Response to ECHA consultation on the proposal for a new REACH restriction on lead compounds in PVC

Published: 24 July 2017

Policies & Issues: Environment

The European Chemicals Agency (ECHA) has invited feedback from stakeholders on the draft proposal for a restriction under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. This would apply to lead compounds used in articles or article parts made from polymers or copolymers of PVC, in cases where a certain degree of lead concentration is reached.

Electrical and electronic equipment (EEE) has been excluded from the scope of this proposed REACH restriction, due to the fact that the same restriction already applies under the RoHS Directive. Orgalime supports this decision, as it avoids unnecessary overlap and conflict between the two pieces of legislation. However, as the current wording does not exclude EEE components, we have requested that it be adjusted to make clear that this exclusion will also apply to these components. We believe this will avoid market distortions and ensure a level playing field and fair treatment of the EEE components placed on the EU market before being assembled in final EEE.

Authors

Linher
Sigrid Linher
Director - Energy, Climate & Environment
Mittelham
Stéphanie Mittelham
Manager - Energy and Environment

Related Position Papers

Environment: Orgalim preliminary key messages for the upcoming revision of the EU Waste Framework Directive Orgalim [11 August 2022]

Environment: Position and recommendations from Europe’s technology industries on the proposed Ecodesign for Sustainable Products Regulation [1 June 2022]

Environment: Orgalim position paper on the upcoming revision of the RoHS Directive [31 May 2022]

Environment: Orgalim position on the upcoming revision of the REACH Regulation [13 April 2022]

Environment: Orgalim Position Paper on the “right to repair” [5 April 2022]

Environment: Orgalim Position Paper on the restriction of PFAS [27 January 2022]

Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]

Environment: Joint industry position paper on the concept of Essential Use [3 November 2021]

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]