EU POPs

September 8, 2025 | Written by GreenSoft Technology, Inc.

EU moves forward with UV-328 and Dechlorane Plus EU POPs Implementation

The UV-328 Prohibition has Entered into Force

May 2023 marked the pivotal moment when the Stockholm Convention, at its eleventh Conference of the Parties (COP-11), agreed to list UV-328 in Annex A (elimination). Limited exemptions were allowed for critical uses in industries such as automotive, aerospace, and electronics.

The EU carried this global decision into law in 2025:

• May 5, 2025 – Delegated regulation adopted by the European Commission
• July 15, 2025 – Regulation (EU) 2025/843 was published in the Official Journal, amending EU POP Regulation (EU) 2019/1021 to add UV-328 to Annex I
• August 4, 2025 – Regulation entered into force, prohibiting the manufacture, placing on the market, and use of UV-328 became prohibited in the EU, with exemptions

Unintentional Trace Contaminant (UTC) Limits

The regulation establishes a phased approach to Unintentional Trace Contaminant (UTC) thresholds:

• ≤100 mg/kg from 2025
• ≤10 mg/kg from 2027
• ≤1 mg/kg from 2029

Exemptions typically expire in 2030, though spare parts may remain permissible until December 31, 2043.

UV-328 Exemptions

Time-Limited Exemptions (Valid Until August 4, 2030)

The placing on the market and use of articles containing UV-328 are permitted for the following categories:

• Land-based motor vehicles
• Industrial coatings for land-based motor vehicles, engineering machines, rail vehicles, and heavy-duty coatings for large steel structures
• Mechanical separators in blood collection tubes
• Triacetyl cellulose film used in polarizers
• Photographic paper and imaging products
• Civilian and military aircraft

Exemptions for Spare Parts (Extended Use up to 2043)

• Land-based motor vehicles
• Stationary industrial machines for agriculture, forestry, and construction
• Liquid crystal displays in instruments used for analysis, measurement, control, monitoring, testing, production, and inspection (excluding medical applications)
• Liquid crystal displays in devices under Regulations (EU) 2017/745 and/or 2017/746 (i.e., medical devices and in vitro diagnostic devices)
• Liquid crystal displays in instruments for analysis, measurements, control, testing, production and inspection.
• Civilian and military aircraft (spare parts only), until 31 December 2030

Articles Already in Use

• Articles containing UV-328 that were already in use in the EU before or on the expiry date of their specific exemption may continue to be used thereafter.

The Dechlorane Plus Prohibition is Still Pending

At the same Stockholm Convention COP-11 Conference in May 2023, Dechlorane Plus was also listed in Annex A (elimination), with exemptions for aerospace and some automotive uses.

The EU followed through with its own legislative action in 2025. The delegated regulation was adopted on May 15, 2025. However, publication in the Official Journal is still pending.

Unintentional Trace Contaminant (UTC) Limits

The regulation establishes a phased approach to Unintentional Trace Contaminant (UTC) thresholds:

• ≤1,000 mg/kg upon entry into force
• ≤1 mg/kg after 30 months (expected December 2027)

Exemptions run until 2030, with a possible extension to 2035, while spare part allowances also extend to 2043.

Dechlorane Plus Exemptions

Time-Limited Exemptions

These applications are permitted for up to five years after the regulation’s entry into force: aerospace, space, defense, and medical imaging applications; radiotherapy devices and installations.

Spare Parts Exemptions

Certain spare parts can continue to contain Dechlorane Plus, but only until the end of their service life or until December 31, 2043, whichever comes first. This applies to parts for:

• Land-based motor vehicles
• Stationary industrial machines for use in agriculture, forestry and construction
• Marine, garden, forestry, and outdoor power equipment
• Aerospace, space, and defense applications
• Instruments for analysis, measurements, control, monitoring, testing, production and inspection.
• Medical devices and accessories under Regulations (EU) 2017/745 and/or 2017/746 (i.e., medical devices and in vitro diagnostic devices)

Articles Already in Use

Articles containing Dechlorane Plus that were placed on the market under valid exemptions and were already in use by the time an exemption expires may continue being used.

What These Prohibitions Mean for You

The bans on UV-328 and Dechlorane Plus under EU POPs highlight how international chemical management decisions quickly translate into enforceable EU restrictions, often with phased compliance deadlines and narrowly defined exemptions. For manufacturers, these changes mean reviewing supply chains, reassessing material declarations, and ensuring that your products align with the updated EU POPs Regulation.

GreenSoft’s EU POPs Data Services

To ensure compliance with the evolving EU POPs regulation, GreenSoft Technology offers a comprehensive solution for electronics manufacturers.

Our team specializes in data collection, validation, and reporting to help companies identify and track Persistent Organic Pollutants (POPs), including UV-328 and Dechlorane Plus, in their supply chain.

We work directly with your suppliers to gather accurate substance data, ensuring your products meet regulatory requirements.

Stay ahead of regulatory shifts and protect both your products and your business with GreenSoft's EU POPs Data Services. Contact us to learn more or schedule a personalized demo.