Developing Integrated Action Plans for NIPs 2: Polychlorinated Biphenyls (PCBs) and Polychlorinated Naphthalenes (PCNs)

Authors :

Roland Weber, POPs Environmental Consulting

This blog post is based on the presentation and remarks of Dr. Roland Weber on the Global Green Growth Knowledge Partnership (GGKP) webinar “Activity Options for Action Plans on the Management and Elimination of PCBs and POP Pesticides” held on 16 December 2025.

Linking POPs to the Triple Planetary Crisis

Currently, thirty-seven Persistent Organic Pollutants (POPs) are listed under the Stockholm Convention. However, these represent only the "tip of the iceberg" considering that an assessment of 100,000 chemicals in production indicated that more than 570 chemicals likely met the Stockholm Convention POP criteria. With approximately 350,000 chemicals now in production and over 13,000 related to plastics (UNEP 2023), chemical production is projected to quadruple between 2020 and 2060 according to OECD. Recent studies conclude that "novel entities," including plastic pollution and chemicals of concern like per- and polyfluoroalkyl substances (PFAS), have already crossed planetary boundaries.

This reality ties directly to the triple planetary crisis of climate change, biodiversity loss, and pollution. For instance, open burning of waste containing POPs contributes to greenhouse gas emissions, while substances such as polychlorinated biphenyls (PCBs), dichlorodiphenyltrichloroethane (DDT), and other POPs drive population collapse in top predators like eagles and killer whales.

Integrated Approach and Life-Cycle Management

To effectively address these intersecting challenges, an integrated approach is essential. National Implementation Plans (NIPs) should not treat POPs in isolation but should align with broader frameworks such as the Basel, Rotterdam, and Minamata Conventions as well as the Global Framework on Chemicals, the Biodiversity and the Climate Convention (GFC). This approach generates "win-win" outcomes. For example, replacing old PCB transformers with energy-efficient models reduces both carbon and POP emissions.

Effective management involves controlling POPs across their entire life cycle from production and import to recycling and disposal. Strengthening national coordination mechanisms and incorporating gender dimensions—ensuring the participation of women in sectors such as agriculture and manufacturing where exposure risks are high—are essential enabling activities.

Action Plans, Lessons, and Continuous Improvement

Action plan activities can be identified early, during POP inventory development. Inventory reports may include a chapter outlining suggested action plan activities. During this stage, also communication among ministries, agencies, and stakeholders should be assessed and strengthened.

Action plans may contain both POP-specific and cross-cutting activities—such as monitoring, contaminated site assessment, or awareness raising—designed to address shared challenges across chemical categories. Reviewing previous NIPs provides an opportunity to refine strategies, update outdated measures, and integrate lessons learned from earlier implementation efforts. Within the NIP structure, Chapter 3 outlines strategy and action plan elements, including a policy statement, implementation strategy, and detailed action plans that specify objectives, activities, performance indicators, timelines, responsible entities, and research needs.

Historic Production and Applications of PCBs

PCBs have been used in a wide range of closed and open applications since 1929. Closed applications primarily involve transformer oils, capacitors, and hydraulic oils, while open applications include sealants, paints, and cutting oils which are particularly relevant for exposure and environmental release. Overall, approximately 1.3 million tonnes of PCBs were produced between 1929 and 1990. About 50% of all production went into transformer oils and around 21% went into small capacitors. While open applications represented 21% of use and remain relevant today, they were mainly utilized in industrial countries.

Urgent Stockholm Convention Deadlines

The Stockholm Convention Annex A establishes clear priorities for the elimination of the use of PCBs in equipment by 2025. This deadline has passed, and therefore these substances should be eliminated from use as soon as possible. Furthermore, each Party shall make determined efforts designed to lead to the environmentally sound waste management of liquids containing PCBs and equipment contaminated with PCBs above 50 milligrams per kilogram no later than by 2028. For the whole PCB management process, there are only around three years remaining to meet this global goal.

Polychlorinated Naphthalenes (PCNs) and Integrated Management

PCNs were listed in 2015 and were used in the same closed and open applications as PCBs, mainly from the 1930s to the 1960s. As they were only produced in volumes of about 150,000 tonnes, industrial PCNs have lower overall relevance compared to PCBs. Remaining PCNs can be managed within the existing PCB management framework. They are detected by chlorine test kits for screening and can be integrated into instrumental settings using gas chromatography. Levels of PCNs in breast milk are two to three orders of magnitude lower than PCBs, showing their considerably lower relevance for average human exposure.

As Weber emphasized, "Breast milk is still the ideal food for infants, and the World Health Organization (WHO) recommends that children be exclusively breastfed for the first six months despite these POPs in the human milk".

Regulatory Frameworks for PCBs and PCNs

For developing and implementing a legislative framework, policy and measures for control and management of PCBs and PCNs in both closed and open applications, recommended activity options include assessing the performance of the current regulatory frame and establishing penalties or fines for improper management or late submission of progress reports. Another option for the regulatory framework is the extended producer responsibility (EPR) and the polluter pays principle (PPP). Historically, five companies produced 90% of all PCBs in the world. Considering these principles, these companies should contribute to the global management of PCBs, as seen in the United States where billions of dollars are paid for PCB contamination especially of schools/buildings and related exposure in recent years.

PCBs are also unintentionally formed in some chemical processes and exist as contaminants in products such as pigments, dyes, or silicone products. Setting unintentional trace contaminant (UTC) limits for chemicals, mixtures, and products, with low POPs limits for reuse and recycling is recommended. The Basel Convention limit of 50 milligrams per kilogram is too high for some recycling flows, such as waste wood or construction and demolition waste, where it could contaminate food and the environment. The European POP Directive has developed and included UTC limits for all POPs, and proposed UTC limits for PCB in a draft legislation are expected to enter soon into force.

Developing Robust Inventories

The development and update of a robust PCB inventory is a high priority for being considered for the next phase of Global Environment Facility (GEF) and World Bank projects. It is recommended to generate one central database for all relevant transformers and capacitors to track liquid weight, PCB content, and equipment condition. This database is best hosted by the utility sector, with the Ministry of Energy and Ministry of Environment having access for national reporting and NIP updates. This robust data is essential to evaluate management progress toward the 2025 phase-out and 2028 elimination targets.

Life-Cycle Management and Contaminated Site Remediation

Recommended activities for sound life cycle management entails assessing the current status and the need for improvement of handling, transport, storage, and disposal of PCB or PCN containing equipment. One big challenge in developing countries is sustainable financing, but a win-win situation exists when phasing in new, more energy-effective transformers. The money invested can be saved ten times over the lifetime of the equipment.

Additionally, PCB contaminated sites are large legacies of the past 100 years and must be systematically identified and inventoried. Recommended activities include identifying sites along the entire life cycle from production to maintenance areas and scrapyards to prevent the contamination of the environment and food products. The recent established Stockholm Convention Best Available Techniques and Best Environmental Practices (BAT/BEP) guidance on POPs contaminated sites can support in this activity.

Analysis and Monitoring of PCBs and PCNs

Establishing analytical and monitoring capacity is vital for promoting the phase-out and management of PCBs. Monitoring of occupational exposure for staff managing PCB equipment can be performed using non-invasive methods, such as analyzing hydroxylated polychlorinated biphenyls (OH-PCBs) in urine to ensure personal protective equipment is used appropriately. This approach allows for the detection of exposure even for individual shifts, informing workers of the need for better protective measures.

Furthermore, countries are recommended to assess their options for monitoring PCBs and PCNs within their region, deciding whether to establish independent analytical capacity or utilize regional and international laboratories. Robust data from the monitoring of equipment and waste oils are key for securing GEF funding. Monitoring activities can also extend to open applications and other matrices to assess contaminated sites and products like recycled oils, pigments, and dyes.

Awareness-Raising and Assessment of Alternatives

The activities for awareness-raising and education can be established by relevant stakeholder groups. Education on the health hazards of PCBs, as well as the related risks to human health, the environment, and food security, is recommended for policy makers. Strengthening the inspection capacity for customs and other competent authorities, such as those responsible for market surveillance and consumer protection, ensures better oversight of PCBs and PCNs. Additionally, education to the utility sector, maintenance workers, and industries that own PCB or PCN equipment and waste is important. For citizens, vulnerable groups, and non-governmental organizations, education on open applications relevant for consumers within broader awareness on POPs and other chemicals of concern is recommended.

Recommended actions for assessment and promotion of sustainable alternatives for PCBs and PCNs include the compilation of information on former closed and open applications to evaluate the effectiveness of current alternatives. In closed applications, the promotion of the most sustainable options should consider both chemical safety and energy efficiency, such as the use of energy-efficient transformers. For open applications, it is vital to promote green alternatives and ensure that PCBs are not substituted with other harmful chemicals like chlorinated paraffins.

As the 2025 Stockholm Convention deadline passed and the 2028 deadlines approaches, countries must intensify efforts to eliminate PCBs along with possibly remaining PCNs from use and ensure their environmentally sound disposal. Strengthening regulatory frameworks provides the legal foundation for sound management, while building robust inventories through centralized databases ensures accurate tracking toward targets and helps secure international financing. Advancing life-cycle management, alongside systematic identification and remediation of contaminated sites, protects human health and prevents environmental contamination.

In parallel, establishing analytical and monitoring capacity provides the data needed to secure co-financing and track progress, while raising awareness among policymakers, utility sectors, maintenance workers, and vulnerable communities fosters informed decision-making and safer practices. Assessing and promoting sustainable alternatives is vital for a holistic response to the triple planetary crisis of climate change, biodiversity loss, and pollution. Developing integrated action plans within NIPs allows countries to move beyond Stockholm Convention compliance by linking POPs management to broader chemicals and waste frameworks, paving the way for a more sustainable future.

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 on the Management and Elimination of PCBs and POP Pesticides”, you can access the full recordings and materials here: https://www.greenpolicyplatform.org/webinar/activity-options-action-plans-management-and-elimination-pcbs-and-pop-pesticides

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