PVC | REGULATION


between the EU’s circular economy goals and the management of restricted substances under the Reach directive and administered by the European Chemical Agency (ECHA). The ECHA proposed a threshold of 0.1% lead content for articles not containing recycled PVC, and for some construc- tion applications there would be a 15-year deroga- tion with a higher limit of lead content for articles using PVC recyclate. VinylPlus submitted comments and information to ECHA, including the results of independent studies into safe levels of lead stabilisers in rigid PVC. The ECHA’s Committees for Risk Assessment and Socio-Economic Analysis (SEAC) assessed the information from all stakehold- ers and held a public consultation on the SEAC draft opinion earlier this year. VinylPlus provided Plastics Recycling World with


an update on legacy additives and when there may be an official announcement. Brigitte Dero said: “The Committees of the European Chemical Agency concluded in favour of allowing for 15 years the recycling of PVC waste containing lead up to concentrations which should allow most recycling to go on, because the conditions applied ensure that the risk is controlled. The decision is now in the hands of the Commission, which will propose legislative measures. In view of the wider discussions regarding the interface between waste and product legislation, it is difficult to predict a precise timing.” VinylPlus has engaged The Natural Step, an NGO based in Sweden, as an external advisor on sustainability issues, including the issue of legacy additives. At the request of the VinylPlus Controlled- Loop Committee, The Natural Step conducted an analysis using the sustainability principles it has developed to evaluate the issue and “to consider the best current waste management option for rigid PVC articles when ‘back casting’ from full alignment with sustainability principles in the longer term”. In The Natural Step’s subsequent report, Legacy additives in rigid PVC and progress towards


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sustainability, it said its analysis indicated that alternatives to recycling rigid PVC, such as landfill- ing and incineration, would breach sustainability principles. It said: “Our long-standing conclusion is that all PVC articles need to be optimised for and managed within a controlled-loop system in order to align with the principles of sustainability advo- cated by The Natural Step. A closer look at man- agement options for rigid PVC waste from window profiles and pipes suggests that legacy additives are not likely to ‘leak out’ from recycled materials, and the reuse of this waste stream is preferable to the alternative disposal routes assessed.” It added that “so long as safe handling and ongoing VinylPlus commitments to achieving controlled- loop management of PVC remain in place, it is likely that the concentration of legacy additives will continue to decline in the material flow as newer PVC formulations enter the recycling stream”. The European Commission recognised the


difficulty of legacy substances in its Plastics Strategy announced in January and dedicated a section to the issue in its announcement. It said: “The issue of legacy substances will continue to constitute a barrier to the circular economy and, therefore, we will take steps to develop a specific decision-making methodology to support deci- sions on the recyclability of waste containing substances of concern. This methodology will take into account the overall cost-benefit of recycling a material compared to its disposal (including incineration with energy recovery). We expect to finish this work by mid-2019.” The regulatory difficulty is highlighted by another part of the PVC legacy additives issue: phthalate plasticisers. Many phthalates have been restricted by ECHA, including DEHP, which has been widely used as a plasticiser in vinyl flooring but was restricted by ECHA. In 2016, the Commis- sion backed a recommendation by ECHA to grant a


Left: Vinyl flooring is a market for recycled PVC containing DEHP


plasticiser


Below: Legacy additives, such as stabilisers used in PVC pipes, are the subject of regulatory conflict


November/December 2018 | PLASTICS RECYCLING WORLD 13


PHOTO: ANDREA LOPEZ, WIKIMEDIA COMMONS


PHOTO: EMERY OLEOCHEMICALS


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