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Download UV-328 Non-Containment Certificate
Environmental · RoHS / POPs Compliance
Regulatory Trends and Non-Inclusion Certificate for UV-328
Conclusion: Due to concerns about environmental pollution and bioaccumulation, the use of UV-328 is strictly restricted both domestically and internationally.
UV-328 is a UV absorber (additive) that has been used in many plastic products and paints. This article provides an overview of UV-328 and its international regulatory trends, as well as precautions for product design and export.
UV-328 has been used to prevent degradation by ultraviolet light
UV-328 (2-(2H-benzotriazol-2-yl)-4,6-di-tert-pentylphenol) has been widely used to prevent degradation of plastics, rubber, paints, etc., by absorbing ultraviolet light. However, due to the following properties, it is subject to international regulations:
Extremely resistant to degradation and persistent in the environment for a long time
It has the properties of a persistent organic pollutant (POPs) that does not easily degrade under normal natural conditions and accumulates in soil and water systems for extended periods.
High toxicity and bioaccumulation in aquatic organisms and mammals
Its impact on ecosystems has been confirmed, and its bioaccumulative nature, which leads to concentration in organisms through the food chain, is considered a problem.
International regulatory trends concerning UV-328
| Regulatory Body / Legal Framework | Regulatory Content |
|---|---|
| Stockholm Convention (POPs Convention) |
Principle Prohibition Added as a persistent organic pollutant (POPs) in 2023. Largely restricted, including import and export, except for specific uses. |
| REACH Regulation (EU) |
SVHC Registration Registered as a Substance of Very High Concern (SVHC) in 2021. Likely to become a restricted substance in the future, requiring information disclosure when contained in products. |
| TSCA (USA) |
Priority Substance Designated as a priority substance. Potential for expanded use restrictions and reporting obligations in the future. |
Points to note for product design and export
For international exports (especially to the EU and North America), there is an increasing demand for proof that UV-328 is not contained.
Since it may be contained in resin raw materials and coatings, a content investigation at the material level is important.
It may be subject to inclusion in the product's SDS (Safety Data Sheet) and SCIP registration.
Switching to Alternatives and Corporate Responsibility
Reducing the use of substances of very high concern like UV-328 is not only about regulatory compliance but also a way to demonstrate a company's environmental awareness and enhance its credibility. The following are effective measures to prepare for future regulatory expansion:
Switching to environmentally friendly materials and alternative UV absorbers
Consider switching to alternative UV absorbers (e.g., benzophenones, triazines) that can replace UV-328.
Requesting raw material and material manufacturers to confirm content
Conducting content surveys across the entire supply chain and collecting and managing information using tools such as chemSHERPA is effective.
Strengthening in-house substance management systems
It is important to establish a system, including regular updates of regulatory substance lists, development of internal databases, and training for personnel.
Summary
POPs Convention (2023)
UV-328 designated as a globally banned/restricted hazardous substance
REACH / TSCA
Regulatory tightening underway, including REACH SVHC registration and TSCA priority evaluation
Exports / Material Selection
Increasing cases requiring non-containment certificates for exports to EU and North America
Corporate Response
Use of alternative materials and establishment of information disclosure systems are key for the future
If you need assistance with investigating whether your products contain UV-328 or with creating certificates, please do not hesitate to contact us.
Inquire here about UV-328 non-containment investigations and certificates
Please feel free to contact us about issuing environmental documents, chemSHERPA compliance, and supply chain surveys.
