The European Chemicals Agency (ECHA) has released a comprehensive screening report evaluating the environmental risks associated with the use of four specific benzotriazole chemicals in various consumer and industrial goods. This report is part of ECHA's continued efforts under REACH Article 69(2) to assess and regulate potentially harmful substances.
Benzotriazoles Under Scrutiny
The four phenolic benzotriazoles – UV-328, UV-320, UV-327, and UV-350 – are primarily used as UV-absorbers in plastics, rubber, resins, and other materials. These compounds are predominantly found in the automotive sector, with additional applications in medical devices, electrical and electronic equipment, and consumer goods. Notably, UV-328 and UV-327 have seen declining use over the past decade, according to data from the Swedish Product Registry.
Divergent Paths for UV-328 and Others
The screening, conducted by ECHA, concludes that the use of UV-328, although posing environmental risks, is expected to be adequately controlled through existing regulatory actions, particularly under the POP Regulation (EU) 2019/1021. This regulation aligns with the global measures undertaken following UV-328's listing in Annex A of the Stockholm Convention.
In contrast, UV-320, UV-327, and UV-350 have been identified as substances posing uncontrolled environmental risks due to their vPvB (very Persistent and very Bioaccumulative) properties. As these chemicals have not been proposed for review under the Stockholm Convention, alternative regulatory measures are necessary within the EU.
Call for Restriction and Impact Assessment
ECHA recommends the preparation of an Annex XV dossier for restriction, targeting the use of UV-320, UV-327, and UV-350 in various articles. This proposal, derived from an extensive consultation process involving various stakeholders, is aimed at mitigating the environmental risks these substances pose.
The report highlights that the restriction of these benzotriazoles is essential to reduce their presence in imported articles and subsequently, their release into the environment. It also underscores the availability of safer alternatives, indicating a feasible transition for industries utilizing these substances.
Socio-Economic Considerations
While the proposed restrictions primarily target imported goods, the impact on certain sectors, particularly automotive and medical device industries, is a concern. These industries rely on specific uses of these substances for safety and performance. The report acknowledges the need for a balanced approach that considers both environmental protection and economic impacts.
ECHA’s initiative underscores a significant step in environmental protection, aligning with broader global efforts to regulate harmful substances. The proposed restrictions, once formalized, are expected to have a substantial impact on the use and import of products containing these benzotriazoles across the European Union.
