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Persistent organic pollutants - UV-328

Environment

Regulation on persistent organic pollutants implements the EU’s international commitments under the Stockholm Convention on persistent organic pollutants (chemical substances). The Conference of the Parties of the Stockholm Convention decided to list UV-328 in Annex A to the Convention. This initiative amends Annex I to the Regulation to include UV-328 as a substance subject to certain restrictions.

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Public consultation

ID: 13887

Lobbying Activity

10 responses

DIGITALEUROPE calls for higher trace limits on pollutant UV-328

DIGITALEUROPE, 27 Aug 2024

DIGITALEUROPE requests a higher trace limit for UV-328 to avoid supply chain disruptions. They claim the currently proposed limit is impossible for electronic manufacturers to monitor effectively.
This change would reduce the administrative burden and prevent potential manufacturing delays for electronics.

MedTech Europe seeks extended transition periods for UV-328 phase-out

MedTech Europe, 23 Aug 2024

The organization requests extended transition periods of 5-10 years for medical technology applications not covered by existing derogations. They argue that modifications to medical device chemical composition trigger stringent regulatory requirements under MDR/IVDR, including validation, clinical testing, and updates to certifications.
This would give them more time to comply while avoiding costly immediate redesigns of certified medical devices.

Plastics Recyclers Europe urges higher chemical trace limit

Plastics Recyclers Europe, 21 Aug 2024

They advocate setting the unintentional trace limit for UV-328 at 0.01%. They also request a verified scientific testing methodology for all substances.
Higher limits allow recyclers to continue operations using current testing technology.

Japan Business Council seeks higher chemical limits and grace period

Japan Business Council in Europe, 27 Aug 2024

JBCE proposes a concentration limit of 1,000 ppm to accommodate complex supply chains. They also request a grace period to avoid banning necessary spare parts too quickly.
This would lower compliance costs and allow companies to use existing stock.
Environmental protection efforts are weakened by allowing higher concentrations of toxic chemicals.

Construction industry seeks wider exemptions for UV-328 chemical ban

CECE - Committee for European Construction Equipment, 22 Aug 2024

The organization requests that the regulation explicitly include and cover non-road mobile machinery, mining, and power generation. They also stand for a transition period of 18 months to facilitate compliance efforts.
Broadened exemptions would provide legal certainty and safeguard the supply of replacement parts.
Environmental interests are harmed by extended timelines for phasing out hazardous chemical substances.

Consultation response

Arnika, z.s., 26 Aug 2024

Arnika is a Czech-based non-governmental organization promoting strict restriction of harmful chemicals and has advocated for toxics-free materials and products for over 20 years. As an organization regularly investigating the contamination of products with POP chemicals and responding regularly to…

Garden machinery federation seeks UV-328 spare parts derogation

European Garden Machinery industry Federation, 21 Aug 2024

EGMF requests an exemption for spare parts for garden and outdoor power equipment. This would allow the repair and reuse of machines placed on the market before the restriction.
This allows manufacturers to avoid costly re-engineering and testing of replacement components.
Environmental advocates lose as persistent pollutants remain in circulation via replacement parts.

Consultation response

Mitsubishi Electric Europe, 26 Aug 2024

Mitsubishi Electric Europe welcomes the opportunity to provide comments on the draft Delegated Regulation to list UV-328 in Annex I of the EUs POPs Regulation. UV-328 is regulated not only as a chemical substance but also as a content in articles according to Annex A of the global Stockholm…

Consultation response

The Japan Refrigeration and Air Conditioning Industry Association, 27 Aug 2024

The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) representing manufacturers of refrigeration and air conditioning equipment in Japan is continuously pursuing and supporting the development of environmentally friendly technologies to contribute to the conservation of the…

Engine manufacturers seek broader exemptions for UV-328 chemical restrictions

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, 23 Aug 2024

EUROMOT requests broader exemptions for non-road machinery, marine vessels, and rail locomotives. They also seek an 18-month transition period to identify chemicals in complex engine components.
Broad exemptions prevent the costly redesign and premature disposal of complex machinery.