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

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.