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You're right! But also, it's effectively the same as ionizing:

"UV-A and UV-B are technically non-ionizing, but all UV wavelengths can cause photochemical reactions that to some extent mimic ionization. For example, ultraviolet light, even in the non-ionizing range, can produce free radicals that induce cellular damage and can cause skin cancer."

https://radiation.ncdhhs.gov/NonIonizing/UVRad.htm#:~:text=U....




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