EU Updates POPs Regulation: UV-328 Added to Annex I

Published: July 15, 2025
Effective Date: August 4, 2025
Regulation: Commission Delegated Regulation (EU) 2025/843

On July 15, 2025, the European Commission adopted Delegated Regulation (EU) 2025/843, officially adding UV-328 (CAS No. 25973-55-1) to Annex I of the Persistent Organic Pollutants (POPs) Regulation. The amendment enters into force on August 4, 2025.

UV-328 is widely used as a UV stabilizer in plastics, coatings, inks, cosmetics, and other polymer-based materials. Due to its persistence and potential for bioaccumulation, the substance is now subject to progressive restrictions under EU law.

New Substance Limits and Timeline

The regulation introduces a phased reduction in the allowable concentration of UV-328 in materials and products:

Substance	Limit	Effective Date
UV-328	100 mg/kg	August 4, 2025
	10 mg/kg	August 4, 2027
	1 mg/kg	August 4, 2029

Manufacturers and importers must prepare for these tightening thresholds well in advance, particularly for long-life products or complex supply chains.

What This Means for Businesses

Companies involved in any stage of the supply chain — from raw materials to finished goods — should take proactive steps to:

• Audit current formulations to identify UV-328
• Test raw materials and additives across product lines
• Verify supplier compliance and declarations
• Assess the regulatory status of goods intended for the EU market

Timely action will be critical to ensure continued market access and avoid non-compliance penalties.

Temporary Exemptions

• Certain uses of UV-328 are temporarily exempt from restriction until February 26, 2030, including:
• Land vehicles
• Blood collection tubes and mechanical separation devices
• Cellulose triacetate film used in polarizers
• Photographic paper

Additionally, spare parts for legacy equipment such as vehicles, industrial machinery, and LCD panels may continue to contain UV-328 until the equipment reaches the end of its service life.

Recommended Actions

• Conduct a comprehensive supply chain review
• Update Safety Data Sheets (SDS), compliance documents, and declarations
• Begin transitioning away from UV-328 in advance of lower thresholds
• Prepare for regulatory inspections and product testing