Compliance

Stockholm Convention / POPs Convention

Stockholm Convention

An international treaty that targets Persistent Organic Pollutants (POPs) for global elimination, restriction, or unintentional-release reduction. Adopted in 2001 and entered into force in 2004, the convention currently lists 34 POPs across three annexes. Annex A (elimination), Annex B (restriction), and Annex C (unintentional production). Unlike the Rotterdam Convention, Stockholm phases chemicals out of trade rather than enabling informed consent for trade.

Updated May 2, 2026

The Stockholm Convention is an international treaty that targets Persistent Organic Pollutants (POPs) for global elimination, restriction, or unintentional-release reduction. Adopted on 22 May 2001 and entered into force on 17 May 2004, the convention is administered by the United Nations Environment Programme (UNEP) and the secretariat in Geneva. The convention currently lists 34 POPs across three annexes. Unlike the Rotterdam Convention, which enables informed consent for trade in 55 listed chemicals, Stockholm phases POPs out of production, use, and trade entirely, with limited specific exemptions for parties that need transitional time.

What Stockholm targets

Persistent Organic Pollutants share four characteristics:

  1. Persistent, they resist environmental degradation and remain in soil, water, sediment, or biota for years to decades
  2. Bioaccumulative, they concentrate up the food chain in fatty tissues
  3. Toxic, they cause harm to human health and the environment
  4. Subject to long-range transport, they travel atmospherically across continents, contaminating regions far from any source

The original 12 POPs (the “dirty dozen” listed in 2001) were the most damaging legacy chemicals: aldrin, chlordane, DDT, dieldrin, endrin, heptachlor, hexachlorobenzene, mirex, toxaphene, polychlorinated biphenyls (PCBs), and three categories of unintentional by-products (dioxins, furans, hexachlorobenzene). Subsequent COPs have added 22 more substances.

The three annexes

AnnexActionExamples
A. EliminationPhase out production, use, import, and exportDDT (with health-use exemption), chlordane, mirex, toxaphene, PCBs, lindane, hexabromocyclododecane (HBCD), short-chain chlorinated paraffins (SCCPs), perfluorohexane sulfonic acid (PFHxS)
B. RestrictionRestricted uses with specific allowancesDDT for malaria vector control under WHO guidelines; perfluorooctane sulfonic acid (PFOS) for specific industrial uses
C. Unintentional productionReduce or eliminate by best available techniquesDioxins, furans, hexachlorobenzene, polychlorinated naphthalenes

A chemical added at a COP enters one of the three annexes. The most stringent (Annex A) requires complete phase-out. Annex B allows continued use under specific conditions. Annex C addresses by-products that cannot be directly traded but can be reduced through process improvement.

Specific exemptions and acceptable purposes

When a chemical is added to Annex A or B, the COP can grant specific exemptions for parties that need transitional time. A party can register for a specific exemption when the chemical is listed; the exemption typically lasts 5 years and can be extended in 5-year increments through subsequent COPs.

For example:

  • DDT: Annex B with a specific exemption for disease vector control under WHO guidelines. Several malaria-endemic countries hold this exemption.
  • PCBs: Annex A with elimination of production but a phased exemption for in-use closed systems (transformers, capacitors) until 2025-2028 depending on country.
  • PFOS and related: Annex B with specific exemptions for fire-fighting foams, photographic processing, and certain industrial applications.

Specific exemptions are listed in the publicly available register maintained by the secretariat. An exporter shipping a Stockholm-listed chemical must verify the importing country still holds the relevant specific exemption; an expired exemption means import is now prohibited.

How Stockholm interacts with Rotterdam

A chemical can be listed under both Stockholm and Rotterdam simultaneously. The two treaties do different work:

TreatyScopeMechanism
Stockholm34 POPsPhase-out / restriction / unintentional-release reduction
Rotterdam55 hazardous chemicals and pesticidesPrior Informed Consent for trade

Some Stockholm-listed chemicals are also on Rotterdam Annex III (PCBs, lindane, mirex, hexachlorobenzene, certain PFOS-containing chemicals). For these dual-listed chemicals:

  • Stockholm imposes the production and use restriction
  • Rotterdam imposes the trade-side PIC requirement (where any trade still occurs under specific exemption)

A chemical with no remaining Stockholm exemption is effectively prohibited from international trade. PIC consent for an Annex A chemical is irrelevant if the chemical cannot be produced, used, or exported anywhere.

What Chinese exporters must do for Stockholm-listed chemicals

China is a party to the Stockholm Convention (ratified 13 August 2004). For Stockholm-listed chemicals:

  • Annex A chemicals: production and use are prohibited in China. A factory still holding inventory must dispose of it under hazardous waste rules. Export is prohibited except where China holds a specific exemption.
  • Annex B chemicals: production and use are restricted to the specific exemption purposes. A factory producing such chemicals must hold the relevant Chinese authorisation.
  • Annex C chemicals: focus is on emission reduction at the production site, not on trade restriction directly.

The Chinese implementation is administered by MEE acting through the National Implementation Plan for the Stockholm Convention. The Solid Waste and Chemicals Management Center is the operational authority.

For a Chinese factory still producing a Stockholm-listed chemical under exemption, the export documentation must include:

When Stockholm catches exporters off guard

Three failure patterns recur:

  1. Specific exemption expiry. A factory continues producing under an exemption that has lapsed. The first hint is often when an importing country flags the cargo as non-conforming. By that point the inventory is sunk cost and the contract is in dispute.
  2. New chemical added at COP. A chemical previously freely traded is added to Annex A at a COP. The treaty allows transition time (typically 12-24 months), but factories not following the convention process do not see the listing coming. Production continues until the import-side ban triggers.
  3. PFAS expansion. The convention has progressively added perfluoroalkyl substances (PFOS in 2009, PFOA in 2019, PFHxS in 2022) and is considering further additions. Factories using PFAS chemistry in coating, fluoropolymer production, or fire-fighting foam should track the COP outcomes closely. The trajectory is expansion, not contraction.

Stockholm’s relationship to REACH and TSCA

REACH and TSCA operate domestically; Stockholm operates globally. The interaction:

  • A Stockholm-listed chemical is typically also REACH-restricted under Annex XVII or Annex XIV (the SVHC authorisation list)
  • TSCA does not have a direct Stockholm-implementation track; the EPA implements Stockholm through ad-hoc rulemaking under TSCA Section 6 for each newly listed chemical
  • The effective restriction in any major market combines the domestic regime and the convention; the more restrictive of the two is what the exporter must satisfy

Rotterdam Convention is the parallel treaty that uses the PIC procedure for trade in 55 listed chemicals. REACH, TSCA, and SVHC are the parallel domestic chemical regimes. MEE China is the Chinese authority. IMDG Class 9 is the transport classification most often associated with POPs in transit.

Reference: https://www.pops.int/

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