European Economic AreaPersistent Organic Pollutants (POPs)

EU Bans UV-328 Under POPs Regulation: Key Deadlines And Exemptions Revealed

The EU’s inclusion of UV-328 under the POPs Regulation represents a critical shift in chemical policy. With strict deadlines and targeted exemptions, companies across the manufacturing value chain must act now to adapt materials, sourcing strategies, and compliance systems.

Published in July 2025. Dates, deadlines and stages may have changed since.

Dr Steven Brennan

3 min readAI-drafted, expert reviewed

Electronics

The European Commission has officially banned UV-328 under the Persistent Organic Pollutants (POPs) Regulation, introducing strict thresholds and limited exemptions for specific uses across the EU from 4 August 2025. This regulatory change will significantly affect professionals in manufacturing, automotive, aerospace, medical devices, and other sectors reliant on UV-stabilised materials.

Why UV-328 Faces EU Ban Under POPs Regulation

UV-328, chemically known as 2-(2H-benzotriazol-2-yl)-4,6-di-tert-pentylphenol, is a widely used UV stabiliser found in plastics, coatings, and electronics. It has been identified as a persistent, bioaccumulative, and toxic (PBT) substance, prompting international action under the Stockholm Convention.

Following a decision at the 2023 Stockholm Convention, the EU amended Annex I of Regulation (EU) 2019/1021 to align with global commitments to eliminate harmful POPs. UV-328 joins this list with phased restrictions and select exemptions, reinforcing the EU’s Chemicals Strategy for Sustainability.

Implementation Timelines And Key Exemptions

The ban introduces three progressive concentration limits for UV-328 in articles, mixtures, and substances:

  • 100 mg/kg from 4 August 2025
  • 10 mg/kg from 4 August 2027
  • 1 mg/kg from 4 August 2029

However, exemptions apply until 4 August 2030 for UV-328 use in land-based vehicles, industrial coatings, blood collection devices, polarisers, photographic paper, and aircraft. Spare parts used in legacy equipment may remain in service until 31 December 2043 or the end of their functional life.

These exemptions are designed to allow time for industry substitution and avoid severe disruptions to critical infrastructure and supply chains.

Implications For Industry Stakeholders

Professionals across the chemicals ecosystem—especially those in automotive, aerospace, electronics, and healthcare—must assess compliance risks and transition plans immediately. The ban not only impacts EU-based manufacturers but also affects importers and distributors handling articles containing UV-328.

Businesses must also prepare for stricter trace contaminant thresholds, starting at 100 mg/kg in 2025 and tightening to 1 mg/kg by 2029, requiring updated analytical capabilities and supply chain transparency.

Questions about this change

What is UV-328 and why is it banned under the EU POPs Regulation?

UV-328 is a chemical used to protect materials from UV degradation. It is being banned due to its persistence, bioaccumulation, and toxicity. The EU has aligned with international efforts to eliminate harmful pollutants under the Stockholm Convention.

Which industries are most affected by the UV-328 ban?

Sectors such as automotive, aerospace, electronics, construction, and medical devices are heavily impacted. The ban limits UV-328 use in coatings, plastics, and optical components, making compliance planning critical for downstream users and suppliers.

Dr Steven Brennan

CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.

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