is required to control the production, use, import, and export of these substances. To comply, the EPA plans to include them in Schedule 2A (POPs List) under the Hazardous Substances and New Organisms Act 1996. 

Substances Proposed for Regulation 

The EPA proposal covers the following: 

  • Chlorpyrifos: A widely used pesticide, already under phase-out in New Zealand by July 2027. The proposed restriction would advance this to December 16, 2026.  

  • Medium-Chain Chlorinated Paraffins: Commonly used in PVC, metalworking fluids, paints, sealants, and adhesives.  

  • Long-Chain Perfluorocarboxylic Acids: A group of PFAS chemicals used in sectors such as electronics, textiles, coatings, and firefighting foams.  

Potentially Affected Sectors 

A wide range of industries may be impacted, including: 

  • Agriculture and agrochemicals  

  • Plastics, polymers, and PVC manufacturing  

  • Automotive and machinery sectors  

  • Electronics and semiconductors  

  • Medical devices and laboratory equipment  

  • Textiles, packaging, coatings, and cleaning products  

  • Aerospace and defence  

Proposed Exemptions 

Under the Stockholm Convention, time-limited exemptions are permitted. New Zealand is consulting on: 

  • Specific Use Exemptions (up to December 16, 2031):  

  • MCCPs: limited use in flexible PVC (e.g., cables, medical devices), polyurethane foam, adhesives, sealants, coatings, metalworking fluids, and certain industrial applications.  

  • LC-PFCAs: use in semiconductor and automotive replacement parts, particularly where alternatives are not yet feasible.  

  • Articles in Use: 
    Existing products containing these substances before the restriction date may continue to be used until the end of their service life.  

Next Steps 

The consultation period runs from March 17 to April 17, 2026. Following this, the EPA will review stakeholder feedback, prepare a report for the Minister for the Environment, and seek Cabinet approval to amend relevant schedules under the HSNO Act. 

To meet its international obligations, New Zealand must finalize these regulatory updates by December 16, 2026.