Application of the EU POP Regulation to the reactivation of activated carbon, including in water treatment and wastewater treatment
Why is the EU POP Regulation relevant for activated carbon used in water and wastewater management, for example?
The EU POP Regulation (EU) 2019/1021 serves to protect the environment and health by restricting the manufacture, use, and disposal of persistent organic pollutants (POPs). It is particularly relevant for water and wastewater management and certain economic sectors. Granular activated carbon is used in the treatment of water (drinking water, but also certain types of wastewaters), which becomes increasingly loaded with PFAS after use. New drinking water limits and environmental quality standards for PFAS significantly tighten the requirements for handling such activated carbon loaded with PFAS.
A joint information bulletin from bdew, DVGW, and DWA – German associations for water and wastewater management – dated January 29, 2026, outlines solutions for reactivating PFAS-loaded activated carbon in the most legally compliant manner possible under the current legal framework.
What problem does the EU POP Regulation cause for the reactivation of PFAS-loaded activated carbon?
If the content of PFAS (such as PFOS, PFOA, and PFHxS) in the loaded granular activated carbon exceeds the limit values specified in Annex IV of the EU POP Regulation, an approved disposal procedure in accordance with Annex V of the EU POP Regulation must be carried out. Only four procedures are listed here:
D9 – chemical/physical treatment
D10 – incineration on land
R1 – main use as fuel or other means of energy production, with the exception of PCB-containing waste
R4 – recovery/recycling of metals and metal compounds from iron and steel production residues
PFAS-loaded activated carbon is often reactivated using thermal processes. The thermal treatment of PFAS-loaded activated carbon itself is not considered incineration on land (D 10) because the activated carbon is retained (which is precisely the purpose of thermal reactivation and circular economy practices). However, the PFAS (and other substances) are removed from the activated carbon, transferred to the exhaust gas, and destroyed in the exhaust gas treatment process. The EU POP Regulation, which is not designed for the recycling of valuable waste (such as used activated carbon), therefore raises doubts about the legal admissibility of the thermal reactivation of PFAS-loaded activated carbons.
How can the problem be solved?
The three associations bdew, DVGW, and DWA, in consultation with the Federal Ministry for the Environment, have worked out the following solution: PFAS-loaded granular activated carbon may be subjected to thermal reactivation if the reactivation is carried out as a two-stage process and complete destruction of the PFAS in the exhaust gas stream is guaranteed.
1. The actual thermal reactivation of the activated carbon is to be regarded as permissible pretreatment. During this treatment, PFAS are removed from the loaded activated carbon and transferred to the exhaust gas.
2. The exhaust gas treatment is to be regarded as disposal method D10 (incineration on land). In this treatment, the PFAS transferred to the exhaust gas is thermally destroyed.
What requirements should be met when reactivating PFAS-loaded granular activated carbon?
- The most important requirements and recommendations for the two-stage process are:
- The exhaust gas treatment leads to the destruction of the POPs listed in the EU regulation.
- The PFAS content (exhaust gas analyses or PFAS mass balance) must be verified.
- The reactivated material does not contain any POPs or only contains permissible trace contaminants.
- The criteria according to § 5 (1) KrWG for the end of the waste property of the reactivated activated carbon are met.
- If the reactivated carbon is to be used in the drinking water sector, the requirements of the so-called § 20 list of the UBA (the German Federal Environment Agency), including the purity criteria of BS EN 12915-1, must be complied with.
If these requirements are not met, the PFAS-loaded activated carbon should be disposed of using the disposal procedures provided for in Annex V of the EU POP Regulation.
What ambiguities or unanswered questions remain?
However, the legal situation remains unsatisfactory. The qualification of thermal reactivation of PFAS-loaded activated carbon as a permissible pretreatment should be clarified in the EU POP Regulation itself. In addition, there is no standardized procedure for determining the PFAS loading of activated carbon. Compliance with limit values is therefore usually estimated on the basis of balances. This leads to uncertainties in the interpretation and application of the EU POP Regulation.
Conclusion
The provisions of the EU POP Regulation must therefore be made more legally certain and practical in the future and revised in line with the circular economy. This applies not only, but also with regard to the reuse and further use of reactivated activated carbon.
The information from bdew, DVGW, and DWA dated January 29, 2026, can be downloaded here (in German).
