Ahead of the Stockholm Convention’s 12th Conference of the Parties (COP-12) in 2025, Ethiopia has submitted a proposal to amend Annex A, aiming to extend exemptions for the use of UV-328 in specific aviation applications due to a lack of feasible alternatives. This amendment could impact regulatory compliance for both civilian and military aircraft containing UV-328-based materials.
Background on UV-328 and Its Regulation
UV-328, a chemical widely used for its UV stabilising properties, is primarily applied in various plastics, coatings, and adhesives to enhance durability under UV exposure. However, its classification as a persistent organic pollutant (POP) under the Stockholm Convention highlights concerns over its long-range environmental transport and potential adverse health impacts. Consequently, UV-328 has been restricted under Annex A of the Convention, which lists chemicals for elimination with limited, specific exemptions.
Details of Ethiopia’s Amendment Proposal
Ethiopia’s proposed amendment, submitted on 25 October 2024, seeks to revise the exemptions in Annex A to allow continued use of UV-328 in specific applications within the aviation sector. According to the proposal, both civilian and military aircraft require UV-328 in adhesives, potting compounds, and potentially other materials essential for aircraft durability and performance. Ethiopia highlights that ongoing efforts to find alternatives have yet to yield viable substitutes for these specialised uses.
Justification for Extended Exemptions
Ethiopia’s explanatory note accompanying the proposal underscores that despite industry-wide efforts, no adequate substitutes for UV-328 have been identified for critical applications in the aerospace and defence sectors. The proposal aims to balance environmental protection with the practical needs of maintaining aviation safety and performance standards. It emphasises that these exemptions would be strictly limited to cases where UV-328 is indispensable due to current technological constraints.
Next Steps and Stakeholder Engagement
The Secretariat of the Stockholm Convention has invited Parties to provide comments on Ethiopia’s proposal by 14 February 2025 to facilitate informed discussions at COP-12. During the conference, stakeholders will review Ethiopia’s data, including further explanations expected on the necessity and scope of these exemptions. This engagement is intended to ensure that the proposed amendment aligns with the Convention’s goals while addressing sector-specific needs.
Ethiopia’s proposed amendment to Annex A reflects an attempt to address the specific technical needs of the aviation industry within the framework of the Stockholm Convention. As COP-12 approaches, the international community will weigh the benefits of this exemption against the potential environmental risks, underscoring the ongoing challenges in balancing public health protections with industry needs.
