The Latest Development on POPs and K-REACH
Regulations once limited to chemical products are increasingly being extended to articles, with growing momentum to manage chemicals under the precautionary principle. Recent developments under the Stockholm Convention and their national implementation illustrate how COP decisions and POPRC reviews continue to add substances of concern (e.g., Dechlorane Plus, UV 328, MCCPs, LC-PFCAs). These listings have prompted accelerated restrictions, bans, or import limits in several jurisdictions. Many countries update domestic prohibitions soon after Convention listings, expanding both the geographic scope and pace of compliance obligations for chemical products and articles used in semiconductor manufacturing.
For the semiconductor supply chain, two operational impacts are particularly prominent. First, the multilayered and specialized nature of the supply chain makes obtaining reliable upstream chemical data difficult, complicating compliance assessments and materials management. Second, K-REACH 2025 amendments introduce a presumption of hazard for substances without test data, establish new hazardous substance groupings, and revise notification and registration thresholds — all of which increase documentation and risk management obligations for manufacturers and downstream users.
Practical responses include early prioritization of at-risk substances and processes, strengthened supplier data flows with formal Annex/MSDS verification, workplace exposure assessment and application of the hierarchy of controls, and a staged roadmap that combines short-term containment with mid- to long-term supply chain transparency and substitution planning. These approaches aim to secure regulatory compliance while maintaining product continuity in a rapidly evolving global landscape.
