EPPA welcomes the lead (pb) in PVC REACH restriction adopted by the European Commission

Date: 9 May 2023

The just published legal text adopted after joint legislative action of the Commission, Member States and the European Parliament prohibits the placing on the markets of PVC articles containing lead. The restriction applies to all PVC articles that cannot be recycled in a closed loop and thereby explicitly exempts PVC profiles which contain lead as a legacy additive in recyclate from old PVC window profile waste.

EPPA welcomes this regulatory measure that prevents any import of new lead in PVC to the European market. EPPA members have completed the phase out of lead (pb) as a stabilizer in 2004 and since then use calcium zinc (cazn) stabilizers in new PVC profiles.

At the same time, the European legislator has indicated its clear commitments towards the Circular Economy by explicitly derogating the continued existence of lead (pb) as a legacy additive in PVC recyclate (rPVC-U) that is used in the production of new PVC profiles for construction applications. "The PVC window profile industry has implemented a closed material loop over the past 25 years. Our production and recycling sites keep the PVC material in a traceable loop from PVC profile to PVC profile. Recycling PVC – and its legacy additive lead – in a closed loop has proven to be the most sustainable management of the material and substance. We welcome that the EU legislator acknowledges this fact and we will continue to invest into this closed loop for our application", says Carsten Heuer, EPPA President.

In view of EPPA's commitment to collect, recycle and use the recyclate from 50% of the available post-consumer profile waste in Europe by 2030, the association considers the REACH restriction to be an important first step on which further measures need to build: waste and product legislation must follow the example of REACH, where a thorough scientific assessment of the risks, socio-economic impacts and environmental effects have lead to the conclusion that traceable closed loop recycling is the right way forward. "We call on national and European legislators to pave the way for our industry to further increase the amounts of PVC recyclate used by harmonizing applicable EU rules to the just adopted lead (pb) in PVC restriction. Applications recycled in a safe, traceable, closed loop must not be subject to any additional barriers on the market", says Carsten Heuer.

Based on a current building stock of over 600 million PVC windows in Europe, the industry expects a linear increase of available end-of-life PVC window volumes over the next years. The implementation of the EU renovation wave is bound to further reinforce this trend.