EU Sets UV-328 Phase-Out Limits

EU Adds UV-328 to POPs Regulation, Sets Strict Phase-Out Schedule

On 5 May 2025, the European Commission adopted Delegated Regulation (EU) 2025/843, amending Annex I of the POPs Regulation (EU) 2019/1021 to include new restrictions on UV-328, a UV stabiliser widely used in plastics and coatings.

The regulation introduces a phased ban on UV-328, reflecting its classification as a Persistent Organic Pollutant (POP) under the Stockholm Convention, due to its toxicity, bioaccumulation potential, and persistence in the environment.

What Is UV-328 and Why It’s Regulated

• UV-328 (CAS No. 25973-55-1) is used in:

o Plastics, rubber, and adhesives
o Protective coatings and films

• It is resistant to degradation and has been found in remote environments, including Arctic regions and marine species.
• Its inclusion under the Stockholm Convention has triggered global action.

Phased Contamination Limits: Key Deadlines

The regulation sets progressively lower thresholds for unintentional presence of UV-328 in materials:

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

These gradual reductions give industry time to reformulate products, upgrade quality control, and replace contaminated recyclates.

Limited Exemptions for Critical Uses

To ensure supply chain continuity, time-bound exemptions are granted until 4 August 2030 for:

• Vehicles and railcars
• Large metal structure coatings
• Blood separation tubes
• Photographic paper and polarising films
• Aerospace components (civil and military)

In specific cases (e.g., spare parts), exemptions may extend to 31 December 2043 or the end of product service life.

Regulation Objectives

✅ Global Alignment
Ensures EU compliance with the Stockholm Convention and supports international POP reduction efforts.

✅ Cleaner Circular Economy
Prevents recycled material contamination, boosting supply chain transparency and non-toxic material cycles.

✅ Industry Adaptability
Provides clear transition timelines for businesses to adapt without disruption.

What Industry Must Do Now

Manufacturers, importers, and recyclers should take immediate steps to:

• Test and monitor UV-328 levels in raw materials and finished goods
• Revise sourcing strategies to minimize contamination risk
• Plan alternatives for UV-328-reliant applications before exemption deadlines
• Document use of derogations and prepare for future inspections

Timeline and Enforcement

The regulation is directly applicable in all EU Member States—no national transposition required.

Reference: EU Delegated Regulation 2025/843 on UV-328