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The Department of Forestry, Fisheries and the Environment ("DFFE") has published Government Notice 7136 ("Notice"), giving South African businesses a tight 30-day window to apply for exemptions relating to three newly listed persistent organic pollutants ("POPs") under the Stockholm Convention. Whether you are in manufacturing, mining, construction, textiles, or defence, this Notice deserves your immediate attention. Any company involved in the use, sale, production, import, or export of these chemicals under the exempted uses must apply to the DFFE within 30 days of the Notice's publication; that is, by 16 March 2026.
At its twelfth Conference of the Parties ("COP-12"), held in Geneva last year, parties to the Stockholm Convention agreed to list several new substances for elimination, namely, chlorpyrifos (a pesticide already banned in South Africa), and two groups of industrial chemicals, long-chain perfluorocarboxylic acids ("LC-PFCAs") and medium-chain chlorinated paraffins ("MCCPs").
For those less familiar with POPs, these are notoriously hazardous substances. They are highly toxic, persistent in the environment and capable of bioaccumulating in living organisms and travelling vast distances. Put simply, they are chemicals that linger in the environment, in animals and in us. With these new listings, any use of these chemicals is now banned except where specific exemptions apply.
The Notice also addresses UV-328, a UV stabiliser already on the Convention's elimination list. The COP-12 reopened this listing to grant the aerospace industry a new exemption, permitting continued use in certain aircraft applications until the end of 2030.
Among the newly listed substances, the "forever chemicals" are perhaps the most notorious. LC-PFCAs belong to the per- and polyfluoroalkyl substances ("PFAS") family, often called "forever chemicals" because of their stubborn persistence in the environment. These substances are prized for their ability to repel water, oil and grease. For the fashion and textile industry, this is significant. LC-PFCAs have historically been used in water-and-stain-resistant coatings on fabrics, from rainwear to school uniforms. As regulators tighten the screws, manufacturers should explore natural or bio-based alternatives that achieve similar performance without the environmental baggage.
MCCPs, on the other hand, are the quiet workhorses of the chemical world, used to make plastics flexible and durable. Chances are, you have encountered them without knowing it. They appear in PVC pipes and cables, children's toys, conveyor belts, adhesives, sealants and leather goods. For the mining sector, MCCPs are particularly relevant in conveyor belts used in underground coal mines. In heavy-industrial applications, they feature in metalworking fluids across the energy, oil and gas, and chemical production sectors.
Chlorpyrifos, a widely used pesticide, rounds out the trio. Unlike the industrial chemicals above, chlorpyrifos is already banned in South Africa, so no exemption applications are required locally. Its inclusion on the Stockholm Convention's elimination list simply brings the rest of the world in line with South Africa's existing position.
With the 16 March 2026 deadline, time is of the essence. The exemptions themselves will come with conditions, sunset dates, and detailed requirements. The DFFE will review submissions and, where appropriate, apply for registration of exemptions with the Stockholm Convention Secretariat on behalf of South Africa.
The global chemicals landscape is tightening, and businesses that do not adapt are at risk of being left behind. Whether you need to audit your supply chain, understand which exemptions apply to your operations, or prepare an application before the deadline, we are here to help.
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