CoRAP 2026-2028: Benzotriazoles and the new era of PMT/vPvM control

On December 9, 2025, ECHA published the draft Community Rolling Action Plan (CoRAP) for the 2026-2028 period. The data show clearly: benzotriazole UV stabilizers are under the strictest evaluation. Six different benzotriazole compounds, all flagged as PMT/vPvM substances, are coming under regulatory scrutiny. For Serbian companies that use plastic coatings, automotive components or polymer materials, this is not a distant forecast – it is an immediate reality that calls for action.

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📋 QUICK OVERVIEW

✓ 28 substances in CoRAP 2026-2028
✓ 6 benzotriazoles under PMT/vPvM evaluation
✓ 17 substances for 2026, 10 for 2027-2028
✓ Final version: March 24, 2026
✓ Impact: plastics, paints, automotive components, electronics

DEADLINE FOR ACTION: January-March 2026

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What CoRAP is and why it should concern you

The Community Rolling Action Plan (CoRAP) is ECHA’s tool for prioritizing substances that will undergo detailed evaluation under REACH (Articles 44-48). This is not an ordinary list. Substances on the CoRAP list have been identified as a potential risk to human health or the environment. EU member states are obliged to evaluate them and, where necessary, request additional data from registrants.

The draft CoRAP 2026-2028 covers 28 substances:

• 17 substances for evaluation in 2026
• 10 substances spread across 2027 and 2028
• 8 entirely new substances compared with the current CoRAP 2025-2027
• 1 substance withdrawn from the list

The Member State Committee will give its opinion on the draft in February 2026. We expect the final version on March 24, 2026.

The benzotriazole offensive: six substances, one type of hazard

The central theme of this draft is benzotriazole UV stabilizers. Of the 17 substances planned for evaluation in 2026, 6 are benzotriazoles. All are flagged with the same hazard concern: PMT (Persistent, Mobile and Toxic) or vPvM (very Persistent and very Mobile).

List of benzotriazoles under evaluation:

For evaluation in 2026 (all evaluated by Spain):

1. Mixture of branched and linear C7-C9 alkyl propionates with a benzotriazole structure (EC 407-000-3)
2. Polyethylene glycol esters of benzotriazole propionic acid and their dimers (EC 400-830-7)
3. Methyl-3-[3-(2H-benzotriazol-2-yl)-4-hydroxy-5-(2-methyl-2-propanyl)phenyl]propanoate (EC 400-820-2, CAS 84268-33-7)
4. Reaction mixture of octyl/2-ethylhexyl benzotriazole propionates with chlorine substitution (EC 916-914-6)
5. Di-substituted tert-alkyl benzotriazole propanoate (EC – confidential)

For evaluation in 2027 (Spain):

6. Mixture of isomers of 2-(2H-benzotriazol-2-yl)-4-methyl dodecyl/tetracosyl phenol (EC 401-680-5, CAS 125304-04-3) – flagged as PBT/vPvB

All six substances share the same characteristics:

• Widespread use across different industries
• Significant environmental exposure
• Evaluation focused on persistence and mobility in the environment

PMT/vPvM: A new paradigm in regulatory control

This brings us to the key change in the regulators’ approach.

WHAT DOES PMT/vPvM MEAN?

P = Persistent
The substance does not break down easily in the environment

M = Mobile
It travels through water and soil without binding

T = Toxic (
Harmful to human health or nature

vP/vM = very persistent and very mobile
An extreme expression of these properties

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Traditional approach vs. new approach

Traditional approach: PBT/vPvB (Persistent, Bioaccumulative, Toxic)

• Focus on bioaccumulation in the tissues of organisms
• Problem: substances accumulate in the food chain
• Examples: PCBs, DDT, brominated flame retardants

New approach: PMT/vPvM (Persistent, Mobile, Toxic)

• Focus on mobility through water and soil
• Problem: contamination of groundwater and drinking water sources
• Examples: PFAS, many pesticides, benzotriazoles

Why does this matter?

PMT/vPvM substances do not have to accumulate in organisms to be a problem. Their mobility means that they:

1. Reach groundwater – once it is contaminated, the sources are hard to clean
2. Travel through soil – persistence + mobility = long-term contamination
3. End up in drinking water sources – direct human exposure
4. Are hard to remove – conventional water treatment is not effective

That is exactly why benzotriazoles are a textbook example of the PMT/vPvM problem. They are extremely stable in the aquatic environment, do not bind firmly to sediment (low Koc), and travel with water flows until they reach drinking water sources.

Where are benzotriazole UV stabilizers used?

Before you assess the risk, you need to understand where these substances are used. This is the key question for Serbian companies. The fact is that benzotriazoles are ubiquitous in modern industry.

Primary applications:

1. Plastics industry:

• Polymer coatings – protection against UV degradation
• PVC stabilization – longer product life
• Polypropylene and polyethylene – garden furniture, building materials
• Transparent plastics – food packaging, medical materials

2. Automotive sector:

• Clear topcoats – protection of automotive paint
• Plastic parts – dashboard, trim, exterior panels
• Polycarbonate glazing – headlights, signalling

3. Paints and varnishes:

• Industrial coatings – protection of metal surfaces
• Architectural paints – resistance to outdoor conditions
• Wood coatings – UV stabilization

4. Electronics:

• Device housings – UV resistance of plastic parts
• Cable insulation – longer service life
• Display materials – protection against discoloration

5. Personal care:

• Sun protection formulations – UV absorption
• Cosmetics packaging – product stability

Annual production:

Benzotriazole UV stabilizers are used in huge quantities. UV-328 alone (which is already under the Stockholm Convention) had confirmed annual imports into the EU of ~1,000 tonnes. The substances in the draft CoRAP have similar or higher annual production.

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⚠️ IMPORTANT WARNING

What does this mean for Serbian companies?

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Check whether this applies to you:

Does your company manufacture or use plastic materials with UV stabilizers? Do you import finished products containing polymers (cars, electronics)? Do you export products to the EU that may contain benzotriazoles? Do you work with paints and varnishes for industrial use?

If the answer to any of these questions is YES – you need to be on alert.

Regulatory timeline:

December 2025: Draft published
February 2026: Opinion of the Member State Committee
March 24, 2026: Final CoRAP 2026-2028 published
2026-2027: Substance evaluation under way
2027-2028: Possible regulatory consequences:

• Identification as an SVHC (Substance of Very High Concern)
• Inclusion in Annex XIV (authorisation)
• Inclusion in Annex XVII (restriction)
• National restrictions

The dual compliance reality in Serbia:

Serbian companies are in a specific situation:

For the domestic market:

• Serbian regulations are not yet aligned with these concerns
• Benzotriazoles are not specifically regulated

For exports to the EU:

• Immediate exposure to REACH requirements
• The need to comply with future restrictions
• Pressure through the supply chain from EU customers

In practice, this means the following: Exporting companies have to stay ahead of EU regulations. Even if Serbian law does not yet require compliance, your EU customers will.

Action plan: What you should do now

STEP 1 of 5: Supply chain mapping

DEADLINE: January-March 2026

• Identify all benzotriazoles in your products
• Check the safety data sheets (SDS) for UV stabilizers
• Contact your suppliers – ask for the detailed composition
• Take an inventory of products that contain polymer materials

Key questions for suppliers:

1. “Do your UV stabilizers contain benzotriazole structures?”
2. “What alternatives are available?”
3. “What is the timeline for a reformulation?”

STEP 2 of 5: Updating REACH documentation

DEADLINE: March-June 2026

If you are a registrant of any of these substances:

• ECHA explicitly calls for registrations to be updated before March 2026
• Add all relevant data on persistence and mobility
• Prepare for possible requests for additional testing

STEP 3 of 5: Assessing alternatives

DEADLINE: Throughout 2026

Start researching alternatives:

• Stabilizers without a benzotriazole structure (hindered amine light stabilizers – HALS, hydroxyphenyl triazines)
• Inorganic UV absorbers (ZnO, TiO2 – for certain applications)
• Alternative polymer formulations that need less UV stabilization

A realistic perspective: Finding an adequate alternative takes time (6-18 months) and performance testing.

STEP 4 of 5: Communication with EU customers

DEADLINE: Ongoing

If you export to the EU:

• Proactive communication with customers about your compliance status
• Prepare documentation on product composition
• Be ready for audit requests

STEP 5 of 5: Monitoring regulatory developments

DEADLINE: Ongoing

• February 2026: Committee opinion – check whether all substances remain
• March 2026: Final CoRAP – confirmation of the evaluation plan
• During 2026-2027: Evaluation reports – ECHA will publish its findings
• 2027+: Regulatory proposals – SVHC, restrictions, authorisations

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Frequently asked questions about CoRAP 2026-2028

Are benzotriazoles already banned?

No. CoRAP is an evaluation process, not a ban. However, the evaluation may lead to restrictions in the 2027-2029 period.

Does this also apply to products for the Serbian domestic market?

Not at the moment. Serbian regulations are not yet aligned. However, if you export to the EU, this concerns you right now.

What are the alternatives to benzotriazoles?

HALS (hindered amine light stabilizers) and hydroxyphenyl triazines are the main alternatives. But they require testing for your specific application – the process can take 6-18 months.

When should final restrictions be expected?

2027-2028 at the earliest. But proactive companies are starting to prepare now, because finding and testing alternatives takes time.

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Conclusion: Early action or reactive scramble

The draft CoRAP 2026-2028 is not a surprise – the EU trend towards PMT/vPvM control has been clear for several years. However, the number of benzotriazoles under evaluation and the speed at which this is developing indicate that regulatory action is not a remote possibility. It is a likely reality in the 2027-2029 period.

For Serbian companies, the choice is clear:

Proactive approach:
Mapping, assessing alternatives, adapting the supply chain – starting right away

Reactive approach:
Waiting for final restrictions, an urgent hunt for alternatives, possible supply chain disruptions

In the dual compliance reality in which Serbian companies operate, staying ahead of the regulatory curve is not a luxury – it is a competitive advantage.

The question is not “whether benzotriazoles will be regulated”, but “when, and how quickly you can adapt”.