Singapore: National Environment Agency provides update on exemptions for Dechlorane Plus and UV-328 for medical devices

In brief

On 12 November 2024, the National Environment Agency (NEA) of Singapore issued an update regarding the exemptions for Dechlorane Plus and UV-328 under the Stockholm Convention on Persistent Organic Pollutants (POPs). This update follows the 11th Conference of the Parties to the Stockholm Convention held in May 2023, where state parties agreed to eliminate these substances with certain specific exemptions.

The ban exemption in relation to Dechlorane Plus and UV-328 is extended to all medical devices in the First Schedule of the Health Products Act 2007 in Singapore and will be subject to further review.


Exemptions for Dechlorane Plus and UV-328

At the 11th Convention on POPs, state parties agreed to adopt Dechlorane Plus and UV-328 in Annex A to the Stockholm Convention for elimination with certain specific exemptions.

On 6 May 2024, the NEA informed industry stakeholders that the manufacture, import and export of these substances, as well as products containing them, will not be allowed in Singapore from 26 February 2025 onwards, in line with the deadline stipulated by the Stockholm Convention. However, following industry feedback which the NEA had carefully considered, the NEA has decided to exempt certain uses and applications of Dechlorane Plus and UV-328 from the requirement to eliminate these substances from such uses and applications. These exemptions, listed in Annex I of the NEA's Circular (see here), include applications in medical devices, aerospace, space and defense, motor vehicles, industrial machines, and more. The exemptions will undergo future evaluations depending on the availability of suitable alternatives, and industry stakeholders will be involved in these assessments.

Effective date for phase-out

The deadline to cease the production, importation and exportation of Dechlorane Plus and UV-328, along with their products, for uses not specified in Annex I, is still set for 26 February 2025. Traders must use the correct Harmonised System (HS) and Product Codes when submitting their import and export TradeNet permit applications, as detailed in Annex II. For the avoidance of doubt, medical devices in the First Schedule of the Health Products Act 2007 are exempt in relation to the Dechlorane Plus and UV-328 ban and, at this juncture, will not be subject to the phasing out for 26 February 2025 until any further announcement from the NEA.

Key takeaways

The NEA's decision to provide exemptions for specific uses of Dechlorane Plus and UV-328 acknowledges the critical role these substances play in certain industries and the current absence of viable alternatives. Nevertheless, the phase-out for other uses will proceed as planned, demonstrating commitment to uphold the spirit of the Stockholm Convention and the broader goal of eliminating POPs. The NEA's announcement is a welcome development for the medical device industry in Singapore, as it will minimize disruptions to the supply chain and ensure continuity in patient care and access to treatment. Industry stakeholders should continue to keep abreast of regulatory developments in this space and monitor the evolving requirements.

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