News Brief
On 2 February 2026, the European Chemicals Agency (ECHA) published its 13th draft recommendation for the REACH Authorisation List (Annex XIV), proposing the inclusion of four substances: UV absorbers UV-326 and UV-329, triphenyl phosphate (TPP), and photoinitiator 379.
The draft is currently open for a three-month public consultation (until 2 May 2026). Relevant industry stakeholders who have objections or suggestions regarding the draft are encouraged to actively submit feedback on aspects such as substance uses, substitution possibilities, and socioeconomic impact during this period.
It is noteworthy that all four substances were only added to the SVHC Candidate List in 2024. Being proposed for authorisation approximately two years later demonstrates that the EU is adopting a faster and more proactive control strategy for highly hazardous substances. This also implies that the compliance response window for affected companies is narrowing, potentially leading to more stringent regulatory requirements in the future and necessitating a quicker transition to safer alternatives.
Details of the Proposed Substances
UV-326 and UV-329, as benzotriazole-class UV absorbers, are extensively used in outdoor weathering applications for plastics, coatings, and rubber. Within the EU market, annual usage of these substances reaches thousands of tonnes. However, due to their very persistent and very bioaccumulative (vPvB) properties, they pose long-term potential risks to the environment.
Triphenyl phosphate (TPP), a traditional flame retardant and plasticizer, is widely used in engineering plastics, adhesives, hydraulic fluids, and other fields. According to EU assessments, its annual usage within the EU ranges from hundreds to thousands of tonnes, and it has been confirmed to possess endocrine-disrupting properties (for the environment).
Photoinitiator 379 is a key component in high-end UV curing systems. In the EU market, its annual usage similarly falls within the range of hundreds to thousands of tonnes. It is primarily used in high-performance inks and coatings and has been clearly identified as toxic to reproduction.
Based on the significant scale of use, wide range of applications, and clear hazards to health and the environment within the EU market, the EU regulatory authorities have decided to include these substances in the Authorisation List to strengthen control and promote substitution. This regulatory move will directly impact domestic producers and exporters, compelling the entire industry to accelerate the assessment of alternatives or proactively prepare for the challenges of authorisation compliance.
Once a substance is formally included in REACH Annex XIV (the Authorisation List), relevant companies must cease placing it on the EU market or using it after the "sunset date", unless they have obtained an authorisation for a specific use or the use is exempted.
If a company wishes to continue using the substance, it must submit a complete authorisation application to ECHA before the "latest application date" (LAD). This application process is complex, time-consuming, and costly. It is important to note that the specific sunset date and latest application date will only be determined once the substances are formally added to the Authorisation List.
Recommendations for Companies
Conduct a comprehensive substance screening: Immediately check product formulations and supply chains for the presence of these four substances and assess their usage and dependency within your operations.
Adopt a dual-track strategy: On one hand, actively research and test alternative substances or technologies. On the other hand, evaluate the necessity for continued use and begin preparing the data required for an authorisation application (e.g., exposure scenarios, risk control measures, alternatives analysis, socioeconomic impact assessment). This preparatory work typically requires over 18 months.
Monitor closely and participate in the consultation: During the current consultation period, submit data- and science-based comments to ECHA on aspects such as the scope of uses and potential grounds for exemptions.
Strengthen supply chain collaboration: Communicate this regulatory development immediately with upstream and downstream partners to jointly assess risks, negotiate response plans, and ensure compliance and continuity across the supply chain.
ECHA's swift action in proposing these substances for authorisation serves as a clear warning to the affected industries. The pace of regulation is accelerating, and compliance costs are set to rise significantly.
Relevant industries should take this signal seriously and utilise the potentially remaining 3-5 year window from now until the sunset dates to systematically plan for the future, ensuring long-term market access for their products in the EU.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
