Correction of Regulation COPs 2026: what chemical industry and waste managers must review

Key data

Companies operating under Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) have an immediate obligation: to review the corrected text published on October 6, 2026. The correction—identified as CELEX:32019R1021R(04)—rectifies material errors in the original standard, which means that the values, limits or procedures a company has been applying until now could have changed without its knowledge.

POPs are chemical substances that accumulate in the environment and in living organisms causing serious damage. That is why the original regulation establishes strict restrictions on their production, use and release, as well as specific rules for their management as waste. A correction of material errors in this context is not a minor formality: it can modify the numerical thresholds that determine whether a company complies or fails to comply with the standard.

What does this regulation establish?

Regulation (EU) 2019/1021 is the European reference framework for controlling persistent organic pollutants. It regulates three main areas:

• Production and use: Restrictions on which POPs substances can be manufactured or used, and under what conditions.
• Release to the environment: Limits and obligations to prevent emissions of these substances in industrial processes.
• Waste management: Specific rules for the treatment, storage and disposal of waste containing POPs.

The correction CELEX:32019R1021R(04) rectifies material errors detected in the current text. According to published information, technical corrections may affect permitted concentration limits and waste management procedures for waste containing POPs. This implies that the numerical values or procedural steps a company currently applies may not match the legally valid text after the correction.

To find out exactly which values or procedures have been corrected, it is essential to consult the full text of the correction on EUR-Lex and compare it with the previous version of the regulation.

Economic and operational impact

The impact of this correction is not homogeneous: it depends on whether the corrected errors affect the concentration limits that each company applies or the procedures it follows to manage its POPs-containing waste.

• Modified concentration limits: If the correction adjusts a numerical threshold, a company that was in compliance may move to non-compliance—or vice versa—without having changed anything in its operations. This requires an immediate review of internal analyses and controls.
• Modified waste management procedures: A change in the steps required to treat or dispose of waste containing POPs may involve additional adaptation costs: new protocols, staff training, updating contracts with external managers or investment in equipment.
• Risk of administrative sanctions: Non-compliance with Regulation (EU) 2019/1021 may result in significant administrative sanctions. Operating with outdated procedures or thresholds—even if due to ignorance of the correction—does not exempt from responsibility.
• Impact on audits and certifications: Companies with certified environmental management systems (ISO 14001, EMAS) must update their internal documentation to reflect the corrected text, or they risk non-conformities in their next audits.

Who does it affect?

• Chemical industry: Manufacturers and distributors of substances that may contain or generate POPs as a byproduct.
• Waste managers: Companies authorized for the treatment, storage, transport or disposal of waste containing persistent organic pollutants.
• Industrial manufacturers: Companies in sectors such as metallurgy, paper, textiles, plastics or electronics that use or generate POPs in their production processes.
• Compliance and HSE managers: Professionals responsible for keeping their organizations' environmental compliance up to date.
• CFOs and operations directors: Due to the potential economic impact of operational adaptations or sanctions resulting from non-compliance.

Practical example

Imagine an industrial components manufacturer that generates waste with traces of POPs substances in its production process. Until October 6, 2026, it applies the concentration limits and waste management procedures according to the text of Regulation (EU) 2019/1021 that it had on file.

Following the publication of the correction CELEX:32019R1021R(04), one of the permitted concentration limits has been rectified due to material error. If the company does not review the corrected text and continues to apply the previous value, it will be operating outside the current legal framework—even though it believes it is in compliance. In an environmental inspection, this could result in a sanctioning procedure with significant administrative sanctions, in addition to the obligation to correct the processes immediately.

The same logic applies to a waste manager that has defined its POPs waste treatment protocol according to the original text: if the correction modifies any procedural step, that protocol becomes outdated and must be reviewed before the next operation.

What should companies do now?

1. Download and read the corrected text: Access the correction CELEX:32019R1021R(04) on EUR-Lex and compare it with the version of Regulation (EU) 2019/1021 that the company currently applies. The objective is to identify exactly which concentration limits or procedures have been modified.
2. Review internal concentration thresholds: Compare the values the company uses in its analytical controls with the corrected limits. If there are discrepancies, update the control procedures immediately.
3. Update waste management protocols: If the correction affects waste management procedures for POPs-containing waste, review and update internal protocols, contracts with external managers and monitoring documentation.
4. Inform the HSE and Compliance team: Communicate the changes to those responsible for environment, safety and regulatory compliance so they can update the environmental management system documentation.
5. Verify impact on certifications: If the company has ISO 14001 or EMAS certification, notify the certifying body or internal auditor of the changes to avoid non-conformities.
6. Consult with specialized legal advice: If there is any doubt about whether the changes affect the company's compliance status, consult with a specialist in European environmental law before the next inspection or audit.

Official source

Consult complete regulation on official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32019R1021R(04)