UV-328 in Aeronautics: Exemption Until 2030 and What Manufacturers Must Do

Key data

If your company manufactures waterproofing tapes, adhesives, or coatings for aircraft and uses UV-328 in its formulations, you have a defined time window: until December 31, 2030. The amendment to the Stockholm Convention, adopted through Decision SC-12/14 and in force for Spain since October 9, 2026, classifies UV-328 as a persistent organic pollutant (POP) and imposes its gradual elimination, with a temporary exemption strictly limited to the aerospace sector.

The exemption is not a general authorization: it only covers the use of the compound in specific aerospace applications. Independent production and general commercialization of UV-328 are not covered by this exemption.

What does this regulation establish?

The Stockholm Convention regulates persistent organic pollutants (POPs), substances that do not degrade easily in the environment and accumulate in the food chain. Decision SC-12/14 incorporates UV-328 into Annex A of the convention, which implies its elimination as a general rule.

However, the amendment recognizes that certain aerospace materials do not yet have viable technical alternatives, so it establishes a temporary use exemption until December 31, 2030. The materials and applications expressly authorized are:

Outside these applications, UV-328 is subject to the general restrictions of the Stockholm Convention. The exemption does not cover the manufacture of the compound for other purposes or its sale as an independent product.

Economic and operational impact

The impact is not immediate in direct costs, but rather in R&D planning and supply chain. Companies that depend on UV-328 in their formulations must assume that, from 2031 onwards, any batch produced with this compound for aerospace use will be outside the law.

The main cost vectors are:

• Product reformulation: identifying and validating alternatives to UV-328 in aerospace adhesives and coatings requires R&D cycles that can extend 2-4 years, especially if materials must pass aerospace certifications (EASA, FAA).
• Component recertification: any change in the formulation of an aerospace material requires technical validation and, in many cases, recertification by the competent aerospace authority.
• Review of contracts with OEM customers: aircraft manufacturers (OEMs) may require the update of material specifications before 2030.
• Inventory management: inventories of materials with UV-328 must be consumed or managed before the exemption expires.

With four years until expiration, the margin exists, but aerospace certification processes are slow. Those who start in 2027 or 2028 may be too late.

Who does it affect?

• Manufacturers of waterproofing tapes for aerospace applications that use UV-328 as a UV stabilizer.
• Manufacturers of polyurethane and polyamide adhesives for the aerospace industry.
• Manufacturers of coatings and paints for structural, mechanical, electrical, and flight control systems of aircraft.
• Tier 1 and Tier 2 suppliers in the aerospace supply chain that supply any of the above materials.
• Procurement and quality departments of aircraft manufacturers (OEMs) that must verify supplier compliance before 2031.
• Regulatory compliance advisors and sustainability managers in aerospace companies.

Practical example

A Spanish company that manufactures coatings for electrical systems of aircraft and uses UV-328 as a stabilizer against ultraviolet radiation can continue producing and supplying that coating until December 31, 2030, covered by the exemption of Decision SC-12/14.

However, if by January 2027 it has not initiated the process of searching for and validating an alternative UV stabilizer, it is likely that by 2030 it will not have a reformulated product with the necessary aerospace certifications. The result: loss of contracts with OEM customers that require materials compliant with the Stockholm Convention from 2031 onwards, or suspension of supplies until recertification is completed.

The four-year window is sufficient, but only if planning begins now.

What should companies do now?

1. Audit UV-328 use in current formulations: identify which products in the portfolio contain UV-328 and in what volume it is used, distinguishing aerospace applications from others.
2. Verify if the use is within the scope of the exemption: only the seven types of materials listed in Decision SC-12/14 are covered. Uses outside that list are not covered.
3. Initiate the process of searching for technical alternatives: contact UV stabilizer suppliers to identify substitutes compatible with aerospace specifications.
4. Plan the recertification process: estimate times and costs of technical validation and recertification before EASA or other competent authorities for reformulated products.
5. Review contracts with OEM customers: check if supply contracts include regulatory compliance clauses that require anticipating the transition before 2030.
6. Establish a transition plan with annual milestones: set internal dates to complete reformulation, validation, and recertification before December 31, 2030.

Official source

Consult complete regulation at official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-22609