This blog post is based on the presentations and remarks of Dr Roland Weber, POPs Environmental Consulting, delivered during the GGKP webinar Activity Options for Action Plans for Brominated, Chlorinated and Other New POPs, held on 22 January 2026.
Many newly listed persistent organic pollutants (POPs) under the Stockholm Convention are plastic additives or polymer-related chemicals: brominated and chlorinated flame retardants, several per- and polyfluoroalkyl substances (PFAS) used in side-chain fluorinated polymers, and, most recently, the non-halogenated UV stabilizer UV-328. Produced in high volumes, many remain embedded in products and plastic waste streams.
Scientific assessments show that “novel entities,” including hazardous chemicals of concern such as PFAS and plastic pollution, have crossed planetary boundaries. Chemicals and waste are closely linked to climate change and biodiversity loss, placing chemical pollution at the heart of the triple planetary crisis.
Against this backdrop, National Implementation Plans (NIPs) under the Stockholm Convention should not address POPs in isolation. Large stocks of POP-containing plastics are concentrated in electronics, transport and buildings – sectors with long service lives and significant recycling flows. Action plan considerations for managing POPs, other chemicals of concern, plastics and resources in these major sectors, therefore, require an integrated, sector-based approach that links POP control with plastic management, resource recovery and broader chemicals and waste frameworks.
Regulatory framework and sectoral focus
Action plans for POP plastic additives should start with the regulatory framework. The objective is to establish clear national rules for managing brominated flame retardants, UV-328, Dechlorane Plus and related substances in products and waste, including sustainable financing mechanisms. This includes listing those substances as banned or restricted substances, setting unintentional trace contaminant limits and low POP content limits, assessing exemptions where needed, and reviewing how other jurisdictions regulate these substances. Extended Producer Responsibility (EPR) is a key instrument to ensure sustainable financing, particularly in electronics, vehicles and construction.
A sectoral approach is essential. More than half of global plastic stocks are located in the electronics, transport and buildings sectors. Managing POPs in these areas is important to improve overall plastic management and support depollution. While a global plastics treaty is still under development, the Stockholm and Basel Conventions can help to fill the gap by implementing ambitious national action plans.
As Dr Weber highlighted: “The right activities to manage POPs in major affected plastic-use sectors can improve overall plastic management in these sectors and lead to depollution.”
Inventory, data and substance flow
No action plan is complete without robust inventories. Countries should refine sectoral inventories for POPs and other chemicals of concern in electronics, vehicles and construction, and assess production, use and stocks. For data management, it is recommended to integrate information on plastics and valuable resources such as metals, which are needed to move towards a circular economy.
Dynamic material and substance flow analysis is particularly useful. It helps policymakers understand how much of a substance has entered a country, where it is stored, when it will reach end of life, and how it moves through recycling and reuse pathways. Such analyses allow time projections – for example, estimating future peaks of POP-containing waste – and support life-cycle-based planning.
Environmentally sound lifecycle management
Sound lifecycle management is a core objective. Action plans should compile information on how POP-containing products and waste are currently managed and assess recycling, separation and destruction options at the national or regional level. Given the large volumes involved, often thousands of tonnes, national or regional treatment solutions are usually more realistic than export.
Separation technologies already exist. In full-scale facilities, brominated, chlorinated and fluorinated plastics can be separated from non-impacted plastics. But these technologies are never perfect, and countries should ensure that recycled plastics do not enter sensitive uses and that contaminated sites are identified and secured.
Alternatives and avoiding regrettable substitution
Alternatives assessment is increasingly important, especially where exemptions remain. Action plans should compile information on chemical and non-chemical alternatives, support education on substitution, and promote sustainable and green alternative chemicals and non-chemical solutions.
Substitution can occur at different levels: replacing a specific flame retardant, changing the resin system, or redesigning the product to eliminate the need for flame retardants altogether. A science-based, life-cycle approach is essential to avoid regrettable substitutions, where alternative flame retardants may also be persistent or hazardous. Periodic review should be conducted to assess the need for continued exemptions and alternatives. Once viable alternatives are available, exemptions should be phased out as soon as feasible.
BAT/BEP and minimizing releases
Where exempted POPs continue to be used, Best Available Techniques and Best Environmental Practices (BAT/BEP) must be applied to minimize release and exposure.
This includes defining release limits, controlling production and waste streams, and considering labeling of products containing exempted POPs to facilitate downstream management. BAT/BEP guidance under the Stockholm Convention provides a range of separation techniques and full-scale recycling plants that are already operating.
Awareness, capacity and enforcement
Education and awareness are critical. Stakeholders, including policymakers, industry, recyclers, customs authorities and the public, need to understand the health and environmental risks associated with POPs and other hazardous plastic additives. Awareness should be embedded within broader discussions on chemicals in products, sustainable consumption and link to the Global Framework on Chemicals.
Capacity building is equally important. Developing regulatory frameworks is only the first step. Effective enforcement requires trained personnel, customs control of e-waste and end-of-life vehicles, and education for workers handling POP-containing materials.
Monitoring and contaminated sites
Monitoring systems should be established for POP flame retardants and other chemicals of concern in products, waste streams and recycling facilities. Where gaps exist, targeted monitoring can improve inventories and risk assessments.
Finally, contaminated sites must be identified, assessed and secured. Open burning and informal dismantling can result in severe contamination of soils, food chains and local communities. While large-scale remediation may be complex and costly, immediate measures – such as restricting access and preventing exposure – can significantly reduce risk. The new Stockholm Convention guidance on contaminated sites provides practical support for this process.
To learn more about the Global NIP Update project, visit Global NIP Update | Green Policy Platform.
For a deeper dive into the GGKP webinar “Activity Options for Action Plans for Brominated, Chlorinated and Other New POPs”, you can access the full recordings and materials here.
This article was curated by Mark Schulman, Content Editor, GGKP, and reviewed by Soomin Bae, Project Support Consultant, GGKP.
