DFFE Calls for Industry Input on Medium-Chain Chlorinated Paraffins Exemptions Under Stockholm Convention
1. Background
The Department of Forestry, Fisheries and the Environment (DFFE) has urged South African companies that manufacture or use Medium-Chain Chlorinated Paraffins (MCCPs) to submit exemption applications by the end of June as the country prepares to implement obligations arising from the Stockholm Convention on Persistent Organic Pollutants (POPs).
During a recent industry engagement, DFFE's Gordon Xabe outlined the international process that led to the listing of MCCPs and explained how South Africa will manage exemptions for affected industries.
2. Understanding the Stockholm Convention
The Stockholm Convention is a global environmental treaty aimed at protecting human health and the environment from persistent organic pollutants. Signed in 2001 and entering into force in 2004, the Convention seeks to eliminate or restrict chemicals that persist in the environment, accumulate in living organisms, travel long distances, and pose significant health risks.South Africa became a party to the Convention in 2002, with DFFE serving as the national focal point responsible for representing the country in international negotiations, implementing Convention requirements, and supporting enforcement through national regulations.Persistent organic pollutants are of particular concern because they can remain in the environment for decades, accumulate in fatty tissues, magnify through food chains, and have been linked to serious health effects including cancer, birth defects, immune suppression, and endocrine disruption.
3. How Chemicals Become Restricted
Before a chemical is listed under the Convention, it undergoes a rigorous review process by the Persistent Organic Pollutants Review Committee (POPRC). This includes scientific assessment of environmental and health risks, evaluation of production and use patterns, consideration of releases and emissions, and examination of available alternatives.Throughout this process, DFFE gathers information from South African stakeholders through Government Gazette notices and industry consultations. Information on current uses, production volumes, available alternatives, and potential economic impacts helps shape South Africa's negotiating position and determine whether exemptions may be required.Ultimately, recommendations are considered by the Conference of the Parties (COP), which decides whether a chemical should be listed and what exemptions may be available.
4. Exemptions Available – But Time Is Limited
While listed chemicals are generally subject to restrictions or bans, the Convention allows countries to register for specific exemptions for certain uses.Importantly, exemptions are granted to South Africa as a country, not to individual companies. DFFE therefore consolidates information received from industry and submits a single national application to the Stockholm Convention Secretariat.Companies seeking continued production or use of MCCPs for exempted applications must provide DFFE with details including:
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The specific exempted useWhether the activity involves production, use, or both
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Annual quantities involved
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The duration requested
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Reasons why alternatives are not currently available or suitable
The Convention's standard exemption period is generally up to five years, although extensions may be requested before an exemption expires. Once an exemption has expired, no new registrations for that exemption can be made.Companies involved in both production and use must ensure that both activities are covered through the exemption process.
5. Regulatory Process Still Underway
While MCCPs have already been listed under the Stockholm Convention framework, DFFE indicated that South Africa's domestic regulatory process will take additional time.
According to DFFE, the development and implementation of national regulations restricting non-exempt uses could take approximately three years, although no firm timeline has yet been established.
In the meantime, companies can continue operating under existing conditions while exemption applications are being processed. DFFE estimates that exemption applications may take approximately three to four months to be reviewed and registered once complete information has been submitted.
6, What Companies Should Do Now
DFFE has requested that all affected companies submit completed exemption application forms by 30 June 2026.Companies that require additional time should notify DFFE in writing before the deadline and request an extension.
DFFE will consolidate all submissions into a single South African application and engage directly with applicants if additional information is required by the Stockholm Convention Secretariat.The department has also committed to sharing the relevant Stockholm Convention registration links once exemptions have been formally approved and published.
For companies that manufacture, import, process, or use MCCPs, the exemption application process represents a critical opportunity to ensure business continuity while South Africa transitions toward compliance with its international obligations under the Stockholm Convention.
7. Resources and Forms