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On May 5, 2025, the European Commission adopted draft amendments to the EU POPs Regulation (EU) 2019/1021 concerning UV-328 and perfluorooctanoic acid (PFOA), as well as its salts and related compounds.
The draft proposes to include UV-328 in Annex I of the POPs Regulation for control, due to its potential to cause damage to the liver and kidneys and its endocrine-disrupting effects. Furthermore, the draft amends the exemptions for PFOA and its salts and related compounds in Annex I, setting a specific limit value for use in firefighting foam and extending the validity period of this exemption.
UV-328
Regarding UV-328 (CAS No: 25973-55-1, EC No: 247-384-8), the revised content of Annex I of the Regulation is as follows:
As per Article 4(1), point(b) of Regulation (EU) 2019/1021, where UV-328 is present as an unintentional trace contaminant in substances, mixtures, or articles, the limit values should be set in a phased approach as follows:
100 mg/kg (0.01% by weight) at the entry into force of this Regulation;
10 mg/kg (0.001% by weight) 2 years after the entry into force;
1 mg/kg (0.0001% by weight) 4 years after the entry into force.
The following cases are exempted for placing on the market of UV-328 present in articles and the use of such articles until 5 years after the entry into force:
in land-based motor vehicles;
in industrial coating for land based motor vehicles, engineering machines, rail transportation vehicles, and in heavy-duty coatings for large steel structures;
in mechanical separators in blood collection tubes;
in triacetyl cellulose film in polarisers;
in photographic paper;
in civilian and military aircrafts.
PFOA
For the specific exemptions of PFOA and its salts and related compounds (CAS numbers: 335-67-1, etc., EC numbers: 206-397-9, etc.), some entries have been modified.
In particular, the amendments introduced points 4a and 4b regarding the specific Unintentional Trace Contaminant (UTC) limit values for PFOA present in fire-fighting foams as follows:
As per Article 4(1), point(b) of Regulation (EU) 2019/1021,
For PFOA or any of its salts present as unintentional trace contaminant in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, the limit value is 1 mg/kg (0.0001% by weight). This UTC limit value shall apply until 3 years after the entry into force.
For any individual PFOA-related compound or combination of PFOA-related compounds present as unintentional trace contaminant in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, the UTC limit value is 10 mg/kg (0.001% by weight). This limit value shall apply until 3 years after the entry into force.
For the sum of the concentration of PFOA, its salts and PFOA-related compounds present as unintentional trace contaminant in fluorine-free fire-fighting foam and originate from fire-fighting equipment which has undergone cleaning in accordance with the best available techniques, the UTC limit value is 10 mg/kg (0.001% by weight).
For point 6, the validity period for exemption as present in fire-fighting foam is extended from July 4, 2025 to December 3, 2025.
The amendment also added point 11, which specified that articles containing PFOA, its salts or related compounds already in use in the Union before or on the date of expiry of the exemption laid down in points 5 (a) to (d)* may continue to be used.
The delegated regulation and Annex for UV-328 and PFOA are available here.
