JBCE's Environment & Energy Committee submitted its views following the call for comments on the proposed restriction of UV-328 under EU POPs Regulation

27/08/2024

On 27^th August 2024, JBCE submitted its views on the proposed restriction of UV-328 under EU POPs Regulation.

JBCE welcomed the specific exemptions for spare parts proposed in Annex I of the UV-328 proposal but highlighted concerns about the proposed specific concentration limit and the applicable start date.

Indeed, for JBCE, the proposed specific concentration limit of 1 mg/kg (0,0001 % by weight = 1 ppm) or less is not realistic for electrical and electronic equipment (EEE) and therefore 1,000 ppm (0.1%) would be a more appropriate limit.

Regarding the applicable start date, for EEE not covered by the specific exemption for spare parts, the six months timeframe until the applicable start date is too tight for companies to process parts inventories and make necessary substitutions. JBCE urged the European Commission to consider a sufficient grace period for the applicable start date in the EU, as this short timeframe risks drastically shortening the lifetime of many end-use products.

 

For more information please contact:

Masakazu Shimosawa, Policy Manager, Environment & Energy

Tetsusaburo Miura, Policy Manager, Environment & Energy

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