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

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.