ROHS Compliance

On October 28, 2025, the European Commission formally adopted Delegated Regulation (EU) 2025/1482, introducing major amendments to the control of polybrominated diphenyl ethers (PBDEs) under the EU Persistent Organic Pollutants (POPs) Regulation (EU) 2019/1021.

Background

PBDEs are persistent, bioaccumulative, and toxic substances that were listed for global elimination under the Stockholm Convention in 2009. Although production in the EU has largely ceased, PBDEs still appear in new products such as furniture and textiles due to the use of recycled materials. The current regulation allows an unintentional total residual limit of 500 mg/kg for PBDEs in mixtures or articles. On July 24, 2025, the Commission proposed a revision to significantly reduce these limits for brominated flame retardants (PBDEs), which was subsequently approved by the European Parliament and Council and published in the EU Official Journal on October 28, 2025.

Key Revisions

The updated regulation introduces stricter total concentration limits for tetra-, penta-, hexa-, hepta-, and decabromodiphenyl ethers (PBDEs) in mixtures or articles:

1. General Products (excluding food contact materials)

a. Combined PBDE limit reduced from 500 mg/kg to 10 mg/kg, effective immediately.

2. Recycled Material Products

a. Transitional phase-out schedule:

i. 500 mg/kg allowed until December 30, 2025

ii. 350 mg/kg effective December 30, 2025

iii. 200 mg/kg effective December 30, 2027

3. Toys and Childcare Articles (e.g., seats, sleep, feeding, hygiene, and mobility products)

a. Regardless of recycled content:

i. 350 mg/kg limit by December 30, 2025

ii. 10 mg/kg limit by May 17, 2027, aligning with general products and removing previous exemptions.

4. Food Contact Materials

a. Exempt from this regulation but must comply with Regulations (EU) 10/2011 and (EU) 2022/1616, which already prohibit PBDEs.

Next Steps for Businesses

The revised regulation enters into force on November 17, 2025. Companies exporting products to the EU are advised to immediately audit their supply chains and perform PBDE screening to ensure compliance and avoid potential trade disruptions.

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