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.
Short-chain chlorinated paraffins (SCCPs; C10 to C13) with a chlorine content >48% were listed under Annex A of the Stockholm Convention in 2017 with a wide range of exemptions. Medium-chain chlorinated paraffins (MCCPs; C14-C17) with a chlorine content ≥45% were subsequently listed in 2025, also with broad exemptions. Together, they constitute one of the highest-volume groups of newly listed persistent organic pollutants (POPs), widely found in plastics, rubber, lubricants and building materials, with extensive applications across the electronics, transport and construction sectors as well as other uses.
Production of chlorinated paraffins has increased sharply over the past two decades, exceeding 1 million tonnes annually since around 2010. Current production is estimated at roughly 1.4 million tonnes per year, with global capacity above 2 million tonnes, bringing cumulative production close to 40 million tonnes by 2026.
Given these volumes, SCCPs and MCCPs are now present in quantities exceeding those of many other POPs combined. Action plans under National Implementation Plans (NIPs) on SCCPs and MCCPs must address not only regulatory compliance, but also large-scale material flows and future recycling challenges.
Regulatory framework and exemptions
Any action plan should begin with the establishment or strengthening of a national regulatory framework for the use, management and substitution of SCCPs and MCCPs in industrial uses, products and waste. This includes reviewing existing legislation, setting low POP content limits and unintentional trace contaminant (UTC) limits, and aligning with international practices, such as the European Union (EU) POP Regulation.
For MCCPs, countries must also assess which exemptions are needed and ensure that any exemption is justified through a science-based assessment. Notifications to the Secretariat of the Basel, Rotterdam and Stockholm (BRS) Conventions should clearly state the type of exemption, estimated quantities, purpose and justification. While SCCP exemptions have expired, MCCP exemptions – including for flexible PVC, certain rubber products, certain adhesives and sealants, metalworking fluids, specific defense-related applications and some further uses – may extend production and use until at least 2031, and for metalworking fluids until 2036.
Customs control, labelling and traceability systems are essential, particularly as many countries are importers rather than producers. The possible introduction of Extended Producer Responsibility (EPR) schemes can also support financing and lifecycle control.
Refining the inventory: linking past and present uses
Robust inventories are the backbone of an effective action plan. Countries should identify companies producing chlorinated paraffins, the mixtures they produce, and their customers and uses. Import data should be cross-checked using CAS numbers, as harmonized system (HS) codes are not specific.
Inventories should also assess SCCP and MCCP presence in products such as plasticized PVC articles, rubber, polyurethane spray foams, sealants, lubricants and paints, as well as recycling streams including PVC, cables, rubber and waste oil. Material and substance flow analysis can help quantify stocks, identify future waste peaks and guide long-term planning.
A strategic recommendation is to combine SCCP/MCCP inventories with assessments of former uses of polychlorinated biphenyls (PCBs) and polychlorinated naphthalenes (PCNs) in open applications. SCCPs and MCCPs substituted PCBs and PCNs in many applications in the 1960s and 1970s, particularly in sealants, paints and cutting oils. Remaining PCBs and PCNs in buildings can therefore be assessed alongside current chlorinated paraffin uses, improving efficiency and coherence.
Alternatives and substitution
Assessment of alternatives is a central pillar of phase-out. Countries should compile information on chemical and non-chemical alternatives for exempted uses and assess which are available nationally. Education and capacity-building on alternative assessment are equally important.
Substitution should prioritize the most sustainable solution, avoiding regrettable substitutions. Periodic review of exemptions is necessary to ensure that, once viable alternatives exist, exemptions are discontinued as soon as feasible.
BAT/BEP and lifecycle control
Where exempted uses continue, Best Available Techniques and Best Environmental Practices (BAT/BEP) must be applied to minimize releases and worker exposure. This is particularly important for open uses such as metalworking fluids and fatliquors, where exposure risks are significant.
Lifecycle management should address import, production, use, recycling and disposal. Recycling streams pose particular challenges. SCCPs and MCCPs are present in flexible PVC, rubber products, construction materials and oils. Without proper control, these substances may circulate in recycled materials, undermining depollution efforts. Notably, recycling exemptions for MCCPs were discussed in the POP Review Committee, but not recommended to the twelfth meeting of the Conference of the Parties (COP12) to the Stockholm Convention, underscoring the need for strict control.
Monitoring, awareness and contaminated sites
Monitoring is indispensable. Without analytical capacity, it is impossible to identify contaminated products or control imports and recycling. However, SCCP/MCCP analysis is technically more complex than PCB analysis. The updated Stockholm Convention guidance on monitoring POPs in products and recycling includes low- and high-resolution methods suitable for different contexts.
Case studies from the EU demonstrate that SCCPs have been found above the regulatory UTC limit in toys, sports equipment, cables and other consumer products. At the same time, human milk monitoring indicates rising SCCP/MCCP levels in several regions, with particularly high levels observed in lower-income countries. While mother’s milk remains the best nutrition for infants, these findings underline the urgency of action.
Action plans should address contaminated sites along the lifecycle of SCCPs and MCCPs, including production sites, industrial use sites and end-of-life treatment areas. Mapping, prioritization and environmentally sound remediation are essential components.
Towards an integrated approach
SCCPs and MCCPs exemplify the importance of integrated and lifecycle-based approaches. Their large production volumes, widespread applications and partly long service lives require integrated action across regulatory, technical and financial domains.
In the absence of a comprehensive global plastics treaty, robust NIP action plans can drive meaningful progress. By combining regulatory reform, inventory development, alternatives assessment, BAT/BEP implementation, lifecycle management, monitoring and awareness-raising, countries can manage and phase out SCCPs and MCCPs effectively – protecting human health while advancing towards a more circular and less contaminated economy.
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.
