JBCE's Environment & Energy Committee submitted its views following the call for comments on the draft screening report on the presence and risk of the four phenolic benzotriazoles (UV-328 and others) in articles

17/08/2023

On 17^th August 2023, JBCE submitted its views on the draft screening report on the presence and risk of the four phenolic benzotriazoles (UV-328 and others) in articles.

 

Regarding ECHA’s draft screening report and specific information requests, JBCE strongly recommends ECHA to: (1) reflect in the EU POP Regulation all the specific exemptions of UV-328 in the Stockholm Convention decision to promote global trade and extend product lifespans including of the spare parts for electrical and electronic equipment (EEE), (2) set the UTC limit at 1,000 ppm considering many uncertain contamination pathways and analytical testing across complex supply chain of EEE.

Additionally, JBCE provides specific information for the application for photographic paper and TAC film in polarizers as well as available alternatives.

 

You can download our position below.

For more information please contact:

Masakazu Shimosawa, Policy Manager, Environment & Energy (This email address is being protected from spambots. You need JavaScript enabled to view it.)