On April 30, 2026, the Official Journal of the European Union officially published the decision (EU) 2026/878. The decision clearly states that the European Union will submit a proposal on behalf of its member states to the Secretariat of the Stockholm Convention on Persistent Organic Pollutants, suggesting that tetrabromophthalate bis(2-ethylhexyl) ester (referred to as TBPH) be included in Appendix A (Elimination List) of the Convention. This means that TBPH is expected to become one of the next batch of persistent organic pollutants (POPs) to be prioritized for elimination on a global scale.

I. Background:

TBPH is a brominated flame retardant mainly used in plastic and rubber products, wires and cables, electronic and electrical appliance casings, polyurethane foams, automotive parts, etc. According to Article 57(e)(2) of Regulation (EC) No 1907/2006 of the European Parliament and of the Council, the EU has listed it as a substance of very high concern due to its extremely high persistence and bioaccumulation potential.

A large amount of scientific research data indicates that TBPH not only has clear toxicity (posing potential hazards to the human endocrine system and reproductive development system, and some studies suggest it may be carcinogenic), but also has the ability to migrate over long distances - the presence of this substance has been detected in the soil, water, and organisms of remote areas such as the polar regions and high mountains, far from human activities. This indicates that its pollution range has covered the entire globe, meeting the criteria for persistent organic pollutants (POPs) as defined in Annex D of the Stockholm Convention, and thus is clearly regarded as a POP that requires global coordinated control.

Based on the above characteristics and potential environmental and health risks, the EU has submitted a proposal to the Convention Secretariat, suggesting that TBPH be included in Annex A of the Convention to reduce its global emissions.

Key planned time points for the inclusion of TBPH in the Convention's Annex A:

April 2026 - The EU Regulation (EU) 2026/878 comes into effect, and the proposal has been submitted to the Convention Secretariat;

October 2026 - The Persistent Organic Pollutants Review Committee (POPRC) will begin to review the nomination dossier of TBPH;

2029 - The final decision on whether to officially include TBPH in Annex A will be made at the Conference of the Parties (COP) to the Stockholm Convention at the earliest.

II. Solutions:

At present, the proposal is still in the international convention review stage and has not completed the final voting process, so TBPH has not yet directly triggered the ban and restriction requirements of the EU POPs regulations.

However, it is important to note that TBPH has previously been included in the REACH SVHC list. According to the requirements of the REACH regulation, if the content of TBPH in the product exceeds the specified limit, enterprises must fulfill the obligation to convey supply chain information and provide substance information to downstream customers and relevant institutions.

At the same time, considering the advancement trend of the Stockholm Convention proposal, it is recommended that relevant enterprises, especially those involved in the production, import, and use of TBPH in the plastic, electronic, automotive, and building materials industries, take proactive actions:

First, conduct a comprehensive investigation of the supply chain to clarify the use, content, and source of TBPH in their own products and raw materials;

Second, establish a dynamic tracking mechanism to continuously monitor the progress of the Stockholm Convention review and the transformation of EU POPs regulations, and promptly grasp changes in control policies;

Third, plan alternative solutions in advance, carry out the screening, testing, and verification of alternative materials, and prioritize the selection of environmentally friendly, compliant, and performance-matching flame retardants to replace TBPH, avoiding risks such as production disruptions and export blockages due to sudden policy changes, and ensuring the stability of the enterprise's supply chain.

Fourth, seek support from professional testing and certification institutions. NBTS, with its deep expertise in compliance testing, can assist enterprises in promptly grasping changes in control policies, providing comprehensive answers to questions and efficient solutions to various TBPH-related compliance issues, offering one-stop testing and certification consulting services, and serving as a reliable product compliance manager for you.