Waste containing POP substances: Overview and applicable management strategies

Synthesis

Disclaimer: The content of this publication is based on the state of knowledge and the regulatory framework in force at the time of publication of the documents.

Context of the study

Persistent organic pollutants (POPs) are chemical substances presenting serious risks to the environment and human health. Their persistence, bioaccumulation’s tendency, and toxicity make them particularly concerning. These chemicals have been intentionally produced (such as pesticides or POPs added for their properties in the manufacturing industry) or unintentionally released into the environment (through waste or biomass incineration, implementation of industrial processes). Among those intentionally produced, some have been widely used by industry and are now found in various products, particularly as flame retardants, plasticizers, and preservatives.

The international regulatory framework for POPs was established in the 1990s with the Aarhus Protocol (1998) and the Stockholm Convention (2001). These agreements aim to control, reduce, or eliminate POP emissions due to their significant impacts on health and the environment. The Aarhus Protocol focuses on reducing POP releases into the atmosphere, while the Stockholm Convention emphasizes the gradual elimination of substances listed in its annexes. These conventions constitute the basis of European and national regulations governing the management of POP-containing waste.

At the European level, Regulation (EU) 2019/1021 is the primary reference. This regulation, which replaces Regulation (EU) 850/2004, prohibits the use of numerous POP substances and imposes strict restrictions on their waste management. France, as an EU member state, has aligned its directives with this regulatory framework, implementing control mechanisms and rigorous analysis protocols to monitor the presence of POPs in certain waste streams, particularly in incinerators.

Objective and Study Plan

The main objective of this study is to provide a comprehensive overview of current knowledge on POPs in waste, analyse trends in the flow of products and waste containing these substances, and draw up recommendations for improved waste management. The study is structured into three main phases:

• Literature review and regulatory analysis: This initial phase involves examining international, European, and national regulatory frameworks, in order to compare the case of France with other countries, as well as the scientific literature on POP waste management.
• Waste flow analysis: The second phase focuses on producing an overview of products and waste that may contain POPs, assessing the corresponding content where available, and quantifying waste containing POPs for a few flows where this level of traceability exists.
• Identification of future pops and recommendations for enhanced waste management: Based on the literature review and consultations with stakeholders, this phase identifies various substances that may be included in POP regulations in the future. The study then proposes strategies to enhance future POP waste management practices, taking into account emerging, non-regulated substances, and formulates recommendations to optimize waste management practices.

Presentation of Main Results

Literature Review and Regulatory Analysis

Regulatory frameworks for POPs are defined across multiple levels:

• Internationally, the Stockholm Convention has established criteria for identifying POPs, focusing on toxicity, bioaccumulation, and persistence. This treaty aims to eliminate or restrict the use of substances listed in its annexes. The Aarhus Protocol, in contrast, emphasizes reducing atmospheric emissions of POPs by setting emission limit values (ELVs) for fixed sources, such as incinerators.
• In Europe, Regulation (EU) 2019/1021 imposes strict restrictions on the production, marketing, and use of POPs. It also defines concentration thresholds to classify certain waste streams as POP waste, requiring specific treatment methods. This regulation has been revised several times to include new substances, notably perfluoroalkyl substances (PFAS), which present new challenges due to their diversity and high persistence.
• In France, national regulations are aligned with European directives, featuring rigorous monitoring mechanisms, especially for incinerated waste streams. Incinerators must comply with emission limits for dioxins and furans, and emission control techniques are continually enhanced to meet regulatory requirements.

Current research indicates that POPs remain prevalent and widespread in products despite bans and restrictions. Flame retardants, such as polybrominated diphenyl ethers (PBDEs), are frequently found in the plastics of electronic devices and insulation foams. These substances can be released during waste treatment processes, contributing to pollution of air, soil, and water. However, scientific literature tends to focus on specific products and waste types, such as electronic equipment and vehicles, with fewer studies analysing a broad range of products and waste types. Some studies examine only the presence of POPs in air or deposited dust, without identifying their sources.

Managing waste containing POPs is complex for several reasons. First, identifying POPs within waste streams is challenging due to a lack of traceability regarding POP incorporation by producers and the diversity of potentially affected products. Second, the analytical techniques used to identify the substances (such as gas chromatography with electron capture detection and high-resolution mass spectrometry) are costly and require specialized expertise. They are therefore not applicable to current waste management processes. For flame retardants, a simplified analysis technique is used on crushed plastics, using X-ray fluorescence spectrometry to identify the total bromine content. Although non-POP substances can sometimes interfere, this technique efficiently identifies plastics with high enough POP levels to be classified as POP waste. Finally, recycling materials contaminated with POPs poses a significant risk. For example, brominated flame-retardant plastics, if recycled, may reintroduce POPs into new products, extending their lifecycle and increasing exposure risks.

Waste Flow Analysis

A literature review was conducted to cover a wide range of products and waste types and to assess the likelihood of POP content. Intentionally added POPs generally fulfil specific material needs, so research was categorized by material type. For example, vehicles were analysed under both plastics and textiles. This research enabled the development of an overview, presented in Figure 1, identifying various relevant products and waste types and their likelihood of containing POPs.

Figure 1: Breakdown of POPs by sector of activity (RECORD, 2024)

According to the collected values in the literature, the presence and levels of POPs in waste vary significantly depending on the product and its manufacturing date, as production methods and regulations have evolved. For instance, older generations of plastics and electronic equipment often contain higher levels of flame retardants, which are now banned or restricted, his is the case with CRT monitors. Data shows that concentrations of POPs can exceed regulatory thresholds in these wastes, which are then classified as POPs waste.

A few other streams may be subject to the presence of POPs, such as electrical cable insulation: the crushed plastic in these cables sometimes contains excessively high levels of flame retardants. As we saw earlier, the literature focuses on certain flows that have a high level of traceability for waste management (in particular, those covered by EPR schemes in Europe). There remains, therefore, a wide range of products and wastes that are poorly or not at all covered by quantitative analyses of POP content.

In order to assess the quantities of POP waste to be managed in the future, research has been carried out to collect product consumption and waste collection data and consumption trends. However, these values are only available for a few specific streams, and it has not been possible to assess the proportion of POP waste within these streams, including those covered by EPR schemes. The Trackdéchets tool, used in France to track hazardous waste, proved inadequate for this study, as it does not yet provide complete statistical data on the tonnages and substances present in waste. As a result, it was not possible to model current and future POP waste volumes.

The analyses carried out show that the volumes of waste containing POPs will continue to increase over the coming decades, particularly in the case of WEEE and industrial plastics. This rise is attributed to the increased production of electronic products and the extension of their lifespan, which will delay the elimination of products containing POPs. The analysis also indicates that new, as yet unregulated, types of POPs could appear in future waste streams, requiring ongoing updating of regulations and management methods.

Identification of future pops and recommendations for improved waste management

Having ratified the Stockholm Convention, France is obligated to consider any new substances classified as POPs by the convention within its regulatory framework. The process of including a new substance on the POPs list under the convention can take several years (approximately five), from the proposal submission to the effective list modification (see Figure 2 for the steps). The timeline may vary depending on the timing of submissions (proposal, risk description, risk management evaluation) to the POPs Review Committee. Each submission follows a precise protocol describing the properties of the substance concerned. The initial submission focuses on the main criteria defining a POP under the convention: persistence, bioaccumulation, long-range environmental transport potential, and toxicity. Subsequent inputs address more specific points, such as environmental fate, regulatory status, alternative solutions, waste management impacts, etc.

Figure 2: Process for adding new substances to the Annexes of the POPs Convention and the POPs Regulation (ECHA) (RECORD, 2024)

Currently, 4 substances are under review, and 3 have recently been added to the convention and are awaiting inclusion in POP regulations. 

Perfluoroalkyl substances (PFAS) are identified as a priority due to their widespread industrial use for water- and stain-resistant properties. Notably, the PFAS family includes over 4,000 substances, and over 7 million according to some sources. The compounds that can be categorised as PFAS are still being determined today, while some are already regulated as POPs under the convention and POP regulations. The literature shows that many of these substances exhibit extreme environmental persistence and bioaccumulate in living organisms, highlighting a major issue for waste management to limit their environmental dispersal. Various countries are currently working on regulatory frameworks around these substances to limit their impact and ultimately incorporate them into the convention.

An analysis of the process for including new POPs reveals limitations in the current system: adding substances is particularly lengthy and resource-intensive for stakeholders, with only a few countries possessing the resources to advocate for the inclusion of new substances. This timeline does not align well with industry developments, where substitutes for POPs are often identified that may present similar environmental and human health challenges.

Several major challenges have been identified in the current management of POP-containing waste. Chemical traceability throughout the product lifecycle remains inadequate, particularly for imported products that may contain unidentified POPs. This lack of traceability complicates waste sorting and increases the risk of POP dispersion in recycling streams, thereby compromising health and environmental safety. Collecting and sorting infrastructure are sometimes undersized or lacks the facilities needed to identify and separate POP waste.

The following actions are recommended to strengthen POP waste management and address emerging substance challenges:

• Optimize and Ensure Traceability of POPs in Products and Waste: Establishing digital systems for tracking chemical substances, including mandatory labelling of POP-containing products, would facilitate waste stream identification and sorting operations. Furthermore, a standardized protocol should be defined for product and waste analysis to verify the presence of POPs in their matrices. This protocol could then be applied to various products and waste in a broad compliance verification campaign.
• Enhance Waste Treatment Processes: It is essential to train waste producers, workers in a collecting centre, and treatment operators to ensure safe and effective handling of POP-containing waste. These training programs should cover the specific hazards of POPs, waste identification, safety protocols, and treatment methods, supported by practical guides and informational videos for all participants. Additionally, waste analysis technologies should be updated, and research and development efforts should be strengthened to adopt innovative techniques aligned with best available practices.
• Strengthen and Ensure Regulatory Compliance: To reinforce the correct application of POP regulation, rapid analysis methods should be implemented, and stricter penalties imposed on violators, involving eco-organisations in the monitoring and sorting of POP-containing products. Enhanced import controls and frequent revisions of regulatory thresholds would also help limit POP entry and circulation, while total bans on these substances, combined with safe alternatives, remain the long-term goal.
• Reduce POP Use in Various Industries: Encouraging industries to develop POP-free alternatives in manufactured products is crucial to limiting dependency on these substances. Supporting research into substitute products and implementing financial incentives will support this transition. For a significant impact, these efforts must be coordinated internationally, requiring harmonized regulations, strengthened monitoring, and deterrent measures to ensure compliance with regulations.

Improved coordination among waste management stakeholders is considered essential to increase the effectiveness of initiatives. Within Extended Producer Responsibility (EPR) systems, eco-organisations play a key role by connecting waste managers, regulatory authorities, and manufacturers. These actors must collaborate to implement standardized systems for tracking and controlling hazardous substances.

Analysis and Commentary on Results

Significant progress has been made in POP regulation over the past 20 years; however, substantial challenges remain to ensure effective management of POP-containing waste. Current regulatory frameworks have successfully limited the use of the most hazardous substances and enhanced waste treatment requirements. Nonetheless, insufficient traceability and technological limitations complicate the identification and sorting of contaminated waste, increasing the risk of POP dispersion into the environment. Additionally, the slow adaptation of regulated substance lists limits the ability to effectively respond to new threats posed by emerging substances such as PFAS.

To overcome these obstacles, it is essential to strengthen the traceability of POPs throughout their lifecycle by implementing a standardized, economically viable protocol, and to promote innovation in substitute products. Harmonized practices across Europe, along with close collaboration among regulators, industries, and EPR organizations, are needed to ensure sustainable management in line with public health and environmental protection goals.

Conclusions

The findings reveal significant disparities in knowledge and management practices for POP-containing waste, depending on the types of products and substances involved. Despite stringent regulations, POPs remain present in numerous products and waste streams, often due to non-compliance of imported products, poorly characterized legacy waste, and the use of recycled materials. Data analysis proved complex, with inconsistent findings across studies, particularly for long-lived products whose manufacturing processes have evolved over time.

Current challenges related to POPs are further exacerbated by the continuous expansion of the list of regulated substances, requiring adjustments in both waste analysis and management methods. Insufficient traceability, the diverse origins of products, and international supply chains complicate the tracking and treatment of POP-containing waste.

To address these challenges, the primary recommendations include improving traceability through standardized and regular analysis of diverse waste streams, strengthening controls, particularly for imported products, developing more effective waste treatment protocols, and promoting POP-free alternatives in industries. These measures are essential to reduce environmental and health impacts and to ensure a more sustainable approach to waste management.