GALA Members Respond to ECHA’s Consultation on Draft Recommendation for Inclusion of UV326 and UV 329 into the Authorisation List (Annex XIV)

Introduction

We appreciate the opportunity to provide our comments to the European Chemicals Agency (ECHA) in the context of its public consultation on the draft recommendation to include UV-326 and UV-329 as priority substances in Annex XIV of the REACH Regulation. In addition, this document will be submitted to the Call for information (on behalf of the Commission) on the possible socio-economic consequences of the authorisation requirement for UV-326 and UV-329.

The Global Antioxidants and Light Stabilizers Alliance (GALA), established in 2026, is dedicated to advancing the scientific understanding of the intrinsic health and environmental properties of antioxidants (AOs) and light stabilizers (LS), while also highlighting their benefits. GALA actively communicates robust scientific information to stakeholders, ensuring accuracy, clarity, and consistency. In addition, it represents the global AO and LS technology sector, supporting its members and market organizations in their engagement with policymakers and regulatory authorities.

GALA’s membership comprises the leading global manufacturers of these substances, and its secretariat is managed by Consortia Management in Germany.

UV light stabilizers are a class of additives incorporated into materials - primarily polymers and coatings - to enable the intended end use of polymeric articles and extend the service life of end products by protecting them from the damaging effects of ultraviolet (UV) radiation.

They are used across a wide range of critical sectors and end user applications delivering both economic and environmental benefits. The applications, such as automotive components, construction materials, packaging materials, as well as in adhesives, sealants, and coatings are essential to society, as they underpin key areas including infrastructure, mobility, communication, energy generation, consumer goods, and industrial production. In doing so, these sectors support the functioning of economic markets, contribute to public safety, and enable the transition to a more sustainable and resilient economy through the extended lifespan of materials and products.

The two substances (UV-326 and UV-329) are manufactured and/or imported between 1.000 – < 10.000 tonnes per annum in the EU.

In January 2024, UV-326 and UV-329 were added to the Candidate List based on the MSC’s conclusion on their vPvB (very persistent, very bioaccumulative) assessment.

In 2024, the European Chemicals Agency (ECHA) published an Assessment of Regulatory Needs (ARN) for hydroxyphenyl benzotriazoles, including UV-326, UV-329. The ARN outlined a range of potential regulatory actions, including a possible restriction under REACH. The justification for further action highlighted that environmental releases occur from consumer and widespread professional uses, which are often non-contained and therefore lead to releases that are difficult to avoid.

Please note, that the intrinsic properties of certain UV stabilisers may lead to their identification as substances of concern under regulatory criteria. However, exactly these properties are inherent to, and necessary for, their effectiveness and performance as UV stabilisers. As a result, any substitution would likely require substances with similar intrinsic properties .

A ban on this group of substances could leave industry without viable alternatives in Europe, potentially leading to the relocation of manufacturing activities outside the EU.

In addition, we consider that other risk management measures are available to effectively control emissions and exposure to these substances.

This submission is accompanied by a report entitled “Risk Management and Emissions Reduction of Four UV Light Stabilisers” (Ricardo, 2026).