EU Consults Over Listing of UV-328 under POP Recast Regulation

SG 123/24

The EU is planning to add UV-328 to its legislation on persistent organic pollutants (POP). If approved, the new law will apply from February 26, 2025.

In May 2023, the Conference of the parties to the Stockholm Convention added UV-328 with specific exemptions to Annex A (elimination) of the Convention (SC-11/11)

UV-328 is used as a UV absorber to protect surfaces against discoloration and degradation under UV/sunlight. This substance has a wide range of applications, including but not limited to:

• Automotive industry
• Liquid crystal panels and meters mounted on vehicles
• Paints, coatings and sealants
• Plastics, including in the non-food contact layer of food packaging
• Printing inks and adhesives in food packaging
• Resin for interior and exterior parts of vehicles 

On July 30, 2024, the European Commission (EC) website announced a four-week consultation on the proposed listing of UV-328 (2-(2H-benzotriazol-2-yl)-4-6-ditertpentylphenol) under Part A of Annex I to Regulation (EU) 2019/1021 on persistent organic pollutants (POP Recast Regulation, consolidated version to August 2023)

To reinforce the application and enforcement of the POP Recast Regulation, an unintentional trace contaminant (UTC) value has been set for UV-328 when the chemical is in substances, mixtures and articles.

Highlights of the draft regulation to amend Part A of Annex I to the POP Recast Regulation are summarized in Table 1.

Table 1

¹Contains, among other things, time-limited derogations for the following applications:

• Land-based motor vehicles until February 26, 2030
• Mechanical separators in blood collection tubes until February 26, 2030
• Triacetyl cellulose film until February 26, 2030
• Photographic paper until February 26, 2030
• Spare parts for 1) land-based motor vehicles, 2) stationary industrial machines for use in agriculture, forestry and construction, 3) liquid crystal displays in instruments for analysis, measurements, control, monitoring, testing, production, and inspection, other than for medical applications, where UV-328 was initially used in their manufacture, until the end of their service life or 2044, whichever comes earlier

Articles containing UV-328 placed on the market within a specific exemption that were already in use by the specific expiry date may continue to be used after that date.

In June/July 2024, the EU consulted over its proposed listing of dechlorane plus and methoxychlor to the POP Recast Regulation (SafeGuardS 102/204). These two POP chemicals were also added to Annex A of the Stockholm Convention in May 2023

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