In the device-specific M-DoC (Material Declaration of Compliance), PULS confirms compliance with the requirements of the REACH and POP regulations. Since UV-328 is not listed there as a Substance of Very High Concern (SVHC) under REACH or as a substance under Annex A of the POP Regulation, it can be assumed that this substance is not present in the product. If UV-328 were present, it would be explicitly declared in the M-DoC.
Explanation: UV-328 (2-(2H-benzotriazole-2-yl)-4,6-di-tert-pentylphenol) is a UV absorber used in plastics, coatings, adhesives, and packaging to protect materials from UV-induced aging. Due to its properties, UV-328 has been regulated and prohibited (REACH) or unintentional traces are allowed (POP) under both the REACH Regulation and the Stockholm Convention – see below for details)
Regulatory status
Candidate List (SVHC): UV-328 was identified as a substance of very high concern (SVHC) in 2014.
Authorisation requirement (Annex XIV): Since 27 November 2023, the use of UV-328 has been banned in the EU without specific authorisation.
2. POP Regulation (EU) / Stockholm Convention
Inclusion in Appendix A : In May 2023, UV-328 was added to Appendix A of the Stockholm Convention, which provides for a global ban on its production and use.
EU implementation : The EU plans to include UV-328 in the POPs Regulation from 26 February 2025, with a limit of 0.0001 % (1 mg/kg) for unintentional traces in products.