REACH Committee should restrict lead stabilisers in PVCPlastics
A group of NGOs, including HEJSupport, sent a letter to the REACH Committee to urge them to restrict the use of lead in PVC as it will reduce the emissions of this highly toxic chemical.
Lead impairs neurobehavioral function, particularly as a result of childhood or fetal exposure and is linked to lower intelligence quotient (IQ). There is no safe threshold for lead exposure. In fact, there is evidence that lead’s impacts on children’s neurodevelopment are greatest at the very lowest doses. (1)
The restriction is feasible and affordable. Previous efforts to remove lead from PVC have been widely successful, and today most or all PVC sold in the EU is lead-free. ECHA rightly concludes that the investment, development, and testing costs associated with the restriction are “negligible”.
The EU PVC industry has today almost entirely phased out lead stabilisers. Most lead emissions from PVC sold in the EU today and in the future – around 90% – can be attributed to imported PVC articles.
EU-wide action is necessary. Although most human exposure to lead is due to historical emissions due to disposal, especially by incineration, the use of recycled PVC made of lead contaminated legacy PVC is also a source of human and environmental exposure to lead.
However, the proposal is not protective enough for the following reasons:
The scope is narrow as it excludes lead that is not used as stabiliser, such as leaded pigments. As acknowledged by the ECHA committees in the final opinion, “Restriction of any lead present in PVC (regardless of intended function) would contribute to addressing the risks identified in the proposal. In addition, it might not be readily apparent why lead is present in an article, so specifying a particular use might not be helpful from an enforcement perspective (the Forum for enforcement indicated in their advice that the restriction will be simpler to enforce if enforcement authorities do not have to demonstrate the function of any lead detected in PVC above the relevant concentration limit)”.
Also, the current proposal will lower the level of protection in Denmark, since the national rules are more restrictive than the proposed EU limit values. Moreover, it is obvious that stricter levels are possible since they are already implemented in Denmark and the industry started the phase out of lead in the 1980’s.
Furthermore, we vehemently reject the proposed higher concentrations of lead in recycled materials (2% and 1% for rigid and flexible PVC recyclate, respectively) compared to virgin material (0,1%). This derogation raises three main issues.
First, the proposal relies on flawed assumptions to conclude that recycling PVC containing lead will have a beneficial environmental and health impact.
Second, as a matter of fact this derogation goes against the EU objective to transition towards a circular economy.
Third, recycling is not an adequate waste management option for PVC containing lead.
(1) Canfield et al (2003). “Intellectual Impairment in Children with Blood Lead Concentrations below 10 μg per Deciliter.” New England Journal of Medicine 348(16): 1517–26. doi:10.1056/NEJMoa022848.