Key takeaway
What This Development Means
New Zealand has made an order adding chlorpyrifos, long-chain perfluorocarboxylic acids and medium-chain chlorinated paraffins to its persistent organic pollutants schedules. Most provisions commence on 9 October 2026, with specified domestic prohibitions phased in later. Manufacturers and importers must match each substance and use to detailed exemptions and expiry dates.
Are New Zealand's New Persistent Organic Pollutants Controls Already Applicable?
Not yet on 14 September 2026. Most of SL 2026/264 commences on 9 October 2026, while specified Schedule 2A additions commence on 16 December 2026 and 8 July 2027. Businesses should check the provision governing their substance and activity.
Does An Exemption Allow Unrestricted Use Of Chlorpyrifos, Long-Chain PFCAs Or MCCPs?
No. The exceptions are tied to listed uses, products, dates and, in some cases, existing articles or replacement parts. Other hazardous-substance, product, workplace and waste rules continue to apply. Evidence should therefore identify the precise legal condition relied upon.
Source basis: Hazardous Substances and New Organisms (Schedules 1AA and 2A) Order 2026, SL 2026/264, 7 September 2026
New Zealand Persistent Organic Pollutants Controls Are Adopted
New Zealand has adopted new persistent organic pollutants controls for chlorpyrifos, long-chain perfluorocarboxylic acids and medium-chain chlorinated paraffins. The Hazardous Substances and New Organisms (Schedules 1AA and 2A) Order 2026, SL 2026/264, was made on 7 September 2026.
The order is adopted secondary legislation but was not yet in force on 14 September. Most provisions commence on 9 October 2026. Specified additions to Schedule 2A are staged for 16 December 2026 and 8 July 2027, so businesses should use the commencement clause rather than treating publication as immediate application.
Substances, Products And Exemptions
The order updates Schedule 1AA of the Hazardous Substances and New Organisms Act 1996 to reflect the 2025 Stockholm Convention listings. It adds chlorpyrifos, long-chain perfluorocarboxylic acids, their salts and related compounds, and medium-chain chlorinated paraffins. Schedule 2A is also amended so New Zealand's domestic prohibitions and controls can apply.
Chlorpyrifos production is not permitted, while use is confined to the crop and pest combinations listed in the order. Long-chain perfluorocarboxylic acid exemptions cover defined semiconductor manufacture, specified vehicle replacement parts and certain articles already in use. Medium-chain chlorinated paraffin exemptions address narrowly described uses including flexible polyvinyl chloride, adhesives and sealants, leather, foams, pyrotechnics, metalworking fluids and replacement parts.
Those permissions are time-limited. Depending on the use, expiry dates run from 15 December 2031 to 31 December 2040. Some replacement parts remain usable for the service life of the relevant existing article. The order also adjusts existing UV-328 exceptions for aircraft water-seal tape and certain polyurethane or polyamide adhesives and coatings until 31 December 2030.
What Changes Now And Later
Existing hazardous-substance approvals, workplace controls, waste duties and other product rules remain relevant. The order does not create a general permission for any listed use, and an exemption from the persistent organic pollutant prohibition does not displace other legal requirements.
Manufacturers and importers should map substance identity, concentration, function, article status and placing-on-market date. Distributors and retailers should obtain supplier declarations tied to the exact exemption. Employers and waste operators should identify legacy stocks and end-of-life articles before disposal or recycling decisions.
Analysis, clearly identified as an inference: the most difficult compliance point will be exemption evidence rather than simple substance screening. The same chemical group can be prohibited in one product, temporarily permitted in another and allowed only for servicing an existing article. A generic supplier statement that a material is "Stockholm compliant" will not establish the relevant use, date or article condition.
Related Foresight coverage explains the 2025 Stockholm Convention decisions, Japan's proposed export controls and the European Commission's adopted long-chain PFCA measure.
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