On 18 January 2024, ECHA published a screening report on four benzotriazoles. This report aims to access whether the use of these four benzotriazoles in articles should be restricted in accordance with Article 69(2) of REACH.
Details of these four benzotriazoles are listed in the following Table:
| Annex XIV entry | Substance Name | Abbreviation | EC | CAS NO. | Intrinsic property |
| 51 | 2-(2Hbenzotriazol-2-yl)- 4,6- ditertpentylphenol | UV-328 | 247-384-8 | 25973-55-1 |
PBT vPvB |
| 52 |
2,4-di-tert-butyl6-(5-chlorobenzotriazol2-yl) phenol |
UV-327 | 223-383-8 | 3864-99-1 | vPvB |
| 53 | 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl) phenol | UV-350 | 253-037-1 | 36437-37-3 | vPvB |
| 54 | 2-benzotriazol-2- yl-4,6-di-tertbutylphenol | UV-320 | 223-346-6 | 3846-71-7 |
PBT vPvB |
Based on available evidences, ECHA considers to restrict or prohibit the use (or presence) of UV-320, UV-350 and UV-327 in articles and prepare an Annex XV dossier for restriction uses of these substances in articles with the following reasons:
- UV-327, UV-350 and UV-320 exhibit vPvB and PBT properties that may pose significant risks to the environment that is not adequately controlled;
- Exposure threshold to UV-327, UV-350, and UV-320 can be determined;
- UV-327, UV-350, and UV-320 have not been proposed to be reviewed under the Stockholm Convention. Therefore, their risk management is not governed by the EU POP regulation.
The listing of UV-328 in Annex A of the Stockholm Convention is currently ongoing and it will lead to the discontinuation of its use globally, except in exempted uses such as spare or replacement parts. ECHA considers that it is not necessary to prepare an Annex XV dossier for restriction uses of UV-328.
UV-328 is the sole benzotriazole substance registered under the EU's REACH regulation. It is primarily imported into the EU from Asia, with an annual confirmed import volume of approximately 1,000 tonnes. Japan also issued a draft restriction on UV-328 in December 2023 to safeguard public health.
Hazards of UV-327, UV-350, UV-320, UV-328
These four benzotriazoles, are commonly used as UV absorbers in various organic materials such as plastics, rubbers, and resins. They are highly persistent in the environment and can accumulate in living organisms due to their poor biodegradability. The report highlights the challenge of predicting the long-term effects of these compounds and the difficulty of reversing environmental and biological exposure risks once they are present, even if releases cease.
Understanding of Annex XIV and Annex XV
In the EU's REACH regulation, the mechanisms of authorisation (under Annex XIV) and restriction (under Annex XVII) operate concurrently to establish a comprehensive safety protocol. Authorisation measures restrict the use of certain chemicals by setting temporary use periods. Once the temporary use period has expired, the corresponding substance is prohibited from being sold on the EU market. The purpose of restrictions is to control the maximum permitted concentration of certain substances in products or to limit their use to certain specific applications. It is crucial to understand that substances classified as 'restricted' under Annex XVII are typically not found in the 'authorised' list under Annex XIV. This distinction underscores their separate roles and objectives within the REACH system.
ChemRadar Insights
The Stockholm Convention is planning a global ban on UV-328, projected within the next few years, while UV-320, UV-327, and UV-350 are currently not regulated outside the European Economic Area (EEA), Switzerland, and the UK. ECHA aims to effectively reduce imports of products containing these substances, thereby diminishing emissions into EU environments.
The timeline for this regulation is still under consideration. ChemRadar will stay updated on developments.
