Stockholm PCB deadlines 2025 and 2028: what they mean for oil

Stockholm Convention Annex A targets 2025 for ending PCB use in equipment and 2028 for sound management of PCB liquids above 0.005% (as of 2026-10-14). The 2025 goal, built on determined efforts for equipment above 0.05% PCB and 5 litres, was largely missed. Owners are bound through national law, such as the EU removal deadline of 31 December 2025.

• The Stockholm Convention had 186 Parties on 2026-10-13; the United States signed on 23 May 2001 but has not ratified it (UN Treaty Collection, 2026).

• UNDP reports 32 PCB projects in 25 countries, aiming to eliminate 41,934 tonnes of PCBs by 2028 with its support (UNDP, 2025).

• Basel Convention technical guidelines set a provisional low POP content of 50 mg/kg for PCBs; wastes above it are to be destroyed or irreversibly transformed unless that is not the environmentally preferable option (Basel Convention, 2017).

• The thirteenth Stockholm Conference of the Parties meets in Panama City from 19 to 30 April 2027 (Stockholm Convention Secretariat, 2026).

This analysis covers the Stockholm Convention duties of Parties and how the EU, England and Wales, and US federal rules apply them to liquid-filled transformers and their oil. It does not cover other national laws, PCBs in open applications such as paints and sealants, or capacitor testing, and it is not legal advice for a specific site.

What is changing under the Stockholm PCB deadlines, and when?

Under the Stockholm PCB deadlines, the 2025 goal for ending PCB use in equipment has passed and the 2028 limit for sound waste management of PCB liquids is the next fixed date. Status as of 2026-10-14: Annex A Part II is in force in the text revised in 2025, both dates remain "subject to review by the Conference of the Parties", and no Conference decision has moved them (Stockholm Convention, 2025). At its twelfth meeting in 2025, the Conference of the Parties urged Parties to meet paragraphs (a) and (e) of Annex A Part II, "taking into account the strategy for polychlorinated biphenyls towards meeting the 2025 and 2028 goals" (Stockholm Convention, SC-12/3, 2025).

The timeline below shows which act set each date that matters to an owner of oil-filled equipment:

The key row for planning is 2028: by then, PCB liquids above 0.005% and the equipment they contaminate should be in an environmentally sound waste route (Stockholm Convention, 2025).

Which transformers and oils fall under the Stockholm Convention PCB deadlines?

Transformers and oils fall under the Stockholm Convention PCB deadlines by PCB content and volume: equipment above 0.05% PCB and 5 litres carries the firmest 2025 duty, and any liquid above 0.005% PCB is in scope for the 2028 waste duty (Stockholm Convention, 2025). The table below sorts equipment and oil by the Annex A Part II provision that applies.

The row most likely to catch an ordinary mineral oil transformer is the third; that is our reading of the thresholds. US rules require owners to assume that untested mineral oil equipment made before 2 July 1979, or of unknown manufacture date, contains at least 50 ppm but less than 500 ppm PCB (40 CFR 761.2, 2026). Ireland's Environmental Protection Agency treats oil-filled transformers made before 1989, or of unknown date, as in scope until a test shows otherwise (EPA Ireland, 2024). Paragraph (c) of Annex A Part II also bars export or import of such equipment except for environmentally sound waste management (Stockholm Convention, 2025).

Why do sources quote 50 ppm and 500 ppm for the 2025 PCB target?

Sources quote both 50 ppm and 500 ppm for the 2025 PCB target because Annex A Part II attaches 2025 to three tiers of effort, and summaries collapse them differently. The Convention text asks Parties, for the 2025 goal, to "make determined efforts to identify, label and remove from use equipment containing greater than 0.05 per cent polychlorinated biphenyls and volumes greater than 5 litres", and only to "endeavour" to do the same for equipment above 0.005 per cent and 0.05 litres (Stockholm Convention, 2025). The firm 2025 tier is therefore 0.05%, or 500 ppm.

The 50 ppm figure comes from three places. UNDP summarises the 2025 duty as ending PCB use in equipment "containing greater than 50 ppm", which, in our reading, merges the endeavour tier into the 2025 date (UNDP, 2025). The 2028 waste duty itself uses 0.005% (Stockholm Convention, 2025). The Basel Convention guidelines set 50 mg/kg as the provisional low POP content for PCB wastes and call it "an internationally practical level for all wastes" (Basel Convention, 2017).

National law then fixes the number. The EU turned the 0.005% tier into a hard deadline of 31 December 2025 for equipment above 0.05 dm3 (EPA Ireland, 2024). US federal rules use 50 ppm and 500 ppm as regulatory bands under 40 CFR 761 (40 CFR 761.3, 2026). For planning, 50 ppm is the safer working threshold in most jurisdictions; that is our reading, not a Convention requirement.

What happens now that the 2025 PCB equipment deadline has passed?

Now that the 2025 PCB equipment deadline has passed, nothing in the Convention itself switches off a transformer: Annex A Part II obliges Parties, and owners feel the date only through national law. The text opens with "Each Party shall" and frames 2025 as a goal subject to review by the Conference of the Parties (Stockholm Convention, 2025). Paragraph (b) also promotes conditions for equipment still in use: intact and non-leaking equipment only, no use in areas for food or feed production, and fire protection and leak inspection in populated areas such as schools and hospitals (Stockholm Convention, 2025).

The goal was largely missed. UNDP reported in April 2025 that "most countries have been unable to meet the commitment under the Stockholm Convention to identify and label equipment containing PCBs and to remove them from use by 2025" (UNDP, 2025). It added that many transformers identified with more than 50 ppm PCB are still in operation, often where national testing, inventory and reporting rules are weak or lax (UNDP, 2025).

The Conference of the Parties responded in 2025 by urging action rather than resetting dates. Decision SC-12/3 asks Parties to develop, update and maintain national PCB inventories and to report quantitative information on PCBs in their national reports under Article 15 (Stockholm Convention, SC-12/3, 2025). In the EU, the national deadline has also passed: equipment above 0.005% PCB and 0.05 dm3 had to be out of use by 31 December 2025 (EPA Ireland, 2024). Equipment still in service above that level in an EU Member State is now a compliance question for the national authority.

How do EU, England and Wales, and US rules turn the Stockholm PCB deadlines into owner duties?

EU, England and Wales, and US rules turn the Stockholm PCB deadlines into owner duties in different ways: the EU and England and Wales set a fixed removal date, while US federal rules regulate PCB transformers by concentration band without a Stockholm date. The United States signed the Convention on 23 May 2001 but is not among the 186 Parties (UN Treaty Collection, 2026).

In the EU, Regulation (EU) 2019/1021 requires holders to remove from use equipment containing more than 0.005% by weight PCB and volumes greater than 0.05 litres by 31 December 2025, and Directive 96/59/EC set the earlier 2010 deadline for equipment with more than 5 litres of PCBs (EPA Ireland, 2024). In Ireland, holders of PCBs or contaminated equipment above 5 litres must notify the EPA by 1 September each year (EPA Ireland, 2024). England and Wales partially implemented the same 2025 removal sentence through the 2020 amendment to their PCB disposal regulations (UK SI 2020/489, 2020).

In the US, 40 CFR 761 defines a PCB Transformer as one containing 500 ppm or more and PCB-Contaminated equipment as 50 ppm or more but below 500 ppm (40 CFR 761.3, 2026). PCB-Contaminated transformers may be serviced only with dielectric fluid below 500 ppm, and any fluid mixed with 500 ppm or greater fluid must be treated as above 500 ppm and incinerated (40 CFR 761.30, 2026). These bands apply whether or not a Stockholm date has passed.

What are the technical consequences for transformer oil testing and handling?

The technical consequences for transformer oil are that PCB content must be measured, not assumed, before any top-up, reclaiming, retrofill or disposal, because the legal class of the oil and the equipment depends on a number in ppm. Two standard gas chromatography methods cover it. IEC 61619:1997, Edition 1.0, determines PCB concentration in non-halogenated insulating liquids by capillary column gas chromatography with an electron capture detector (IEC, 1997). ASTM D4059-00(2018), listed as Active, quantifies PCBs in electrical insulating liquids by gas chromatography, with precision established only for mineral oils and silicones (ASTM, 2018).

Mixing is the main way a clean unit becomes regulated. Annex A Part II bars recovery for reuse in other equipment of liquids above 0.005% PCB, except for maintenance and servicing (Stockholm Convention, 2025). Under US rules, fluid below 500 ppm that is mixed with fluid at 500 ppm or more is treated as above 500 ppm in its entirety (40 CFR 761.30, 2026). Oil processing rigs, hoses and storage tanks that have handled contaminated oil can carry PCBs into the next unit; that is our inference from the mixing rule, and it is why oil service records matter.

Handling PCB oil is hazardous work. Before draining, sampling or transferring oil that is or may be above 50 ppm, the lower US regulatory band (40 CFR 761.3, 2026), read the oil's safety data sheet (SDS) and follow the national PCB and hazardous waste rules, such as 40 CFR 761 in the US or the national rules implementing Regulation (EU) 2019/1021 in the EU.

What must owners do with PCB oil before 2028?

Before 2028, owners should plan to get PCB liquids above 0.005% and the equipment they contaminate into an environmentally sound waste route, which in practice means testing, labelling, planned removal and destruction or decontamination. The binding owner duty comes from national law. The Convention text sets the end point: Parties shall "make determined efforts designed to lead to environmentally sound waste management of liquids containing polychlorinated biphenyls and equipment contaminated with polychlorinated biphenyls having a polychlorinated biphenyls content above 0.005 per cent" no later than 2028 (Stockholm Convention, 2025). The table below assigns the steps; dates are the latest a plan can use, and national law may set earlier ones.

The first two rows decide everything else: without a measured PCB value per unit, an owner cannot tell which units carry a 2025 removal duty and which can wait for the 2028 waste route. The Basel guidelines make destruction or irreversible transformation the default for PCB wastes above 50 mg/kg (Basel Convention, 2017).

What is still open on the Stockholm PCB deadlines?

Three points remain open on the Stockholm PCB deadlines as of 2026-10-14: whether the Conference of the Parties will review the dates, how far behind Parties are, and whether national rules will tighten. Both dates are written "subject to review by the Conference of the Parties", and the Conference reviews progress at five-year intervals using Parties' reports (Stockholm Convention, 2025).

The next checkpoint is the thirteenth meeting in Panama City from 19 to 30 April 2027 (Stockholm Convention Secretariat, 2026). The small intersessional working group on PCBs is preparing an updated report on progress towards elimination: its workplan set 25 September 2026 for the third draft, 12 October 2026 for comments and 15 and 16 October 2026 for an in-person meeting to finalise it, with the final report due to go to the thirteenth meeting as an information document by 13 January 2027 (Stockholm Convention Secretariat, 2026). Any change to the 2028 date would come from a decision there or later; none has been proposed in the documents checked for this article.

Funding and capacity remain the practical limit. UNDP lists data inconsistencies, a lack of national expertise and disposal facilities, private co-financing and procurement as key challenges (UNDP, 2025). Where a country lacks destruction capacity, PCB equipment may be exported only for environmentally sound waste management (Stockholm Convention, 2025), so disposal planning likely needs to start well before 2028; that timing point is our inference.

Lubinpla, an applied AI company, works cases like this from an owner's own documents, such as SDS and test certificates, and site history, and returns one cited document for review with each step approved by the user.

Lubinpla applies this kind of reasoning to your own documents and site history and drafts the document for your review before it goes out.

Sources checked 2026-10-14.

Sources

1. Secretariat of the Stockholm Convention. Stockholm Convention on Persistent Organic Pollutants, text and annexes revised in 2025 (Annex A, Part II). 2025. https://chm.pops.int/Portals/0/download.aspx?e=UNEP-POPS-COP-CONVTEXT-2025.English.pdf

2. Conference of the Parties to the Stockholm Convention. Decision SC-12/3, Polychlorinated biphenyls. 2025. https://www.pops.int/Implementation/IndustrialPOPs/PCB/Decisions/tabid/692/ctl/Download/mid/8099/Default.aspx?id=53&ObjID=35690

3. Secretariat of the Stockholm Convention. Small intersessional working group on PCB, overview and 2025-2027 workplan. Accessed 2026-10-14. https://www.pops.int/tabid/9725/Default.aspx

4. Secretariat of the Stockholm Convention. Meetings of the Conference of the Parties. Accessed 2026-10-14. https://chm.pops.int/TheConvention/ConferenceoftheParties/Meetings/tabid/210/Default.aspx

5. Global Environment Facility. GEF at the BRS Conventions COPs 2025. 2025. https://www.thegef.org/events/gef-brs-conventions-cops-2025

6. United Nations Treaty Collection. Chapter XXVII-15, Stockholm Convention on Persistent Organic Pollutants, status as at 13 October 2026. https://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XXVII-15&chapter=27&clang=_en

7. UNDP Chemicals and Waste Hub. Eliminating polychlorinated biphenyls (PCBs). April 2025. https://www.undp.org/sites/g/files/zskgke326/files/2025-04/eliminating_polychlorinated_biphenyls-undp_chemicals_and_waste_hub.pdf

8. Basel Convention. Technical guidelines on the environmentally sound management of wastes consisting of, containing or contaminated with PCBs, PCTs, PCNs or PBBs (UNEP/CHW.13/6/Add.4/Rev.1). 2017. https://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW.13-6-Add.4-Rev.1.English.pdf

9. Environmental Protection Agency, Ireland. Persistent organic pollutants, PCB information leaflet. November 2024. https://www.epa.ie/publications/compliance--enforcement/waste/PCB-information-leaflet-Nov-24.pdf

10. UK Government. The Environmental Protection (Disposal of Polychlorinated Biphenyls and other Dangerous Substances) (England and Wales) (Amendment) Regulations 2020, SI 2020/489, explanatory note. 2020. https://www.legislation.gov.uk/uksi/2020/489/note/made

11. US EPA, eCFR. 40 CFR Part 761, Polychlorinated biphenyls (PCBs) manufacturing, processing, distribution in commerce, and use prohibitions, up to date as of 2026-10-08. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-R/part-761

12. IEC. IEC 61619:1997, Edition 1.0, Insulating liquids, contamination by polychlorinated biphenyls (PCBs), method of determination by capillary column gas chromatography. https://webstore.iec.ch/en/publication/5670

13. ASTM International. ASTM D4059-00(2018), Standard test method for analysis of polychlorinated biphenyls in insulating liquids by gas chromatography. https://store.astm.org/d4059-00r18.html

Written by the Lubinpla team from the sources listed and checked against them before publication.

Reviewed by Jonghwan Moon, Founder & CEO, Lubinpla, 2026-10-14.