European Commission Proposes Ban on PVC Articles that Contain Lead

European Commission Proposes Ban on PVC Articles that Contain Lead

On July 12, 2019, the European Commission proposed a ban on polyvinyl chloride (PVC) articles containing lead or lead compounds in an effort to reduce lead release as well as direct and indirect lead exposure

This ban would have an impact on PVC products that use lead stabilizers, which are a popular additive for their cost-effectiveness, stability and durability. Companies currently using lead stabilizers will need to find alternatives such as calcium/zinc, organotin or barium/zinc stabilizers.

Under the ban, articles produced from PVC polymers or copolymers would be prohibited from containing lead and lead compounds, and PVC articles with a concentration of lead equal to or greater than 0.1 percent weight by weight of the PVC material would be banned from the EU market.

Timeframes & Regulations

The EC issued notice about the proposed ban to the World Trade Organization (WTO) on July 12, 2019. Stakeholders have a 60-day period to comment on the proposed ban, which ends on September 10, 2019, though the proposed implementation date for the ban will be sometime between July and September 2019. The ban would enter into force 20 days from its publication in the Official Journal of the EU.

Parties looking to provide feedback can contact the European Commission’s TBT Enquiry Point.

This proposed ban follows a 2015 risk management option analysis (RMOA) conducted by the European Chemicals Agency (ECHA) stating there was a need for a ban on lead stabilizers in PVC products. At that time, the European Stabiliser Producers Association commented that their industry was on course to substitute lead-based stabilizers in PVC throughout the EU by the end of 2015.

What Products Are in Scope?

Following the ECHA’s RMOA, companies were asked to voluntarily remove lead; however, this proposed ban would require the elimination of lead from EU-made PVC products as well as imported PVC products.

If approved, PVC products such as window fittings, pipes, tubes, wiring and cables would come in scope.

Lead use in products is currently restricted by the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation’s Candidate List of Substances of Very High Concern and Restricted Substances List. This regulation ensures that listed chemical substances are used properly and are gradually replaced with less harmful alternatives.

If the ban is accepted and enforced by the WTO, there will be a 24-month grace period for certain products. For example, enforcement of the ban on rigid and flexible recycled PVC material and PVC-silica separators in lead acid batteries would likely be deferred.

Collecting accurate supply chain data can help manufacturers track what goes into their products to ensure compliance with updates to legislation as they are made.

To learn how our Product Compliance Suite can streamline your supply chain data collection and reporting processes, email info@assentcompliance.com.

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