Chlorpyrifos in articles: from 30 September 2026 the limit is 0,01 mg/kg
7 min read
The components you clear through customs on Wednesday, and the fabric already in the warehouse, answer from that day to a threshold that does not yet exist: ten micrograms per kilogram of a substance you do not buy, do not use and have never sought in a bill of materials. Above it the article cannot be placed on the Union market. And importing it, on the definition that counts, already is placing it.
Counting the twenty days
Commission Delegated Regulation (EU) 2026/1423 of 30 June 2026 (OJ L, 2026/1423, 10.9.2026) adds a single entry to Part A of Annex I to Regulation (EU) 2019/1021 on persistent organic pollutants. Article 2 sets entry into force at «il ventesimo giorno successivo alla pubblicazione» (the twentieth day following publication). Published on Thursday 10 September, that day is Wednesday 30 September 2026. No deferred application: entry into force and applicability coincide.
The entry fits on one line. Chlorpyrifos, CAS 2921-88-2, EC 220-864-4, and in the exemptions column one sentence: «Ai fini della presente voce, l’articolo 4, paragrafo 1, lettera b) si applica al clorpirifos presente in sostanze, miscele o articoli in concentrazioni pari o inferiori a 0,01 mg/kg (0,000001 % in peso).» — Article 4(1)(b) applies to chlorpyrifos in substances, mixtures or articles at or below 0,01 mg/kg.
We compared the consolidated texts of 1 January and 30 September 2026, line by line. Beyond the version header only two blocks change, both marked M18: the amending act in the head table, and this entry at the foot of Part A. Nothing else moves. It is the fifteenth consolidated version — counted on the Cellar register, from 02019R1021-20190625 to 02019R1021-20260930, layer number 014 — and it raises the standing question: which text you read, and on what date.
The word that concerns you is «articoli»
Article 3(1) of Regulation 2019/1021 leaves no room: «Sono vietati la fabbricazione, l’immissione in commercio e l’uso delle sostanze elencate nell’allegato I, sia allo stato puro che all’interno di miscele o di articoli» — manufacturing, placing on the market and use are prohibited — alone, in mixtures, or in articles. The three words that count are the last of that list.
An «articolo» is not a chemical. REACH defines it by «una forma, una superficie o un disegno particolari che ne determinano la funzione» — a shape, surface or design that determines its function more than chemical composition does: a gasket, a cable, a garment, a crate, a panel. The term «immissione in commercio» comes from REACH too, with the sentence that decides the case: «L’importazione è considerata un’immissione sul mercato» (import is deemed to be placing on the market). An importer is not downstream of the prohibition: they are inside it from day one, for a substance on none of their purchase orders.
The Convention allows exemptions. The Union takes none
The route runs from Stockholm. Recital (3) records that the Conference of the Parties, meeting «dal 28 aprile al 9 maggio 2025», decided to amend Annex A to the Convention «per includervi il clorpirifos con deroghe specifiche» — to include chlorpyrifos with specific exemptions — and that the Union had supported that line in Council Decision (EU) 2025/868 of 23 April 2025.
Recital (5) shuts the door. Chlorpyrifos is approved in the Union neither in plant protection products nor in biocides, under Regulations (EC) No 1107/2009 and (EU) No 528/2012, and so: «È pertanto opportuno inserire il clorpirifos nell’elenco dell’allegato I del regolamento (UE) 2019/1021 senza deroghe specifiche.» — chlorpyrifos should therefore be listed in Annex I without specific exemptions. The pesticide approval was never renewed: Implementing Regulation (EU) 2020/18 of 10 January 2020 closed it. The trace limit, says recital (6), serves to reinforce «l’applicazione e l’esecuzione nell’Unione dell’articolo 3, paragrafo 1» (the application and enforcement in the Union of Article 3(1)).
The difference is measured against the entry immediately before yours. Dechlorane Plus carries exemptions for spare parts for vehicles, agricultural and forestry machinery, aerospace and defence applications and medical devices, to 31 December 2043. Chlorpyrifos has one line and no date.
The only window is six months, and it is not in the new entry
A window does exist, elsewhere: Article 4(2). For a substance added to Annex I after 15 July 2019, Article 3 «non si applica per un periodo di sei mesi se tale sostanza è presente negli articoli prodotti alla data in cui il presente regolamento diventa applicabile alla sostanza in questione o prima di tale data» — shall not apply for six months where the substance is in articles produced on or before the applicability date. The next subparagraph goes further: the prohibition does not touch articles already in use before that date.
On the calendar: whatever was produced by 30 September 2026 has six months — until 30 March 2027, if the period runs from the applicability date: the natural reading, which that sentence does not write. Whatever is produced afterwards has nothing. And the hook is the production date of the article, not that of the order or of clearance: a datum held by your supplier, not by you. Anyone who cannot evidence it has no window, even for a part sitting in the warehouse for a year.
The bottom of the table, and no method
0,01 mg/kg is ten micrograms per kilogram, ten parts per billion. Annex I holds no lower trace-contaminant threshold: PFOS, PFOA and PFHxS sit at 0,025 mg/kg, the brominated diphenyl ethers at 10, hexabromocyclododecane at 75. Only methoxychlor, listed earlier, sits at the same level.
And here is the point no circular will make: the regulation does not say by which method to measure it. Across the whole consolidated text «CEN» appears once, in the PFOS entry, where European Committee for Standardisation standards «sono usate come metodi di prova analitici» (shall be used as analytical test methods). The chlorpyrifos entry has nothing of the kind. The only handhold is the definition in Article 2, point 12: a trace contaminant is an amount «superiore al limite di rilevazione dei metodi di rilevazione esistenti a fini del controllo e dell’applicazione» — above the detection limit of existing detection methods for control and enforcement. The rule assumes a method exists and does not say which. Whoever asks for the evidence — a customer, a customs office, a lead contractor — asks per part number, not per company. It is the mechanism of the safety data sheet again: the document follows the article, and travels back when the premise changes.
What we do not know
We do not assert that chlorpyrifos is present in any given supply chain: it is a possibility to be ruled out by measurement, not a fact established here. We have not verified which accredited laboratories currently cover 0,01 mg/kg across the various matrices — textiles, polymers, paper, alloys — nor whether an applicable harmonised standard exists: the regulation cites none. We know of no national enforcement guidance published after 10 September 2026, nor how customs authorities will treat a declared production date for the purposes of Article 4(2).
The two axes, applied
Complying. The new entry becomes a control running on your own systems: for every part number placed on the market, the bill of materials, the supplier declarations with their dates, the test reports available and the declared production date — the one that decides whether the six-month window covers you. It flags the uncovered part numbers before anyone else asks, and leaves a dated, exportable dossier for an authority, or for the customer passing their obligation down to you.
Deciding. The same platform holds ERP, supplier master data, document archive, laboratory and customs files of a manufacturing business in a single operating model, on which AI agents carry out decisions with an operator in command: which suppliers to question first, which lots to hold, which samples to send for testing on the budget you actually have. For large enterprises, defence, public administration and healthcare. Always in two modes: on-premise, on standalone machines needing no deep integration into your network, or a dedicated cloud with a dedicated VPN and a data centre in Italy, with shared management — you need not already employ people who administer models.
The first session, at no cost, produces the dated list of your exposed part numbers: which article, which supplier, which document is missing. It stays with you. Talk it through with one of our engineers.