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The European Commission recently announced significant amendments to Annex I of Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), specifically addressing the substances UV-328 and perfluorooctanoic acid (PFOA), its salts, and PFOA-related compounds. These revisions, detailed in Commission Delegated Regulation (EU) 2025/843 and Commission Delegated Regulation (EU) 2025/1399, aim to further restrict the presence and use of these hazardous chemicals within the European Union.
Amendments Concerning UV-328
Commission Delegated Regulation (EU) 2025/843 specifically addresses UV-328 (2-(2H-benzotriazol-2-yl)-4,6-di-tert-pentylphenol, CAS No. 25973-55-1), a substance primarily used as a UV absorber. The regulation introduces new, progressively stricter concentration limits for UV-328 when present as an unintentional trace contaminant (UTC) in substances, mixtures, or articles. These limits are set to decrease over time to ensure a gradual phase-out and allow industries to adapt.
Revised UTC Limits for UV-328:
| Effective Date | Concentration Limit |
| August 4, 2025 | 100 mg/kg (0.01%) |
| August 4, 2027 | 10 mg/kg (0.001%) |
| August 4, 2029 | 1 mg/kg (0.0001%) |
Recognizing the complexity of certain industrial applications and the need for a transition period, the regulation also outlines specific derogations for the placing on the market and use of articles containing UV-328. These exemptions are generally valid until August 4, 2030, unless otherwise specified, and cover a range of critical sectors:
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.
For spare parts in land-based motor vehicles, stationary industrial machines for agriculture, forestry, and construction, and liquid crystal displays in instruments for analysis, measurements, control, monitoring, testing, production, and inspection (excluding medical applications), where UV-328 was originally used, the exemption extends until the end of their service life or December 31, 2043, whichever comes earlier. For liquid crystal displays in medical devices (Regulation (EU) 2017/745 and (EU) 2017/746) and other analytical instruments, the exemption for spare parts lasts until the end of their service life. Spare parts for civilian and military aircrafts are exempted until December 31, 2030.
Amendments Concerning PFOA, its Salts, and Related Compounds
Commission Delegated Regulation (EU) 2025/1399 introduces several key changes to the regulation of perfluorooctanoic acid (PFOA), its salts, and PFOA-related compounds. One significant amendment involves new specific UTC limits for PFOA in fire-fighting foams:
For fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems:
Concentrations of PFOA or any of its salts must be equal to or below 1 mg/kg (0.0001 % by weight).
Concentrations of any individual PFOA-related compound or combination of PFOA-related compounds must be equal to or below 10 mg/kg (0.001 % by weight).
- These limit values will apply until August 3, 2028.
For fluorine-free firefighting foam originating from firefighting equipment that has undergone cleaning in accordance with the best available techniques:
- The sum of the concentration of PFOA, its salts, and PFOA-related compounds must be equal to or below 10 mg/kg (0.001 % by weight).
In addition, for fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in system, the transitional period for certain applications, such as testing and training purposes, is extended from July 4, 2025 to December 3, 2025.
