ANALYSIS | PVC REGULATION
European Commission publishes regulation covering lead in PVC
New regulation includes specific measures to allow recycling of ‘legacy’ PVC compounds and reuse in new products
Following the rejection by the European Parliament in February 2020 of the European Commission’s derogations (special exclusions) covering recycling of legacy PVC compounds — which were part of a proposed wider update of restrictions on use of lead and lead compounds in PVC — the Commission has published a new and revised regulation. According to the Com-
mission, the new regulation addresses Parliament’s previous concerns while still including a number of derogations designed to achieve a balance between encouraging material circularity and mitigating long-term health risks. The original draft set a limit on the content of lead and its compounds in PVC articles used or placed on the market within the EU at 0.1% by weight and this is unchanged. As lead stabilis- ers are not effective at such low levels this limit effec- tively rules out their use. The 0.1% limit will not impact on European PVC producers, which voluntarily ended the use of lead stabilisers in their produc- tion in 2015. However, the inclusion of the limit in the new regulation should prevent imports of PVC
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The European Commission has introduced new rules covering lead levels in new and recycled PVC products
products and articles containing lead in to the EU. The key changes in the
new regulation are focused predominantly on deroga- tions for recycled materials. The original draft included derogations designed to allow recycling of PVC material recovered from end-of-life products manu- factured with lead stabilisers (so-called ‘legacy’ material). Limits of 2% for recycled rigid PVC and 1% for flexible formulations (where loss to the environment is more likely) were proposed. Those limits were set following detailed consid- eration by the European Chemical Agency (ECHA)’s Committee for Risk Assess- ment (RAC), which estimat- ed that successive recycling dilutions would see lead concentrations in recycled PVC materials fall to the 0.1% level over a period of 15-20 years. However, these derogations were rejected
COMPOUNDING WORLD | July 2023
by Members of the Euro- pean Parliament (MEPs)in 2020 due to concern over ‘carry-over’ of lead and the ongoing risk of exposure. The rejection of the
derogations caused concern for the PVC industry due to the potential impact on recycling. The European PVC industry’s VinylPlus programme has seen volumes of PVC recycled grow steadily since its inception in 2000. Accord- ing to the latest Progress Report, the industry recycled 813,226 tonnes of PVC in 2022 and is on course to recycle 1m tonnes by 2030 (total European PVC production amounted to around 6.5m tonnes in 2021, according to the most recent Plastics Europe data). Most of this recycled PVC
is sourced from long lifetime ‘legacy’ products such as window profiles, cables and roofing membranes, a considerable volume of
which is likely to have been produced before lead stabiliser use ended eight years ago. Without some form of derogation, the PVC industry argued that recycling of legacy material using current technology would have been extremely difficult, if not impossible. The original derogations
proposed by the Commis- sion were intended to leave a risk-managed recycling route open and were in line with the RAC’s assessment that alternatives to recycling, such as landfill or incineration, also presented potential environ- mental and health risk. Since the European
Parliament’s rejection, the Commission has revisited the derogations to address Parliament’s concerns. It has removed the derogation covering recycled flexible PVC from the new Regula- tion completely, while the original limit for recycled rigid PVC has been reduced
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